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Privacy Policy

1. Scope

Taylor Maritime Investments Limited (Company, We, Our, Us) is an investment company incorporated in Guernsey and which is seeking admission to the premium segment of the Official List and the Main Market of the London Stock Exchange. We are committed to safeguarding the privacy and confidentiality of the personal data entrusted to us, and have implemented policies and controls to ensure the security of your personal data. This Privacy Policy relates solely to our processing of personal data where the share register services and administration and related services of our business are delivered. In the event that additional processing is required, we may issue a further supplementary privacy notice specifically in relation to that processing.

This Privacy Policy is addressed to the following categories of data subjects:

  • our shareholders;
  • our beneficial owners;
  • our directors;
  • staff located at our affiliates; and
  • third party supplier contacts.

The Company’s website may contain links to other third party websites. If you follow a link to any of those third party websites, please note that they have their own privacy policies and that the Company does not accept any responsibility or liability for their policies or processing of your personal data. Please check these policies before you submit any personal data to such third party websites.

2. Purpose

The purpose of this Privacy Policy is to allow you to understand what personal data the Company will collect (or which will be collected on its behalf), how we will use it, and who may access it.

By providing your information to us, whether via our website, in person, in writing, via one of our service providers or over the phone, you acknowledge the processing set out in this Privacy Policy. Further notices highlighting certain uses we wish to make of your personal data together with the ability to opt in or out of selected uses may also be provided to you when we collect personal data from you.

3. Personal data that the Company collects

The Company only collects the personal data that we determine is required for the purposes set out at Section 4: Purposes for which we use your personal data, below. We may collect:

Information you provide to the Company Personal data that you provide to the Company, such as when contacting us using the email or physical address(es) listed on our website, including your name, email address, bank account details (where required) and other contact details;

In relation to shareholders only, information relating to your shareholding share register services are outsourced to registrars, which hold the majority of this personal data. We periodically receive reports listing our shareholders;

KYC and due diligence information information obtained by third party screening providers and publicly available information and background screening, where required by law or applicable financial regulations;

Our correspondence if you contact us, we will typically keep a record of that correspondence. This may include telephone calls in relation to management of shareholdings, and you will be informed that any call is being recorded. If you object to this, you can end the call at that point and utilise an alternative method of communication should you prefer;

Device Information such as information about your operating system, browser, software applications, geolocation, security status and other device information in order to improve your experience, to protect against fraud and manage risk; and

Website and communication usage details of your visits to the Company’s website and information collected through cookies and other tracking technologies including, but not limited to, your IP address and domain name, your browser version and operating system, traffic data, location data, web logs and other communication data, and the resources that you access.

4. Purposes for which we use your personal data

When the Company collects your personal data, we may use or disclose it for the following purposes. Below each purpose the Company notes the “lawful basis” that allows that use of your personal data. An explanation of the scope of the “lawful bases” can be found at Annex A to this Privacy Policy.

To understand who our shareholders/beneficial owners are and undertake reporting and analysis Our corporate records contain information in respect of shareholders/beneficial owners to include names and addresses, account designations and the amount of shares held. We share this information with our authorised brokers to undertake reporting analysis.

Lawful bases: legitimate interests (to understand our shareholder demographic and undertake reporting and analysis); legal obligations; legal claims (where applicable)

To maintain our share register we may process your personal data to set-up, maintain and update the register of our members, to prepare and issue share or stock certificates, to receive and deal with transfers, probates, powers of attorney, changes of address, and all similar documents normally needed to maintain the register, to deal with telephone enquiries for shareholders, to maintain and update dividend and interest payment instructions and account details, to make dividend payments, to deliver Annual Report and Accounts and Interim Reports, to assist with proxy voting and to enable you to use online platforms which enable you to vote by proxy and access and manager your shareholdings.

Lawful bases: legitimate interests (to manage your shareholding); legal obligations, contractual necessity; legal claims (where applicable)

For administrative purposes we may process your personal data to arrange for payment of directors fees, deal with queries, pay dividends, organise and minute all meetings, liaise with directors regarding meetings and board packs, assist with the arrangement of travel, accommodation and directors’ requirements for board and committee meetings, maintain and keep a register of declared interests, advising directors and monitoring directors’ interests and conflicts.

