What is the purpose of this Privacy Notice?

Welcome to IXICO’s Shareholder Privacy Notice.  You are being provided with a copy of this privacy notice because we and our representatives are processing personal information about you and we consider the protection of your personal data and privacy a very important matter. This notice therefore makes you aware of how and for what purposes your personal data will be used and for how long it will usually be retained. It provides you with certain information that must be provided under the General Data Protection Regulation ((EU) 2016/679) (GDPR).  Before you provide us with any Personal Data, you should read through this Privacy Notice in full and make sure that you are comfortable with our privacy practices.

Who does this Notice apply to?

This privacy notice applies to you if you are an individual and are a current or former registered shareholder of IXICO plc and describes what personal information we collect, how that information is used and what your rights are in relation to that information.  For the purposes of applicable data protection and privacy laws, IXICO Plc with its registered offices at 4^th Floor, Griffin Court, 15 Long Lane, London EC1A 9PN, is considered the “Data Controller” in respect of the Personal Data that it collects, uses and manages in accordance with this Privacy Notice. This information may also be used by our affiliated entities and group companies, namely IXICO plc, IXICO Technologies Limited and IXICO Technologies Inc (our group companies) and so, in this notice, references to we, IXICO or us mean IXICO Plc and our group companies. IXICO plc is listed on the Alternative Investment Market (AIM) and operates in accordance with the AIM Rules. We have engaged Equiniti Limited as our registrar. Equiniti Limited and other Equiniti Group entities (“Equiniti”) maintain the IXICO shareholder register and process shareholders’ personal information on our behalf.

Data protection principles

We will comply with data protection law and principles, which means that your data will be:

• Used lawfully, fairly and in a transparent way.
• Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
• Relevant to the purposes we have told you about and limited only to those purposes.
• Accurate and kept up to date.
• Kept only as long as necessary for the purposes we have told you about.
• Kept securely.

The kind of information we hold about you

We collect various types of personal data about you, including:

• your general and identification information (e.g. name, email and/or postal address, contact phone numbers);
• date of death;
• details of your past or present holdings of shares and/or interests in shares in IXICO plc;
• details of how you have in the past exercised, or intend in the future to exercise, your voting
  rights attached to shares in IXICO plc.

How is your personal information collected?

We collect personal information in a variety of ways, including

• you providing it to us, to Equiniti or to other third parties engaged to carry out services on our behalf for example when you provide information in writing or provide your details via Equiniti’s website;
• if you are also an employee of an IXICO group company;
• by providing it to us or to Equiniti by third parties acting on your behalf such as brokers and other agents through whom you may have acquired or disposed of your shares or interest in shares;
• where you exercise your rights in respect of your shares, including by your attendance at general meetings and voting in person or by your casting proxy votes, whether in hard copy form or by submitting electronic instructions via the CREST system;
• from third parties who perform services on our behalf, such as our registrars who assist us with maintenance of our share registers and with the conduct of our general meetings;
• by capturing your voice on audio recording equipment, for example on any recordings made of our general meetings if you attend such meetings, and on any recordings made of other
  presentations to shareholders if you attend such presentations.

The legal basis for IXICO processing your Personal Data

In order to comply with applicable data privacy laws, IXICO is required to set out the legal basis for the processing of your Personal Data. In accordance with the purposes for which we collect and use your Personal Data as set out above, the legal basis for IXICO processing your Personal Data will typically be one of the following:

• the performance of a contract that we have in place with you or other individuals or organisations;
• IXICO or our third parties’ legitimate business interests to process the information so that we can communicate effectively with shareholders; or
• compliance with our legal obligations.

It is important that you notify us or Equiniti of any changes to your personal details (such as a change of address) so that your record on the shareholder register can be kept up to date.

The purposes for which we process your Personal Data

We process your Personal Data for the following purposes:

• Where we need to comply with a legal obligation (such as maintaining and administering the
  Company’s register of members);
• Make shareholder communications and shareholder meeting materials available to you such as the Annual Report and the Notice of Annual General Meeting;
• Where we need to comply with a contractual obligation.

Your personal information will be shared where there is a legal requirement to do so, for example with regulatory agencies. Your personal information will also be shared with Equiniti and may be shared with other trusted third parties engaged by us, such as our professional advisors or parties engaged to perform processing activities on our behalf. If personal information is processed outside the European Economic Area (EEA), this will be done under agreements based on the standard contractual clauses approved by the European Commission to ensure that the information is protected in the same way that it would be if it were processed within the EEA.

Records retention

Your Personal Data is not kept for longer than is necessary for the purposes for which it is collected. This means that data and records (including Personal Data) are destroyed or erased from our systems when no longer required. The amount of time that records are kept for varies depending upon the type of Personal Data they contain.

Your rights

Subject to certain exceptions, you have the right to request to access your personal information that we hold, to request that your information is rectified or deleted, to request that processing of your information is restricted or to object to our processing of your personal information. In some circumstances we will not delete or stop processing your personal information when requested to do so, for example due to legal or regulatory requirements.

Data Protection Officer

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this Privacy Notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

Contact details

Postal Address:

IXICO Technologies Limited
FAO: Data Protection Officer
4^th Floor Griffin Court
15 Long Lane
London EC1A 9PN
United Kingdom

Or by email to: 
DPO@ixico.com

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).

EU Representative

Individuals and data protection supervisory authorities in the EU may contact our data protection representative according to Article 27 GDPR:

DP-Dock GmbH, Attn: IXICO

Ballindamm 39, 20095 Hamburg, Germany

www.dp-dock.com

ixico@gdpr-rep.com

Changes to the privacy policy

We reserve the right to modify or amend this Policy at any time by posting the revised Policy on our website.