Below you will find Privacy Policy and Cookie Policy of NW Advisors Limited and NW Advisors, LLC (hereinafter collectively referred to as “NW Advisors”). PLEASE READ THESE POLICIES CAREFULLY.

PRIVACY POLICY

Effective Date: May 25, 2018.

NW Advisors understands that your privacy is important to you and is committed to safeguarding the confidentiality and privacy of personal information entrusted to it.

This Privacy Policy describes how NW Advisors handles and protects your personal information in connection with the hosting of this website, and the provision of its diverse business advisory services in the field of strategic communications ("Services").

Scope of this policy

This policy applies to personal information which is collected and/or used by NW Advisors in its capacity as a controller as that term is defined in the EU data protection laws. The contexts in which this might occur are explored under "When do we collect personal information" below.

When we provide Services to clients, we sometimes handle personal information as a processor. This means that we process the information solely on the instructions of our clients, who retain control of the information. Therefore, if our use of your personal information is not covered by this policy, you may need to contact the client (and controller) on whose behalf the processing of your information is carried out.

Quick read

NW Advisors collects personal information from and on behalf of its clients (e.g. about their employees and customers) to provide business advisory services to those clients. It also processes client personal information to manage its relationship with those clients. Further, NW Advisors also collects some personal information from visitors to this website, recruitment applicants, and attendees at NW Advisors events.

NW Advisors uses personal information to deliver its Services to clients. For its own purposes, it also uses personal information to analyse and improve how it delivers those services, to contact representatives of its clients or prospective clients and to market to them, and to administer recruitment and events.

If NW Advisors uses your personal information, you may have certain important rights which you can exercise. The rights you will be able to exercise will depend on how and why NW Advisors uses your information.

The primary point of contact at NW Advisors for questions regarding your personal information is info@nwadvisors.com.

Who is your controller?

The NW Advisors entity responsible for your personal information will be the entity that originally collected information from or about you. If you have a direct interaction with NW Advisors (for example, you attend an NW Advisors hosted event), the identity of your controller may be disclosed to you in connection with that interaction. If we process your personal information in the course of providing our Services to clients, your controller will be the NW Advisors entity providing the Services (assuming those Services are provided as a controller, see above for an explanation). Please note that the contact details for all NW Advisors entities in respect of data protection or privacy issues are the same, and are as set out below.

Your Acceptance

In respect of personal information collected over this and other NW Advisors websites, your continued use of these websites constitutes your understanding of, and agreement to, the practices described in this Privacy Policy and elsewhere on the websites as well as any subsequent updates.

When do we collect personal information?

We collect information about you if:

• you use this (or any other NW Advisors) website;
• you enquire about, or engage NW Advisors to provide, its Services (either in a personal capacity, or as a representative for your employer or client);
• the use of your personal information is reasonably necessary to provide our Services (in these circumstances, your personal information may be disclosed to us by our client who may, for example, be your employer or service provider, or we may obtain your personal information from a range of public or subscription sources, directly from you, or from your associates or persons known to you);
• you apply for a position with NW Advisors;
• you attend an NW Advisors hosted or sponsored event or webinar;
• you contact us with any other enquiry, complaint or notice.

What types of personal information are collected and what do we use it for?

The following is a summary of the types of personal information we collect, and the purposes for which that information is used.

Website Users
NW Advisors may automatically collect personal information (through the use of Cookies or similar technologies, including your IP address, device identifier, browsing patterns on its websites, click stream data, and HTP protocol elements) to ensure the effective operation of the website or in order to align the presentation of our Services more closely to your requirements (for example, processing information about your broad geographic location to serve you with a local version of this website). This tracking information is stored in an anonymous, aggregated and non-personal format, and is also used to understand and analyze trends, to administer the websites, and to learn about user behavior on the websites.

Please refer to our Cookie Policy for a more detailed overview on how NW Advisors uses Cookies.

In certain instances, NW Advisors may use IP addresses to help identify you when NW Advisors feels, in its sole discretion, that it is necessary to enforce compliance with this Privacy Policy, to protect its services, websites, systems, information, employees, business partners, subsidiaries, users, customers or others, or when required by law or for law enforcement purposes.

