Robert Pruzan PRIVACY NOTICE

1. About this notice

This notice (the “Privacy Notice”) provides information about how Robert Pruzan ( “we”, “us”, or “our”) gathers and uses personal information. We are committed to respecting the confidentiality of the personal information you supply to us and all data will be processed in accordance with applicable data privacy laws.

This is why we are providing you with the information in this Privacy Notice.

If you do not agree with our use of your personal data as set out in this Privacy Notice, you should not submit your personal information to us. However, if you do not wish to submit your personal information, or if you wish to exercise your rights to prevent us using your data, you should be aware that we may not be able to do business with you. For more information on this, please see sections 9, 10, and 11.1.

2. About us

We are Robert Pruzan, registered at 31 West 52nd Street, 22nd Floor, New York, NY 10019 USA. Which Robert Pruzan entity is the controller of your personal data will depend on the relationship that we have with you, the data in question and how and why we are using it.

3. Contacting us

Should you have any questions or concerns about this Privacy Notice or the processing of personal data we hold about you, please contact us:

In the US:

By post: 31 West 52nd St., 22nd Floor, New York, NY 10019
By phone: 888-497-3340
By email: privacy@centerview.com

4. Information we collect

We collect your personal information from a variety of sources, as set out in this Privacy Notice. Where necessary we collect information directly from you or indirectly from third parties, and through your use of our website.

4.1 Information you provide to us

This section details the information we collect about you in the course of your relationship with us and otherwise in your interaction and correspondence with us and our representatives. We will collect:

• • basic personal details of certain directors or other individuals for client verification purposes such as name and address (and proof of name and address), email address, telephone number, and any other contact details you supply to us;
  • details of your company’s directors, shareholders, secretaries, authorised signatories and identification documents;
  • banking details;
  • details of business advisers you employ including your advisers;
  • records of all communications including electronic communications with our staff and meeting notes (see below for more details); and
  • employment and education history, references, skills, and information related to your candidacy (where you send us this information as part of a job application process).

Please note that we keep copies of electronic communications. In certain areas, we are required to keep copies of these electronic communications for a period of at least five years (or up to seven years at the request of a regulator).

4.2 Information we collect from other sources

We will receive information about you from third parties. We will collect the following information from third parties:

• • data received from background checks related to the job application process. This may include criminal record checks and credit history or bankruptcy checks as required for regulatory purposes;
  • data received from due diligence activities (such as anti-money laundering, politically exposed persons and sanctions checks);
  • fraud enquiries (for example, information from police reports);and
  • basic personal details, and employment and education history (where we are sent this information by you or an employment agent).

In the context of the provision of our services we may receive personal information from third parties such as your employer, other parties relevant to the services we are providing (e.g., counterparties in transactions) and others such as regulators and authorities. That information could include your name, contact details, employment details and other information relevant to the services that we are providing to our client.

5. How we use the information we collect

The information which we collect and what we use it for will depend on the nature of our business relationship with you. We use your information:

• to provide our services and to fulfil our contractual obligations to third parties;
• for our internal business administration and record keeping purposes;
• for legal and regulatory compliance purposes, including as necessary to respond to governmental, regulatory or law enforcement agency requests;
• where required or considered appropriate, carrying out ‘know-your-client’ (KYC) checks and other procedures that we undertake prior to you becoming a client of ours and in the course of our ongoing business relationship;
• for recruitment and evaluating your candidacy as a job applicant; and
  to send invitations, marketing materials, updates or other publications that we feel may be of interest to you and to organise events. You may opt out of these materials at any time by following the instructions in the invitation, email, update, or publication.

6. Sharing your information

We will not disclose your personal information to third parties except as detailed in this Privacy Notice. Further, we do not sell your personal information.

Where necessary, we disclose your personal data to third parties that are specifically engaged by us to provide services to us, in which case we will require those parties to keep that information confidential and secure and to use it solely for the purpose of providing the specified services to us. We may provide your information to third parties engaged by us to provide services to us, including:

• professional advisers, including accountants, auditors, compliance consultants, legal advisers and tax advisers;
• fraud prevention agencies;
• information technology providers, including providers of client relationship management systems, and information security providers;
• administrative service providers;
• employment agents; and
• data storage suppliers;
• we may disclose to law enforcement agencies and regulators, government departments or competent authorities of the UK, the US, France or of other countries any personal data (including tax status, identity or residency or other personal and payment information, documents or self-certifications) where we are under a duty to disclose or share your information in order to comply with any legal or regulatory obligation, or if we reasonably consider that this is necessary to help prevent or detect fraud or other crime or to protect our rights, property, or safety, or that of our customers or others. Such disclosure may be made directly to such regulators or competent authorities or made indirectly to our advisers or providers who will make such filings or disclosures on our behalf;
• if we are under a duty to disclose or share your information with HM Revenue & Customs (HMRC) or other tax authorities, who may transfer it to the government or the tax authorities in another country where you may be subject to tax. Such disclosure may be made directly to such regulators or competent authorities or made indirectly to our advisers or providers who will make such filings or disclosures on our behalf; and
• if you have consented to any disclosure to a third party.

