Privacy policy

This privacy policy is issued on behalf of Sirius Minerals Foundation Limited (“Sirius Minerals Foundation”).

Protecting your privacy is very important to Sirius Minerals Foundation. Sirius Minerals Foundation respects your privacy and is committed to protecting your personal data. This policy (together with our Terms and Conditions and Cookies Policy) will inform you as to the types of personal data we may collect about you when you interact with us. It also explains how we’ll store and handle that data, and keep it safe.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other information we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy is complementary to that information and will not override it.

Controller

This privacy policy is issued on behalf of Sirius Minerals Foundation Limited so when we mention "Sirius Minerals Foundation", "we", "us" or "our" in this privacy policy, we are referring to Sirius Minerals Foundation Limited. Sirius Minerals Foundation Limited is the controller for your personal data under the applicable legislation and it is primarily responsible for processing and ensuring proper protection of your data.

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Information we may collect from you

We may collect, receive, store and process the following data about you:

• Information that you provide by filling in forms on our website. This includes requesting further services including, for example, name, home and/or business address, email address, telephone number, demographic information such as age and/or other information that may identify you as an individual and such other information as may be necessary for the purposes identified in this privacy policy. We may also ask you for information when you report a problem with our website.
• If you contact us, we may keep a record of that correspondence and your details.
• Details of your visits to our website including, but not limited to, traffic data, location data, weblogs and other communication data, and the resources that you access.
• Any other data you may provide to us in connection with our services and/or our website, including but not limited to:
  • information you provide when you apply for funding from the Sirius Minerals Foundation;
  • information you provide when you register your interest in receiving funding from the Sirius Minerals Foundation;
  • information you provide when using the Contact Us section of the website;
  • information you provide us by contacting us; and
  • pictures, comments and/or videos or information which you submit to us either via our social media sites or our website.

If you do not agree to us collecting this information about you, we may not be able to provide you with certain services, including those identified in this privacy policy, and you should not use our website as some of this information is collected automatically.

Uses made of your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• To send you notices (for example, in the form of e-mails, mailings, and the like), and otherwise correspond with you, about our products and services, that We think might interest you, provided we are permitted to do so by law. You always have the right to unsubscribe. You can do so by clicking on the relevant link in the next email we send you, or by contacting us using the details on our website.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

Disclosures of your personal data

We may have to share your personal data with the following types of parties for the purposes set out in paragraph above:

• Service providers acting as processors who provide essential elements of the transaction with which we are both associated, including for website activity IT and system administration services;
• Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services; or
• HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Where we store your personal data

The personal data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by companies operating outside the EEA who work for us or for one of our service providers. We will put in place appropriate protection to make sure your personal data remains adequately protected and is treated in line with this policy.

Data Security

Sirius Minerals Foundation has put in place appropriate security measures to protect your personal information from loss, unauthorised access, destruction, misuse, modification or disclosure. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data Retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances you can ask us to delete your data: see below for further information. That will not necessarily oblige us to delete all of it because, as above, we might need to retain some aspects of it to meet legal, accounting or reporting obligations to which we are subject.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we are allowed to use this information indefinitely without further notice to you.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data:

• Request access to your personal data (commonly known as a "data subject access request" or “DSAR”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it;
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us;
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where you believe we have no legitimate reason for continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be obliged to comply fully with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request;
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. In some cases, we might demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms;
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it;
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. Again, it is subject to any overriding legal, accounting and reporting rights we might have to retain copies of your data; and
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please email dataprotection@siriusminerals.com. As Sirius Minerals Foundation wishes to ensure the personal information it holds about you is complete, accurate and up to date, please keep us informed if your personal data changes.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Third-Party Links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

Revisions to this policy

We may at any time revise this policy without notice. Please check this policy regularly as continued use of the Sirius Minerals Foundation website after a change has been made is your acceptance of the change.

Last updated: 23 May 2018