CopperEye Labs Limited ("CopperEye") respects your privacy and is committed to protecting the personal information that you provide to us.

This Privacy Policy (as updated and amended from time to time) describes our current policies and practices with regard to Personal Data collected by us from you directly and/or through our web site (www.coppereye.com) where such Personal Data is protected by the Data Protection Act 1998 ("DPA"). The term "Personal Data" refers to personally identifiable information about you, such as your name, job description, birthday, e-mail address or mailing address.

The terms "CopperEye", "we", "us", "our" and "ours" when used in this Privacy Policy mean CopperEye Labs Ltd, including without limitation all our offices, branches and subsidiaries existing from time to time.

The terms "you", "your" and "yours" when used in this Privacy Policy mean any user of our web site, enquirer (on-line and off-line), customer, employee or consultant of CopperEye.

This statement explains our policies and practices regarding the use and disclosure of your Personal Data by CopperEye. If and when our data practices change, we will notify you of the changes by posting our updated Privacy Policy on our web site. Therefore, you should visit our web site regularly to review the terms of this Privacy Policy and make sure that you are aware of how CopperEye collects and uses your Personal Data.

By submitting Personal Data manually or in electronic form to us and/or by using our web site, you consent to the collection and use of your personal information by CopperEye as explained below.

What information do we collect about you?

You may provide us with your Personal Data in order to receive information, advice, products or services from us or in connection with a job application or employment by us.

CopperEye offers access to some services that require registration. We may use your registration contact information to send notification to you of CopperEye products and services and third party products and services that we think may be of interest to you by e-mail and/or postal mail and to provide a personalized service to you. An option is provided when registering with CopperEye to opt out of such email notifications; the same opt-out option will be provided in every piece of email sent to you by CopperEye.

We may also request your e-mail address or mailing address for the purposes of conducting a survey or to provide additional services (for example, subscriptions to e-mail newsletters, announcement lists or information about conferences and trade shows). Whenever we request the identity of a visitor, we will clearly indicate the purpose of the inquiry before the information is requested. We maintain a strict "No-Spam" policy that means that we do not sell, rent, or otherwise give your e-mail address to a third-party for marketing purposes, without your consent or as permitted by this Privacy Policy.

We may from time to time send e-mail announcements of new CopperEye products and services. Except as stated above, CopperEye will not send you e-mails that you have not agreed to receive.

When you register for a contest or other promotion, we may ask for your name, address, and e-mail address so we can administer the contest and notify winners.

We sometimes supplement the information that you provide with information that is received from third parties. For instance, if inaccurate post codes are received, we will use third party software to fix them.

To comply with money laundering regulations, we may need to request additional evidence of identity from you, and may use a credit reference agency for this purpose (who will record that an enquiry has been made).

We also reserve the right to monitor, intercept and/or record your communication with us by mail, voice, email or any other form of transmission for the purposes of quality control, security, to comply with our regulatory obligations and other business needs. We may reject, delay or remove content from emails which have a nature, content or attachments which may disrupt our system or because they may pose security risks or which we suspect may pose security risks. We may also filter out emails which contain certain content which is deemed offensive or unwanted spam. Unavoidably such filtering may affect the delivery of some "innocent" emails. Any Personal Data contained in such recorded information will be processed in accordance with the terms of this Privacy Policy.

We may also receive your Personal Data from our service providers, agents, advisers, persons with whom we do business on your behalf or other business partners. Where Personal Data is disclosed to us by third parties, it is the obligation of the disclosing party to ensure such Personal Data is disclosed with requisite authority and consent and we will process such Personal Data in accordance with this Privacy Policy.

How do we use your personal information?

We process your Personal Data, and share your Personal Data with our offices, branches and subsidiaries and with third parties only for specific and limited purposes. We ask only for Personal Data that is adequate, relevant and not excessive for those purposes. Some of these purposes may include the following:

• To provide the products and services you request from us, and all related information.
• To process your registration form(s) and competition entries.
• To process and respond to your inquiries and requests for information and/or products and/or services.
• To send you newsletters, update emails and other information you request.
• For the purposes of processing, servicing and maintaining accounts and transaction records.
• To monitor and archive communications with you.
• To contact you occasionally to inform you of products and services provided by us or third parties whose products and/or services we think you may be interested in. We may contact you by letter, telephone or email for this purpose.
• To carry out credit checks, "know your client" checks, identification authentication or verification checks.
• To comply with legal and regulatory requirements and to resolve disputes.
• To help diagnose any problems with our customer database, server and administer our website.
• To process your job application and other employment related matters.

Will we disclose your information to outside third parties?

We do not share with, nor rent nor sell nor distribute your Personal Data to unrelated third parties, except under these limited circumstances:

• We may share various details about you within CopperEye, including sharing your Personal Data with our offices, branches and subsidiaries as required in order to provide you with the specific products and/or services you have requested and to look after your needs. For example, we may share your Personal Data for the purposes of providing you with information about specific products and services, or to process your registration form(s) and competition entries, or to send you newsletters and update emails, or to update and maintain our databases, IT systems and accounts, or to process your job application and other employment related matters.
• Personal Data may occasionally be transferred to third parties who act for us for further processing in accordance with the purposes for which the Personal Data was originally collected or for purposes to which you have consented or otherwise in accordance with this Privacy Policy. For example, these non-affiliated third parties may be services providers (such as call centre operators, web hosting companies, mailing houses or technology companies that need to process your Personal Data in order to help us develop, operate and maintain our services and systems) or professional services providers (such as legal, accounting and consulting service providers).
• Unless you have given us your consent to the processing of your Personal Data in accordance with this Privacy Policy (which includes sharing or other disclosing), we will not share or disclose your Personal Data to any unrelated third parties for their own marketing purposes.
• We may share or transfer the information in our databases to comply with a legal or regulatory requirement, for the administration of justice, interacting with anti-fraud databases, to protect your or our interests, to protect the security or integrity of our databases or our web site, to take precautions against legal liability, or in the event of our sale, merger, reorganization, transfer of business, dissolution or similar event.
• If we sell or buy any business or assets we may disclose your Personal Data to the prospective seller or buyer of such business or assets.