7. Security

We acknowledge that the information you provide may be confidential and will maintain the confidentiality of and protect your information in accordance with our normal procedures and all applicable laws. We employ appropriate technical and organisational security measures to help protect your personal data against loss and to guard against access by unauthorised persons. We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

In addition, those employees, agents, contractors and other third parties who process your personal data will only do so on our instructions and they will be subject to a duty of confidentiality.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data. Any transmission is at your own risk. Once we have received your information, we will use procedures and security features to try to prevent unauthorised access.

8. Changes to our Privacy Notice

We reserve the right, at our discretion, to change, modify, add to, or remove portions from, our Privacy Notice. We will of course notify you of any changes where we are required to do so.

NOTICE TO DATA SUBJECTS IN CALIFORNIA

9. Your rights

Under the California Consumer Privacy Act (CCPA), California residents have the right, with respect to applicable personal information, and following a verifiable request, to:

• access—twice in a 12-month period, free of charge—for the 12-month period prior to the request, the categories and specific pieces of personal information we have collected about you, the categories of sources from which the personal information is collected, the business purpose for collecting the personal information, and the categories of third parties with whom we share that personal information;
• delete personal information under certain circumstances (unless we are legally entitled or required to retain it);
• opt-out of the sale of personal information (if a business sells personal information, which, as noted above, Robert Pruzan does not);

Such requests may be made by emailing us at privacy@centerview.com or calling us at 888-497-3340. We do not discriminate against our users on the basis of their exercising any of their rights afforded by the CCPA, which is further in accordance with California residents’ rights under that title.

Following any request, we will verify your identity using at least two data points you have previously provided to us. Please have this information available so that we can verify your request. You may also authorize an agent to submit a request on your behalf, so long as you provide the authorized agent written permission to request on your behalf, and your authorized agent is able to verify their identity with us.

FOR DATA SUBJECTS WITHIN THE UK AND EUROPEAN UNION

10. Our bases for collecting and using the information

We are entitled to use your personal data in the ways set out in this Privacy Notice on the following bases:

• we have legal obligations that we have to discharge;
• the use of your personal data is necessary for our legitimate interests in:
• providing services requested by your employer or company under contract;
• for legal and regulatory compliance purposes
• communicating with you;
• statistical analysis;
• to effect a reorganisation of our business;
  • you have consented to such use; and/or
  • to establish, exercise or defend our legal rights for the purposes of legal proceedings.

If you do choose to provide your consent you can withdraw it at any time by contacting us (see section 3).

11. Your rights

You have certain rights in relation to your personal data.

11.1 Your rights in connection with personal information

Under certain circumstances, by law you have the right to:

• • Object to processing of your personal information where we are relying on a legitimate interest (or that of a third party) and there is something about your particular situation which makes you want to object to processing on this ground.
  • Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are processing it lawfully.
  • Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
  • Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see above).
  • Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
  • Request the transfer of your personal information to another party in a machine-readable, commonly used and structured format.

If you want to exercise any of these rights, then please contact us using the details at section 3. The various rights are not absolute and each is subject to certain exceptions or qualifications. For example, if you wish to withdraw your consent or object to processing, we may need to discuss with you whether our use of your data needs to continue for other lawful purposes, such as fulfilment of a legal or contractual requirement.

We will respond to your request within one month of receipt of your request. In some cases we may not be able to fulfil your request to exercise the right before this date, and may need to apply our right to extend the time in which we will respond. Where we cannot provide a full response to you for any reason, we will let you know about this in our initial reply to your request.

11.2 Your duty to inform us of changes

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.

11.3 Fees

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). In some cases, we may charge a reasonable fee if your request for access is clearly unfounded or excessive, or if you request multiple copies of the information. Alternatively, we may refuse to comply with the request in such circumstances.

11.4 What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

11.5 Right to complain

If you wish to request further information about any of the above rights, or if you are unhappy with how we have handled your information, please contact us on the contact details contained in section 3.

If you are not satisfied with our response to your complaint or believe our processing of your information does not comply with data protection law, you can make a complaint to the relevant data protection authority. We can advise you which authority is relevant to your personal data if you contact us on the contact details contained in section 3.

12. Where we store your information

We transfer, use and/or store your personal information outside of the UK and the European Economic Area (“EEA”) and the laws of some of these destination countries may not offer the same standard of protection for personal information as the UK and countries within the EEA. It may also be processed by staff operating outside the UK and the EEA who work for us or for one of our suppliers (for example, those who supply support services to us).

We currently transfer your personal information to the following countries outside of the UK and EEA:

• United States of America; and
• Canada.

We may also transfer your personal information to other countries outside of the UK and EEA from time to time. Transfers to our third party service providers are required to enable them to use and store your personal information on our behalf. Where we transfer your personal information outside the UK and EEA we will put in place appropriate security procedures in order to protect your personal information. Where your information is transferred outside the UK or to any country outside the EEA, we ensure that this is done using specific legally-approved safeguards. You can request further details and a copy of these safeguards by contacting us (see section 3).

13. Keeping your information

We will keep your information only for as long as necessary depending on the purpose for which it was provided. When determining the relevant retention periods, we will take into account factors including:

• our contractual and business relationships with you;
• legal obligations under applicable law to retain data for a certain period of time;
• statute of limitations under applicable law(s);
• (potential) disputes; and
• guidelines issued by relevant supervisory authorities.