Betero Privacy Policy

Last updated: 10 April 2022

Introduction
PI Betero may collect about you
Betero may collect PI in relation to you
Purpose and legal basis for processing your personal information (PI)
To whom Betero disclose your PI
Marketing and exercising your right to opt-out of marketing
Third-party marketing/sale of PI
PI retention
PI security
Your rights
Contacting Betero
Linked websites
Change to this Privacy Policy

Betero request you take time to carefully read through this information. The information contained within this Privacy Policy is applicable to any person or entity who accesses, uses, relies on, interacts or engages with our Site, Products and Services.

1. Introduction

If there are any terms in this Privacy Policy that you do not agree with, please discontinue use of our Site, Products and Services immediately. This Privacy Policy applies to all information collected through our Site, Products and Services, as well as any related services, sales, marketing, products and events. Please also read our Website Terms of Use ("Terms") which govern all Betero web pages ("Site").

Betero are committed to safeguarding your Personal Information ("PI"), your right to privacy and where applicable processing PI in line with applicable privacy and data protection laws as applicable in each jurisdiction we operate in.

Betero may use third-party providers to collect and process information, including financial information (for example relating to debit and credit card details to process payments via a third-party) to provide the Site, Products and Services to you. If you have any questions or concerns about this Privacy Policy, or our practices with regards to your personal information, please contact Betero.

When you visit the Betero website and, more generally, use any of the Betero website (the Site and/or our Products and Services (the "Services"), Betero may request certain information from you. References to "you" or "your" refers to individuals whose PI is processed by Betero, including by clients with direct or indirect relationships (such as employees, contingent workers, consultants, oﬃcers, agents (together "Representatives" of Betero).

This Privacy Policy sets out the purposes for which Betero may collect, use and disclose (collectively "processing") PI and how it is treated and protected. Furthermore, it sets out an individuals' rights in relation to the processing of their PI.

2. PI Betero or our Service Providers may collect about you

For information purposes only and not advice, please always seek independent advice. PI is information relating to an individual, which can be used either alone or with other sources of information to identify that individual. PI does not include information where the identity of the individual or the specific detail of the information has been removed and is therefore anonymous. Sensitive personal information (SPI) is a sub-category of PI that includes PI relating to race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about health and genetic and biometric data, none of which Betero collects.

The nature of the information that Betero or our Service Providers may collect will depend on the Products and Services Betero provide and Betero 's relationship with you. PI that may be processed by Betero is categorised as follows (the PI listed for each category is non-exhaustive examples):

Identification data - Full name, title, date of birth
Contact data - Personal address, telephone number, email address
Electronic Monitoring data - To the extent permitted by law, Betero my record and monitor your electronic communications with Betero
Financial data - Bank account number and details; credit card number and details
Marketing and Communications data - Marketing and communication preferences; tracking data relating to whether you have read marketing communications from Betero (please also see our cookies policy)
Professional Information data - Position/job title, work address; telephone number; email address, sector and area
Profile data - Username and password for our online services that you have access to; Services requested; marketing communications responded to; survey responses
Services data - Payment details to and from you; details of services you have provided to Betero and Betero have provided to you
Product data – details about products you have used, purchased, interacted with and the ways you may interact with our Products
Site data – any interaction and data usage or upload onto or with our Site.
Technical data - Your use of and interaction with our Site, Products and Services including your IP address, browser type, browser type, browser plug in types and versions, operating system, data and technical data inputs and outputs, information you provide onto the platform or download from the platform.
Sensitive Personal Information (SPI) – Betero will never collect Sensitive Personal Information.

3. Betero may collect PI in relation to you in the following ways:

when you provide it to Betero in connection with interaction with the Betero Site, Products or Services, such as a completed account application, system interaction and usage, order, download or purchase
throughout the course of the relationship with you, including where you change your details, provide additional PI, or where the services Betero are providing to you change
from public sources where you have manifestly chosen to make your PI public, including via public profiles on social media, articles, marketing and through any other platforms or mediums
from visits to the Betero Site or through logging into any of Betero Services or password protected areas and usage or purchase of Betero Products.

Betero may also create or derive PI such as creating records of your interactions with Betero, subject to and to the extent allowed by applicable law.