Lawful bases: legitimate interests (to make corporate decisions and ensure that our directors are engaged consulted appropriately); legal obligations; legal claims (where applicable)

To comply with legal or regulatory requirements, or as otherwise permitted by law we may process your personal data to comply with our regulatory requirements (for example, to comply with KYC, anti-money laundering or insider dealing requirements) or dialogue with our regulators or to defend or prosecute claims. This may involve background checks including screening against PEP, sanctions and/or anti-money-laundering databases on a periodic basis.

It is possible that special categories of personal data (e.g. political opinions, religious beliefs, ethnicity) and/or data relating to criminal convictions or offences may be received as a result of these background checks where such information has been made public or is relevant to the necessary checks.

Lawful bases: legal obligations; legitimate interests (to cooperate with law enforcement and regulatory authorities); legal claims (where applicable). Where special categories of personal data or data relating to criminal convictions or offences is processed, we will rely on substantial public interest (fraud prevention) or legal claims, as applicable.

To inform you of changes to notify you about changes to the Company’s services and products;

Lawful bases: legitimate interests (to notify you about changes to the Company’s services)

To re-organize or make changes to the Company’s business in the event that the Company (i) is subject to negotiations for the sale of the Company’s business or part thereof to a third party, (ii) is sold to a third party or (iii) undergoes a re-organization, we may need to transfer some or all of your personal data to the relevant third party (or its advisors) as part of any due diligence process for the purpose of analysing any proposed sale or re-organisation. The Company may also need to transfer your personal data to that re-organised entity or third party after the sale or re-organisation for them to use for the same purposes as set out in this policy;

Lawful bases: legitimate interests (in order to allow the Company to change its business); legal claims (where applicable)
To communicate effectively with you and conduct the Company’s business to conduct the Company’s business, including to respond to your queries, to otherwise communicate with you (and keep a record of that communication, including recordings of telephone conversations relating to your shareholding), or to carry out our obligations arising from any agreements entered into between you and the Company.

Lawful bases: contract performance; legal obligation (the share registrar is legally required to record all conversations that result or good result in placing a trade); legitimate interests (to enable the Company to perform its obligations and provide its services to you, for the purposes of maintaining service standards and, if applicable, for the prevention, detection, investigation and prosecution of fraud); legal claims (where applicable)

5. Sharing your personal data (and transfers outside of the EEA)

The Company will only use or disclose your personal data for the purpose(s) for which it was collected and as otherwise identified in this Privacy Policy.

Sharing outside of the Company: personal data may be provided to third parties, including our brokers, share registrars, administrators, legal advisors, auditors, financial advisors, regulatory authorities or other self-regulatory organisations (when required to satisfy the legal or regulatory requirements of governments), regulatory or law enforcement authorities (where required or in cases of suspected criminal activity or contravention of law), or to comply with a court order or for the protection of our assets.

Transfers outside of the EEA: Your personal data may be accessed by suppliers or other persons in, transferred to, and/or stored at, a destination outside the EEA in which data protection laws may be of a lower standard than in the EEA. The Company will, in all circumstances, safeguard personal data as set out in this Privacy Policy.

Where the Company transfers personal data from inside the EEA to outside the EEA, The Company may be required to take specific additional measures to safeguard the relevant personal data. Certain countries outside the EEA have been approved by the European Commission as providing essentially equivalent protections to EEA data protection laws and therefore no additional safeguards are required to export personal data to these jurisdictions. In countries which have not had these approvals (see the full list here http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm), The Company will establish legal grounds justifying such transfer, such as EU Commission-approved model contractual clauses, or other legal grounds permitted by applicable legal requirements.

Please contact us at the email address provided in the Contact Us section below if you would like to see a copy of the specific safeguards applied to any export of your personal data.

6. Retention of your personal data

The Company’s retention periods for personal data are based on business needs and legal requirements. The Company retains your personal data for as long as is necessary for the processing purpose(s) for which the information was collected, and any other permissible, related purpose. For example, the Company may retain certain transaction details and correspondence until the time limit for claims arising from the transaction has expired, or to comply with regulatory requirements regarding the retention of such data. When personal data is no longer needed, the Company either irreversibly anonymises the data (and the Company may further retain and use the anonymised information) or securely destroys the data.