Where appropriate, before disclosing Personal Data to a third party, we will contractually require the third party to take adequate precautions to protect that data and to comply with applicable law.

What anonymous information do we collect through our website and how do we collect it?

Every computer connected to the Internet is given a domain name and a set of numbers, which serve as that computer's "Internet Protocol" IP address. When a visitor requests a page from the CopperEye web site, our web servers automatically recognize that visitor's domain name and IP address. The domain name and IP address reveal nothing personal about you other than the IP address from which you have accessed our site. We use this information to examine our traffic in aggregate, and to investigate misuse of the CopperEye web site, its users, or to cooperate with law enforcement. We do not collect and evaluate this information for specific individuals. Our Web servers do not automatically record e-mail addresses of the visitors.

Do we use cookies on our website?

We only set cookies on the download registration form in order to prevent you from having to re-register to gain access to other downloads. No personal information is set in the cookie.

Cookies by themselves cannot be used to discover the identity of the user. A cookie is a small piece of information which is sent to your browser and stored on your computer's hard drive. Cookies do not damage your computer. You can set your browser to notify you when you receive a cookie. This enables you to decide if you want to accept it or not. If you choose not to accept cookies from our websites you may not be able to access and use all of part of such web sites or benefit from the information and services they offer. The IAB website at www.allaboutcookies.org tells you how to remove cookies from your browser.

Data integrity and security

We strive to maintain the reliability, accuracy, completeness and currency of Personal Data in our databases and to protect the privacy and security of our databases. The security measures in place on our web site and computer systems, aim to protect the loss, misuse or alteration of the information you provide to us. We keep your Personal Data only for as long as reasonably necessary for the purposes for which it was collected or to comply with any applicable legal or regulatory requirements, or our data retention policy.

Links from our web site to third party websites

Our web site may contain hyperlinks to web sites that are not operated by us. Any such hyperlinks are provided for your reference and convenience only and do not imply any endorsement of the activities of these third-party web sites or any association with their operators. We do not control these web sites and are not responsible for their data or privacy practices. We urge you to review any privacy policy posted on any web site you visit before using the web site or providing any Personal Data about yourself.

Transfer of Personal Data abroad

We may transfer your Personal Data to our branches and offices and third party processors which may be located outside the European Economic Area ("EEA"). Where your Personal Data is transferred outside the EEA we will ensure that the recipient agrees to keep your information confidential and hold it securely in accordance with the requirements of the DPA.

When you visit our web site, the various communications will result in the transfer of information across international boundaries.

By providing us with your Personal Data, you consent to us transferring your Personal Data abroad, including outside the EEA.

Unsubscribing from our mailing list

When you sign up for a CopperEye e-mail newsletter or off-line update, you should only receive the information you affirmatively select. Each e-mail sent by CopperEye contains information on unsubscribing from lists to which a user may have previously opted-in. If you no longer wish to receive information from us and want to be removed from our mailing list you can "unsubscribe" by email or by post by contacting us at the following address:

The Data Protection Officer

CopperEye Labs Limited

1 St. Andrew's Hill, London EC4V 5BY

email: marketing@coppereye.com

Please allow twenty eight days for the unsubscribe process to be completed.

Please remember that stopping the information that you receive from us about our products and services may not benefit you. For example, you may not hear about our new products and services that may be more beneficial to you and save you money.

If you do not want to receive unsolicited postal mail from any source, you can stop this by registering with the "Mailing Preference Service" in the UK. There are also telephone, fax and email preference services. For more information on the preference services, please visit the Direct Marketing Association's website.

Data access and correction

Upon receipt of a written subject access request and enough information to permit us to identify your Personal Data, we will (subject to the exceptions to the requirement to disclose under the DPA) disclose to you the Personal Data we hold about you, for which we may make a small charge.

We encourage you to ensure that your Personal Data is accurate and kept up to date. Please regularly update any information you have given to us by sending an email to info@coppereye.com or by writing to us at the address below. We will correct any Personal Data that you notify us is inaccurate and notify any third party recipients of necessary changes.

Requests to delete Personal Data are subject to any applicable legal and regulatory requirements or document retention obligations and any of our current contracts which are still in force.

If you wish to make a subject access request, relating to Personal Data held about you by us, please write to:

The Data Protection Officer

CopperEye Labs Limited

1 St. Andrew's Hill, London EC4V 5BY

email: marketing@coppereye.com

Feedback

We welcome comments about this Privacy Policy. If you have any questions about this Privacy Policy, including use of your Personal Data, or any part of our service, you may contact us by emailing marketing@coppereye.com.

Governing Law

This Privacy Policy governs how we process your Personal Data collected both on-line and off-line. When viewed on-line, this Privacy Policy forms part of our website Terms of Use which can be viewed at www.coppereye.com. This Privacy Policy shall be governed by and construed in accordance with the laws of England. You agree to submit any dispute arising out of or in connection with our processing of your Personal Data to the exclusive jurisdiction of the courts of England.