LeadNorth Limited (“LeadNorth”), is registered in Mauritius under number 178885 registered office Mohabeer Mungur Street, Floreal, Mauritius. LeadNorth is regulated by the Financial Services Commission of Mauritius.

LeadNorth is fully committed to safeguarding your privacy, whether online or otherwise, and the success of our business depends upon our ability to maintain the trust of our clients. Protecting the confidentiality of your personal information is of paramount importance to us here at LeadNorth. Safeguarding your privacy is critical not only for the maintenance of our reputation but also to satisfy the legal and regulatory requirements of the Data Protection Regulation (DPR) imposed on us to safeguard our clients and maintain orderly markets.

The DPR is a set of data privacy regulations introduced to ensure higher quality standards on the handling, processing and storage of personal data to which all organisations must adhere to. The regulation impacts all areas where personal data is concerned such as retention, privacy and processing rules providing new rights to individuals requiring companies such as LeadNorth to provide information with regards to the processing of data in a clear and transparent way. LeadNorth have therefore published this Privacy Policy setting out the principles governing our use of your Personal Data.

1. Introduction
This privacy policy explains how LeadNorth collects, stores, shares, protects and uses personal information of our website visitors, business contacts, suppliers, professional advisors, investors, actual and potential sponsors and management teams involved in a transaction or potential transaction with LeadNorth

2. Non-public Personal Information Collected
a) When you become a client of LeadNorth, we will ask you to provide us with certain Information including personal data. There are two types of information that we collect from our clients, namely:
• Personal information which includes but is not limited to our client’s name, residential address, date of birth, e-mail address, employment details and information relating to your financial circumstances;
• Information relating to the visitors when visiting our website.
b) We may supplement the information that you provide us with information that we receive from our service providers, marketing agents and or other third parties such as your Independent Financial Adviser (IFA) or Intermediary. This information will enable us to provide you with a professional service and help us to keep you informed with research and other information that you may be interested in.

3. How We Acquire Your Information
Most of the information that LeadNorth receive will come directly from you or your Financial Adviser or Intermediary, normally at the point when you register, apply to use any of our services, become a client or, complete a contact form on our website. We may also obtain personal information about you from other sources, such as:
• Fraud prevention agencies;
• Identification verification checks;
• Tracing companies, should we lose contact with you so as to keep you updated with regards your investments;
• Web search – we may search for your contact details over the web.
• Platforms – where our services are distributed through a platform, the platform may forward us a breakdown of the investments, including the name of your IFA;
• Risk and Compliance portals to conduct regulatory checks;
• Third party cookies where we collect information on how visitors use our website;

4. The Types Of Personal Data We Might Collect And Process
We may collect and process the following data:
• Information about you such as name, title, date of birth, gender, nationality, country of birth, country of residence, employment status, email address, post code, contact number. We require this information not only to help us to identify you, but also to allow us to contact you;
• Government Identification documentation such as Passport details, Driving Licence, National Insurance Number, National ID number, Tax Identification Number and utility bills;
• Government Records that may be held by financial crime prevention agencies, the Electoral Register and by Utility Services providers;
• Income/Wealth such as your employment status, income and source of wealth;
• Contractual Information such as details regarding your products and benefits that we may provide;
• Third Party information, where relevant such as your IFA , Intermediary, Executor, or any Power of Attorney etc.;
• Online Information such as – cookies and IP address, if you use our website
• Audio Recordings such as voice recording if you, or your IFA or Intermediary, contact us. These are recorded for regulatory purposes.

Any personal information you provide to us will be dealt with in accordance with this Privacy Policy.

5. How Do We Use The Information That We Collect From You?
We use your personal information for the purpose for which it has been obtained and for related purposes. For example, we collect your personal information so that we can act on your request to:
• Provide our services to you;
• Process your profile opening application;
• Proceed with Where we have an obligation to do so, such as identification verification with fraud prevention agencies to enable us to comply with our anti-money laundering obligations and for the purposes of crime and fraud prevention and to protect our business interests;
• Carry out regulatory checks and meet any legal or regulatory obligations;
• Completing any enquiry or requests you may make;
• Keeping you updated with regular/quarterly reports;
• Maintaining a backup of our investment register for Business Continuity purposes;
• Carry our obligation in law and to the extent necessary for the proper operation of our systems;
• Keep you up to date on other products and services that may be of interest to you.

Before providing you with our services, we are required to obtain certain information about you so as to verify your identity and meet our obligations under The Financial Intelligence and Anti-Money Laundering Act 2002 (FIAMLA) along with any other applicable legislation and for the purposes of crime and/or fraud prevention. Unless otherwise stated, the legal basis for our use of your personal data will be that this information is required for one or more of the legitimate interests as described in this Policy.

6. Who We Share Your Personal Data With?
We monitor communications where the law requires us to do so. We will also monitor where we are required to do so to comply with our regulatory rules and practices and, where we are permitted to do so, to protect our business and the security of our systems.

