March 2018 Industry snapshot

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PRIVACY NOTICE - Nordhaven Corporate Finance

Nordhaven Corporate Finance comprises the separate legal entities Nordhaven Corporate Finance AB, Stockholm, Nordhaven Corporate Finance AS, Oslo and Nordhaven Corporate Finance Oy, Helsinki.

The statement below is the joint privacy statement of Nordhaven Corporate Finance. At Nordhaven Corporate Finance we focus on implementing fair information practices that are designed to protect your privacy. If you have questions or complaints, or if you feel that your concerns have not been addressed in our privacy statement below, you can contact us respectively at:

As regards Nordhaven Corporate Finance, Stockholm: Tel: +46 85 025 6700 E-mail: stockholm@nordhaven.com Business ID: 559123-6038

As regards Nordhaven Corporate Finance, Oslo: Tel: +47 901 07 708 E-mail: oslo@nordhaven.com Business ID: 979 157 886

As regards Nordhaven Corporate Finance, Helsinki: Tel: +358 207 613910 E-mail: helsinki@nordhaven.com Business ID: 1000611-5

We at Nordhaven Corporate Finance are engaged to process your personal data and other data relating to you reliably, securely, and in a transparent manner. In this Privacy Notice, we describe how we collect and process personal data of our clients, potential clients, and other business contacts.

The joint controllers of your personal data, as described herein, are the Nordhaven Corporate Finance offices in Sweden, Norway and Finland. Should you have any questions relating to the processing of your personal data, or should you wish to use your rights as a data subject, please contact us by using the contact details set out above.



1 Collection of Personal Data

As a corporate finance service provider, we regularly receive and process personal data in connection with our B2B business operations, for example in connection with our business promoting activities and when performing and managing client assignments. “Personal data” are data that can be used to identify you or data that can otherwise be linked to you. We mainly process personal data which we obtain from you directly, for example when you send emails to us or communicate with us through other channels in connection with the activities described above or when you sign up for an event organised by us. Where applicable, we also process your personal data obtained from publicly available sources, such as your employer’s or organization’s website, and personal data that accumulates from your use of our website. We also receive personal data through job applications submitted to us. We may typically process the following types of your personal data:

• basic information, such as your name, your contact information (email address, other address, phone number(s)), your employer or organization, your title or position in your organization;
• information you provide to us for the purposes of attending meetings and events as well as information about your participation in our events;
• identification information provided by you or collected by us as part of our business promoting activities and business intake procedures in compliance with applicable laws;
• personal data of individuals provided to us by or on behalf of our clients, our clients’ other advisors, partners, third parties involved in our projects or generated by us in the course or providing services; and
• any other information relating to you which you may provide to us.

2 How We Use Personal Data

We use the personal data we collect for the following purposes:

• he performance, management and administration of our business relationship with you and/or your organisation, such as the performance and management of client assignments and provision of services, also including the processing of payments, accounting, auditing, billing, and collection as well as related support services;
• business development and marketing, such as (i) communicating with you by way of announcements, newsletters, events and our other services which we think that may be of interest to you; (ii) maintaining our contact and B2B marketing lists, and (iii) compiling statistics and improving our services and communications, for example by gathering information regarding your preferences through methods such as by utilizing “cookies” and other website analytics or the tracking of our client publications to improve the quality of our communications and interaction with you;
• handling and storing job applications; and
• compliance with our legal obligations, including obligations with respect to anti-money laundering and sanctions checks as well as other legal and regulatory requirements.

3 The Legal Basis for Processing Personal Data

When processing your personal data for the purposes described in this Privacy Notice, we process your data in the performance of our client assignments, based on our legitimate interest in maintaining our business relationship and in promoting and marketing B2B business relationships towards our contacts as well as based on job applications received by us. Our view is that you participating in our activities or otherwise communicating with us creates a meaningful business relationship between us, a legitimate interest for us to approach you by promoting and marketing B2B business relationships and opportunities as well as a legitimate interest for us to process your personal data for ordinary communication and marketing purposes.



4 How We May Share and Transfer Personal Data

We do not sell, rent, distribute, or otherwise make your personal data available to any third party except as described below.

We may share personal data with our suppliers when they perform services on our behalf, mainly to maintain and support our IT systems and to process data, including personal data, on our behalf. However, such suppliers are obliged to process the data on our behalf and for the abovementioned purposes only.

We may share information among our Nordhaven Corporate Finance offices and among other member firms of Clairfield International.

We may also transfer personal data to third parties such as other client advisors and other third parties involved in our client assignments and in our business promotion discussions which may have a link with you or your organization, including third parties based outside the European Union (the “EU”) and the European Economic Area (the “EEA”).

If we transfer personal data outside the EU or the EEA, such transfer will be performed subject to appropriate safeguards required by applicable data protection laws.

We use MailChimp as a data processor in the circulation of our newsletters, targeted announcements and other targeted B2B business promoting circulations distributed by e-mail. MailChimp is based in the USA and is certified within the EU - U.S. Privacy Shield Framework and the information is protected in compliance with the General Data Protection Regulation.

We take appropriate technical and organisational measures against unauthorised or unlawful processing of personal data and against accidental loss or destruction of, or damage to, personal data in accordance with our internal security procedures covering the storage and destruction of personal data as well as access to personal data. We regularly check our security policies and procedures to ensure our systems are secure and protected.



5 How Long We Will Store Personal Data

Your personal data will be stored for the purposes mentioned above for as long as we have a meaningful B2B business contact, other meaningful contact, a B2B marketing or business promotion interest, an interest in maintaining a meaningful contact possibility for the purposes of our operations or as may otherwise be required by law. If the processing of your personal data is no longer necessary for the purposes they were collected or received, we will delete or anonymise the personal data relating to you in a secure manner. We may retain your personal data for a longer period to the extent required by our automated disaster recovery backup systems or to the extent we deem the data necessary to assert or defend legal claims during any relevant retention period.



6 Your Rights relating to the Personal Data

You have the right to:

• request a copy of the personal data we process relating to you;
• request the correction of incorrect personal data relating to you and in some cases the deletion of your personal data;
• request the restriction of processing of your personal data or to object to processing; and
• receive, under certain preconditions, your personal data in a structured, commonly used, and machine-readable format, and the right to transmit those data to another data controller.

In addition, you have an express right to ask us not to send you marketing-related communications.

Please note that if we restrict or delete your personal data, this may result in us not being able to provide to you the communications and invitations described above.

If you consider that your rights under the applicable data protection laws have been infringed, you may lodge a complaint with the competent data protection authority in the relevant country.



7 Updates

This Privacy Notice has been updated in May 2018. We reserve the right to amend this Privacy Notice from time to time without separate notice.