NW Advisors's Former, Current and Prospective Clients
If you submit an enquiry to NW Advisors about our Services (either over the website, or by emailing, telephoning or meeting with one of our colleagues), then we will process information such as your name, job title and contact information in order to respond to your enquiry.

If you attend an NW Advisors event or webinar, or if you associate with an NW Advisors colleague at, for example, an industry event, then NW Advisors may collect basic personal information, such as contact details, which you voluntarily provide (for example, by filling in a form or handing over a business card) in order to facilitate your participation in the event, and for the management of our relationship with you as an actual or prospective client.

If you or the organisation you are associated with becomes an NW Advisors client, then we may process your personal information in order to:

• carry out client communication, service, billing and administration;
• deal with client complaints;
• administer claims.

Taking account of applicable marketing laws, we also process personal information about our clients (former, current and prospective) in order to:

• send our clients newsletters, know-how, promotional material and other marketing communications;
• invite our clients to events (and arrange and administer those events).

Performing Services for Our Clients
As discussed above, many of our Services involve the processing of personal information. In the majority of cases, personal information is provided to us in strict confidence, subject to restrictive undertakings on its use / disclosure.

Illustrative examples of the use of personal information in connection with our Services, and the legal bases we rely upon for using personal information, are set out in Annex 1 (Use of Personal Information for our Services).

Other Uses
If you apply for a position with NW Advisors, we will need to collect personal information in order to consider your application, and during any interview and assessment phase.

If you contact us for any other reason, we will collect basic contact details, as well as any other personal information relevant to the reason for your enquiry, in order to resolve that enquiry.

What is our legal basis for collecting personal information?
All processing (i.e. use) of your personal information is justified by a "lawful basis" for processing. In the majority of cases, processing will be justified on the basis that:

• the processing is necessary for the performance of a contract to which you are a party, or to take steps (at your request) to enter into a contract (e.g. where you request certain Services as an individual client, or where we help advise your employer or service provider on fulfilling an obligation to you under a contract);
• the processing is necessary for us to comply with a relevant legal obligation (e.g. where we are required to collect certain information about our clients for tax or accounting purposes, or where we are required to make disclosures to courts or regulators);
• the processing is in our legitimate interests, subject to due consideration for your interests and fundamental rights (this is the basis we rely upon for the majority of the processing of personal information in connection with the provision of our Services, and also for the purposes of most client on-boarding, administration and relationship management activities).

In limited circumstances, we will use your consent as the basis for processing your personal information, for example, where we are required by applicable law to obtain your prior consent in order to send you marketing communications.

Before collecting and/or using any special categories of data (as that term is defined in the GDPR), or criminal record data, we will establish a lawful exemption which will allow us to use that information. This exemption will typically be:

• your explicit consent;
• the establishment, exercise or defence by us or third parties of legal claims;
• other uses allowed by applicable law including context specific exemptions provided for under local laws of EU Member States and other countries implementing the GDPR, such as in relation to the processing of special category data for the purposes of preventing or detecting fraud in relation to instructions from potential clients.

Disclosure of Personal Information to Third Parties
NW Advisors will not disclose your personal information to third parties other than as described in this Privacy Policy unless NW Advisors has your permission or is required or permitted by law. Third party contractors, consultants and/or vendors engaged by NW Advisors to provide services may have access to your personal information. These third parties will be subject to their own data protection requirements providing the same or greater level of security provided by NW Advisors and in most instances will also have entered into a written agreement with NW Advisors which addresses the protection of your personal information.

NW Advisors may also disclose your personal information for the purposes of:

• responding to requests from law enforcement agencies, regulators or courts, or to subpoenas, search warrants, or other legal requests;
• the prevention and/or detection of crime;
• establishing legal rights or to investigate or pursue legal claims;
• a merger, acquisition or corporate restructuring to which NW Advisors is subject;
• preventing risk of harm to an individual.

Information Security
NW Advisors has reasonable technical safeguards, security policies and procedures in place to protect personal information from unauthorized loss, misuse, alteration, or destruction. Measures we take include placing confidentiality requirements on our staff members and service providers, limiting access to your personal information on a "need to know" basis, and providing training to appropriate NW Advisors personnel.