We may share your personal information with the following third parties:
• Your IFA or Intermediary where you have given your authority. Where transactions have been carried out through your IFA or Intermediary, that person will be deemed to be your agent to whom full details of your information under the Agreement may be disclosed unless you advise us to the contrary in writing;
• Our Service Providers and Agents (including their sub-contractors) and in order to provide and maintain the provision of the services, such as:
- The custodian – (this is currently Pershing Securities Limited
- The Broker(s)
- IT companies who support our technology;
- Offsite storage firms;
- Confidential waste disposal;
- Printing firms
• Appointed Auditors, Accountants, Tax Consultants, Lawyers or other professional advisers to the extent that they require access to the information in order to advise us;
• Mauritius Revenue Authority (MRA)
• Regulators such as the Financial Services Commission (FSC); the Data Protection Office (DPO); and other authorities as required;
• Introducing firms;
• Our external agencies who will only contact you when requested by us to do so for the purpose of improving our service to you;
• Any third party as a result of any restructure, sale or acquisition of any company within the LeadNorth, provided that any recipient uses your information for the same purposes as it was originally supplied to us and/or used by us;
• Anyone to whom we may transfer our rights and/or obligations under the Agreement;
• Any person notified by you as authorised to give instructions for the purposes of managing or administering the service provided under your Agreement with us, to the extent reasonably necessary to enable us to perform the services.
• Any person that you request us to share your information with;
• Businesses that are legally part of the LeadNorth, or that become part of the Group;

Where LeadNorth has a duty to do so to meet applicable law and regulatory requirements, or if law or regulation allows us to do so.

LeadNorth will not lend or sell your information to third parties, but we may provide access to your personal identifiable information when legally required to do so, to cooperate with police investigations or other legal proceedings, to protect against misuse or unauthorised use of our website, to limit our legal liability and protect our rights, or to protect the rights and safety of visitors to our website. In those instances, the information is provided only for that limited purpose.

7. How We Keep Your Personal Data?
LeadNorth is committed to only keeping your personal information for as long as this is considered necessary, for the purposes for which it was collected, or as required by any laws that apply. This will include keeping your information for a reasonable period of time after your investment or relationship with us has ended. In the absence of specific legal, regulatory or contractual requirements, all other personal information is kept for seven (7) years after your investment has ended. In some cases, however, we may be required by law to keep your information for longer.

8. Sending Your Personal Data Internationally
Subject to applicable law, LeadNorth may share your personal information with our service providers and this may involve transferring it to other countries outside of Mauritius whose data protections laws may not be as extensive as those to which this Policy applies. Where we share information with organisations in another jurisdiction, we will ensure that we do this in accordance with Data Protection Laws and Regulations and take appropriate measures to ensure they agree to apply equivalent levels of protection. We will further ensure that we include conditions in the contract to protect all personal information to the required standards of the DPR. LeadNorth may also share your information with other companies that are legally part of the LeadNorth of companies for the purposes of providing our services to you. However, only the appropriate data controllers will have access to relevant investor data.

9. Accuracy of Your Personal Information
We endeavour to ensure that the personal information we hold about you is accurate and up to date. Should the data we hold about you be inaccurate or outdate, we will correct it upon your request.

10. Confidentiality & Security of Your Personal Data
We are committed to implementing and maintaining commercially reasonable and appropriate measures to maintain your personal data in a secure and confidential fashion. We will not share this information with any third party outside LeadNorth unless so required by law. For example, with authorities such as the Financial Services Commission (FSC) or with any other regulatory authority to which we are subject or with any person empowered to require such information by or under any legal enactment.

Where LeadNorth use external data service providers to process personal data on our behalf to enable them to assist in providing, maintaining and operating the services required to fulfil our obligations to you, we will always ensure that we hold appropriate agreements in place to protect your data. Any data transfers between LeadNorth and its external service providers are conducted by secure means.

11. Marketing Communications
If you are an account holder and/or an investor, business contact or newsletter subscriber covered by this Policy we will keep you updated with details of our (and of other companies within the LeadNorth) products and services which we feel may be of interest to you. This would also include news and information about the financial markets and financial services. We will send such information by email using the contact details that you have provided to us. When you register with us or apply to use our services, you may specify your marketing and communication preferences or indicate that you do not wish to receive news or information from us. Should you consent to receiving marketing communications, you may change your preferences or opt out at a later date by contacting us, as set out below under ‘Contact Us’.

Furthermore, we shall ensure that any third-party company that assist us in marketing our products and services, or with whom we have joint marketing agreements, are under contractual obligations to protect the confidentiality of your personal information and use it only to provide the services we have requested them to perform.

12. Your Rights
You may, subject to certain limitations, have data protection rights depending on the data protection laws that apply to our processing of your Personal Data, including the right to:
• Access your Personal Data, and some related information, including the purpose for processing the Personal Data, the categories of recipients of that Personal Data to the extent that it has been transferred internationally, and, where the Personal Data has not been collected directly from you;
• Restrict the use of your Personal Data in certain circumstances
• Have incomplete or inaccurate Personal Data corrected
• Data portability - meaning, in certain specific circumstances, receive your personal information, which you have provided to us, in a structured, commonly used and machine-readable format and the right to transfer that information to another data controller without hindrance, or to have such personal information transferred to another data controller where technically feasible;
• request that the personal information is erased under certain circumstances;
• object to the processing of your personal information;
• be informed about any use of your personal information to make automated decisions about you, and to obtain meaningful information about the logic involved, as well as the significance and the envisaged consequences of the processing;
• prevent any processing of personal data that is causing or is likely to cause unwarranted and substantial damage or distress to you or another individual; and
• make a complaint to the Data Protection Office (DPO) about the way in which your personal data is being used.

Should you wish to exercise any of these rights, please contact the Head of Legal & Compliance via our contact details below. Should you contact us to exercise any of the above rights, we may ask you to provide some additional information in order to verify your identity.

13. Concerns and Queries
We take your concerns very seriously. We encourage you to bring it to our attention if you have any concerns about our processing of your Personal Data. This Privacy Policy was drafted with simplicity and clarity in mind. We are, of course, happy to provide any further information or explanation needed. Our contact details are below.

Head of Legal & Compliance
LeadNorth Limited
Mohabeer Mungur Street,
Floreal, Mauritius
Email: compliance@leadnorth.com