6. Retention of your personal data

The Company’s retention periods for personal data are based on business needs and legal requirements. The Company retains your personal data for as long as is necessary for the processing purpose(s) for which the information was collected, and any other permissible, related purpose. For example, the Company may retain certain transaction details and correspondence until the time limit for claims arising from the transaction has expired, or to comply with regulatory requirements regarding the retention of such data. When personal data is no longer needed, the Company either irreversibly anonymises the data (and the Company may further retain and use the anonymised information) or securely destroys the data.

7. Safeguarding your personal data

The Company uses physical, electronic and procedural safeguards to protect against unauthorised use, access, modification, destruction, disclosure, loss or theft of your personal data in the Company’s custody or control.
The Company has agreements and controls in place with third party service providers requiring that any information the Company provides to them must be safeguarded and used only for the purpose of providing the service the Company has requested the company to perform.

Security over the internet

No data transmission over the Internet or website can be guaranteed to be secure from intrusion. However, the Company maintains commercially reasonable physical, electronic and procedural safeguards to protect your personal data in accordance with data protection legislative requirements.

All information you provide to the Company is stored on our or our subcontractors’ secure servers and accessed and used subject to the Company’s security policies and standards. You are responsible for complying with any other security procedures of which you have been notified by the Company.

8. Changes to this Privacy Policy

From time to time, the Company may make changes to this Privacy Policy.

Please contact us to ask any questions you may have about this Privacy Policy.

9. Your Rights

If you have any questions in relation to the Company’s use of your personal data, you should first contact the Company at the email address provided in the Contact Us section below. Under certain conditions, you may have the right to require the Company to:

    • provide you with further details on the use the Company makes of your information;
  • update any inaccuracies in the personal data the Company or its service providers hold;
  • delete any personal data that the Company no longer has a lawful ground to use;
  • where processing is based on consent, to withdraw your consent so that the Company stops that particular processing;
  • object to any processing based on the legitimate interests ground unless the Company’s reasons for undertaking that processing outweigh any prejudice to your data protection rights; and
  • restrict how the Company uses your information while a complaint is being investigated.

 

Your exercise of these rights is subject to certain exemptions to safeguard the public interest (e.g. the prevention or detection of crime) and the Company’s interests (e.g. the maintenance of legal privilege). If you exercise any of these rights, the Company will check your entitlement and respond in most cases within a month.

If you are not satisfied with the Company’s use of your personal data or the Company’s response to any exercise of these rights you have the right to complain to your local data protection regulator. The relevant regulators are listed here.

Jurisdiction Data Protection Regulator
UK Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AFEmail: dataprotectionfee@ico.org.ukTelephone: 0303 123 1113
Guernsey Office of the Data Protection Commissioner
St Martin’s House
Le Bordage
St Peter Port
Guernsey
GY1 1BR
Email: enquiries@odpc.gg
Telephone: +44 (0)1481 742074

Contact Us

If you have any questions or concerns about our privacy practices, the privacy of your personal data or you want to change your privacy preferences, please contact the Company at Taylormaritme@sannegroup.com or at its registered office for the attention of Sanne Fund Services (Guernsey) Limited, at 1 Royal Plaza, Royal Avenue, St Peter Port, Guernsey GY1 2HL 

If after contacting the Company you do not feel that the Company has adequately addressed your concerns, you may contact your local data protection regulator identified above.

ANNEX A: Table of Lawful Bases

Use of personal data under EU data protection laws must be justified under one of a number of legal “grounds” and the Company is required to set out the grounds in respect of each use in this policy. An explanation of the scope of the grounds available is set out below. The Company notes the grounds that it uses to justify each use of your information next to the use in the “Purposes for which we use your personal data” section of this Privacy Policy.

These are the principal legal grounds that justify our use of your information:

Consent: where you have consented to the Company’s use of your information. More information is set out at Section 5. You may withdraw your consent by contacting us at the email address provided in the Contact Us section of this Privacy Policy or by clicking through unsubscribe wording in the relevant correspondence.

Contract performance: where your information is necessary to enter into or perform the Company’s contract with you.

Legal obligation: where the Company needs to use your information to comply with its legal obligations.

Legitimate interests: where the Company uses your information to achieve a legitimate interest and the Company’s reasons for using it outweigh any prejudice to your data protection rights.

Legal claims: where your information is necessary for the Company to defend, prosecute or make a claim against you, the Company or a third party.