Despite NW Advisors's best efforts, however, security cannot be absolutely guaranteed against all threats.

Retention of your personal information
NW Advisors retains your personal information for the period of time required for the purposes for which it was collected, any compatible purposes which we subsequently establish, or any new purposes to which you subsequently consent, or to comply with legal, regulatory and NW Advisors policy requirements. This period of time will usually be the period of your, or the relevant client's, relationship or contract with NW Advisors plus a period reflecting the length of time for which legal claims may be made following the termination of such relationship or contract. Some information (such as call recordings, tax records and certain information required to demonstrate regulatory compliance) may need to be kept for longer. Personal information will be kept for a shorter or longer period of time if so required by law or an NW Advisors policy, if the information becomes subject to a legal hold (for example, following a communication from our regulator) or if we have identified through a data protection impact assessment that a different retention period is appropriate.

Your EEA (European Economic Area) Rights
If your personal information is processed by NW Advisors in the EEA then, subject to certain exemptions, and dependent on how and why we use it, you have certain rights in relation to your personal information. We may ask you for additional information to confirm your identity before disclosing any personal information to you. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.

You can exercise your rights by contacting us. Subject to legal and other permissible considerations, we will make every reasonable effort to honour your request promptly or inform you if we require further information in order to fulfil your request.

We may not always be able to fully address your request, for example if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way.

Right to Access
You have the right to access personal information which NW Advisors holds about you, together with certain information about how and why your personal information is processed.

Right to Rectification
You have a right to request us to correct your personal information where it is inaccurate or out of date.

Right to be Forgotten (Right to Erasure)
You have the right under certain circumstances to have your personal information erased. Your information can only be erased if it is no longer necessary for the purpose for which it was collected, and we have no other legal ground for processing the information.

Right to Restrict Processing
You have the right to restrict the processing of your personal information, but only where:

• its accuracy is contested, to allow us to verify its accuracy;
• the processing is unlawful, but you do not want it erased;
• it is no longer needed for the purposes for which it was collected, but we still need it to establish, exercise or defend legal claims;
• you have exercised the right to object, and verification of overriding grounds is pending.

Right to Data Portability
You have the right to data portability, which requires us to provide personal information to you or another controller in a commonly used, machine readable format, but only where the processing of that information is based on (i) consent; or (ii) the performance of a contract to which you are a party. Please note that NW Advisors rarely relies upon consent as a legal basis, and the performance of a contract basis will only be relevant to the extent that you, as an individual, are party to a contract with NW Advisors or a client, and our use of your personal information is necessary for the performance of that contract.

Right to Object to Processing
You have the right to object to the processing of your personal information at any time, but only where that processing is based on our legitimate interests. If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.

If you reside in the European Economic Area (EEA) and would like to exercise your right to access, review, correct or discuss how your personal information is processed by NW Advisors please contact us at info@nwadvisors.com.

If you reside outside of the EEA you can also make a request to update or remove information about you by contacting info@nwadvisors.com. NW Advisors will make all reasonable and practical efforts to comply with your request, so long as it is consistent with applicable law and professional standards.

In addition, under applicable local law you may have the legal right to lodge a complaint with the relevant supervisory authority or local data protection authority.

Marketing
NW Advisors may send you information related to its services, products and events that we believe are of interest to you. This information may be sent by post or via email. If at any point you no longer prefer to receive marketing communications from NW Advisors you can (i) unsubscribe from NW Advisors communications sent by email using a link provided in marketing emails sent from NW Advisors; or (ii) contact us to exercise your right to prevent all forms of marketing (both post and email).

Children
NW Advisors’s websites are not intentionally designed for or directed at children under the age of 13. It is NW Advisors’s policy never to knowingly collect or maintain information about anyone under the age of 13, except as part of an engagement to provide professional services.

Links
NW Advisors websites may contain links to other sites that are governed by other privacy policies that may differ somewhat from this one. Users should review the privacy policy of each website visited before disclosing any personal information. To the extent that NW Advisors provides links to third party websites, such links do not constitute an endorsement, sponsorship, or recommendation by NW Advisors of the third parties, the third party websites, or the information contained on those websites, and NW Advisors is not responsible or liable for your use of such third party websites. Where appropriate you should review the privacy polices of any websites or applications before submitting personal information.