Important Notice

Due to legal restrictions, the contents of the following web pages may not be accessed by persons who are located in the United States, Canada, Japan, Australia or the Republic of South Africa or residents in any EU Member State (other than any EU Member State where Taylor Maritime Investments Limited’s (the “Company’s”) shares are legally marketed) or in any other country where the offer of the securities to the public is not taking place.

The contents of this website is only directed at persons who (i) if they are within the United Kingdom, fall within Articles 49(2)(a) to (d) or 19(5) of the Financial Services and Markets Act 2000 (Financial Promotions) Order 2005 or are persons to whom the shares in the Company may otherwise lawfully be offered under such Order and/or persons who are a “professional client” or an “eligible counter party” within the meaning of Chapter 3 of the FCA’s Conduct of Business Sourcebook, or (ii) if they are receiving the prospectus relating to the Company contained in this website (the “Prospectus”) in circumstances under which the laws or regulations of a jurisdiction other than the United Kingdom would apply, are persons to whom the shares described in the Prospectus may be lawfully offered under that other jurisdiction’s laws and regulations (“Relevant Persons”).

The promotion of shares in the Company is restricted under, together, Directive 2011/61/EU of the European Parliament and of the Council of 8 June 2011 on Alternative Investment Fund Managers as implemented in the UK, Commission delegated regulation (EU) No 231/2013 as amended and transposed into the laws of the UK pursuant to the European Union (Withdrawal) Act 2018 and the European Union (Withdrawal Agreement) Act 2020 and any secondary legislation, rules, regulations and procedures made pursuant thereto (in each case as amended and transposed into the laws of the UK pursuant to the European Union (Withdrawal) Act 2018 and the European Union (Withdrawal Agreement) Act 2020), The Alternative Investment Fund Managers Regulations 2013 (as amended by The Alternative Investment Fund Managers (Amendment etc.) (EU Exit) Regulations 2019) and the Investment Funds Sourcebook forming part of the FCA Handbook (the “UK AIFM Regime”) and, consequently, information contained on the pages that follow is only directed at persons to whom shares in the Company may lawfully be marketed pursuant to the UK AIFM Regime.

If you are not a Relevant Person, you should not access or view this website and take no further action. Any investment or investment activity to which this website relates is only available to Relevant Persons. By accessing or viewing this website, each user is deemed to confirm, represent and warrant to the Company that it is a Relevant Person and accordingly a person to whom this the contents of this website can be lawfully communicated.

The Company has not been, and will not be, registered under the United States Investment Company Act of 1940, as amended, (the “US Investment Company Act”), and investors will not be entitled to the benefits of the US Investment Company Act. The shares of the Company have not been and will not be registered under the United States Securities Act of 1933, as amended (the “US Securities Act”), or with any securities regulatory authority of any state or other jurisdiction of the United States and may not be offered, sold, exercised, resold, transferred or delivered, directly or indirectly, in or into the United States or to or for the account or benefit of any US Person (within the meaning of Regulation S under the US Securities Act) except pursuant to an exemption from, or in a transaction not subject to, the registration requirements of the US Securities Act and in compliance with any applicable securities laws of any state or other jurisdiction in the United States. There has been and will be no public offer of the Shares in the United States.

While the Company has taken reasonable care to ensure that the information on this website (other than information accessed by hyperlink) is accurate at the time of last revision of the website, the Company accepts no liability for the accuracy or completeness or use of, nor any liability to update, the information contained on this website. The contents of this website should not be construed as the giving of advice or the making of a recommendation and should not be relied on as the basis for any decision or action. In particular, actual results and developments may be materially different from any forecast, forward-looking statement, opinion or expectation expressed on this website.

None of the information contained on the following pages nor any copy thereof may be taken or transmitted in or into the United States or distributed, directly or indirectly, in or into the United States. Persons present in the United States of America are not permitted to access this section of the website and should exit it immediately.

By clicking the “ACCEPT” button below you (i) certify that you are not located in the United States or a US Person located outside of the United States, Canada, Japan, Australia or the Republic of South Africa or in any EU Member State (other than any EU Member State where the Company’s shares are legally marketed) or third country where the offer of the securities to the public does not take place and (ii) acknowledge that you have read and understood and agree to the notices and disclaimers set forth above.

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