Changes to this Policy
By using NW Advisors websites you consent to the collection, use and storage of personal information as described in this Privacy Policy and elsewhere on the websites. NW Advisors reserves the right to make changes to this Website Privacy Policy from time to time. NW Advisors will notify you by posting amendments to the Privacy Policy on this website.

Contact Us
If you have questions or concerns regarding this policy or NW Advisors’s personal data processing policies, please contact NW Advisors at: info@nwadvisors.com.

ANNEX 1: USE OF PERSONAL INFORMATION FOR OUR SERVICES

Service	Why is personal information used?	What legal bases are relied upon?
Strategic Communications	NW Advisors has a team of experts who are experienced in designing and implementing communication strategies for clients. In order to provide clients with tailored, intelligence led strategies, NW Advisors may be given, and may pro-actively collect through its own research, personal information about key individuals or parties involved in an issue or incident about which our client has requested communications advice.	Legitimate interest in providing public relations consultation to clients, including in relation to the handling of situations relating to or involving particular individuals.*

*In all cases where legitimate interests is relied upon as a lawful basis for processing Personal Data, NW Advisors takes steps to ensure that its legitimate interests are not outweighed by any prejudice to the rights and freedoms of the underlying data subjects. This is achieved in a number of ways, including through the application of principles of data minimisation and security, and by taking steps to ensure that personal information is only collected or otherwise obtained where it is relevant to the provision of Services to a client, and where access to personal information for NW Advisors is reasonably necessary for the provision of those Services.

COOKIE POLICY

Effective Date: May 25, 2018.

This policy applies to NW Advisors Limited and NW Advisors, LLC (collectively “NW Advisors”).

NW Advisors is committed to safeguarding the privacy of your personal information and to being transparent about the technologies it uses. This Cookie Policy explains how and why Cookies and similar technologies are used by NW Advisors to improve and enhance your user experience when using our websites. This Cookie Policy should read in conjunction with the NW Advisors Privacy Policy. By continuing to browse or use NW Advisors websites you agree that NW Advisors can store and access Cookies as described in this Policy.

What are Cookies and other Tracking Technologies?
A cookie is a small text file containing small amounts of information that a website puts on a user’s computer (or mobile device) when you visit a website and is used by the website to send information to your browser and for the browser to return information to the website.

You can find more information about cookies at: www.allaboutcookies.org and www.youronlinechoices.eu. For a video about cookies, please visit www.google.com/policies/technologies/cookies.

How do we use Cookies and other Tracking Technologies?
The information your browser sends to one of NW Advisors’s websites is used for authentication and identification of your session and allows NW Advisors to display the correct information on the website. NW Advisors matches the cookie against your details so it can distinguish you from other users as you browse the site, which helps it to provide you with a good user experience. Most web browsers enable you to erase cookies, block cookies, receive a warning before a cookie is stored on your device or disable cookies. If you wish to withdraw consent to use Cookies at any point you will need to delete cookies using your web browsers settings. If you do so, however, this site may not function correctly.

Logging: NW Advisors records and stores details of the pages visited so that it can generate usage statistics. Except as otherwise provided in this Privacy Policy, NW Advisors does not sell or share any information gathered to other companies.

By continuing to use this website you give your consent for NW Advisors to use cookies as detailed above.

If the way NW Advisors uses cookies changes significantly (e.g. a new cookie being added with different functionality), NW Advisors will inform you from the log in page. This detail will always be available to you from the navigation links at the bottom of all pages.

What if I don’t want cookies to be used?
By using NW Advisors’s website you agree that NW Advisors can place cookies on your device as explained above. If you want to remove existing cookies from your device you can do this using your browser options. If you want to block future cookies from being placed on your device you can change your browser settings to do this. Please note that if you use your browser settings to block the use of all Cookies it may impact certain functionality on the NW Advisors websites or degrade your browsing experience.

Contact Us
If you have questions or concerns regarding this policy or NW Advisors’s personal data processing policies, please contact NW Advisors at: info@nwadvisors.com.