Unless Betero otherwise indicate that the provision of specific PI is optional, any PI requested is necessary for Betero to provide you or your organisation or entity with the Site, Products and Services utilised and/or requested. If you do not provide the PI requested, Betero may not be able to provide access to the Site and usage or the Products and Services and Betero reserves the right not to do so.

4. Purpose and legal basis for processing your PI

The below table sets out the purposes and basis for which Betero and our third-party service providers may process PI.

Processing purpose Category of PI Basis of Processing

To consider opening an account and purchasing Site, Products and Services

Identification data
Contact data
Financial data
Profile data
Services data

Performance of a contract
Legal or regulatory obligation
Legitimate interests: ensuring Betero do not accept or assist or further any fraudulent or any unlawful activities, such as terrorism or money laundering

To deliver the Site, Products and Services you have requested

Identification data
Contact data
Financial data
Profile data
Services data
Technical data
Marketing & Communications data

Performance of a contract
Legal or regulatory obligation
Legitimate interests: ensuring that you are provided with the best client services and visitor services Betero can oﬀer, and securing a prompt payment of any fees, costs and debts in respect of our Services

To manage payments, fees and charges and to collect and recover money owed

Identification data
Contact data
Financial data
Services data

Performance of a contract
Legitimate interests: ensuring Betero can manage payments, fees and charges and to collect and recover money owed

To manage the relationship with you which will include notifying you about changes to Betero terms of business or this Privacy Policy

Identification data
Contact data
Profile data
Marketing and Communications data

Performance of a contract
Legal or regulatory obligation
Legitimate interests: ensuring Betero can notify you about changes to Betero terms of business or this Privacy Policy

(Where applicable) To interact with governmental or regulatory bodies or other competent national authorities

Identification data
Contact data
Financial data
Services data

Legal or regulatory obligation
Public interest

To detect or prevent fraud and/or other criminal activity and to protect the company and company assets

Identification data
Contact data
Electronic Monitoring data
Financial data
Profile data
Services data
Technical data

Legal or regulatory obligation
Public interest
Legitimate interests: protecting Betero detecting, and protecting against breaches of Betero's policies and applicable laws
Review and update to ensure the systems and Services are adequate

To manage and protect Betero business, including improving data security, troubleshooting data and systems, system maintenance and testing, data hosting, managing our oﬃces and other facilities

Identification data
Contact data
Profile data
Technical data
Marketing & Communications data

Legal or regulatory obligation
Legitimate interests: ensuring the eﬃcient and secure running of Betero business, including through oﬃce and facilities administration, maintaining information technology services, network and data security and fraud prevention

To invite you to take part in market insight or other events or similar events, and to manage your participation in them

Identification data
Contact data
Profile data
Technical data
Marketing & Communications data

Legitimate interests: ensuring Betero client records are up-to-date; promoting Betero 's client services; receiving feedback; improving Betero 's services; identifying ways to expand Betero business

To send you marketing (including by paper and electronic channels) communications and service updates.

Identification data
Contact data
Profile data
Technical data
Marketing & Communications data

Legitimate interests: reviewing how clients use, and what they think of, Betero services; identifying ways to improve and expand Betero business

In relation to vendor services (as applicable):

Purpose and/or activity Type of data Legal basis for processing

To engage you or the organisation or entity you work for as a new supplier, including performing background checks

Identification data
Profile data
Contact data
Financial data
Services data

Performance of a contract
Legal or regulatory obligation
Legitimate interests: ensuring Betero do not deal with proceeds of criminal activities or assist in any other unlawful or fraudulent activities for example money laundering or terrorism
Public interest

5. To whom Betero disclose your PI

In connection with one or more of the purposes outlined in the section 'Purpose and Legal basis for processing your PI' above, Betero may disclose PI to:

professional advisors, third parties, agents or independent contractors that provide services to Betero (including, but not limited to: legal representatives, professional consultants, consultants, contractors, parts suppliers, services suppliers, third party agencies and individuals), which includes their professional advisors, third parties, agents, independent contractors that provide services to them (such as IT systems providers, payment services providers, platform providers, financial advisors, payment processors, brokers, consultants (including legal representatives and accountants);
goods and services providers (such as providers of marketing services where Betero are permitted to disclose your personal information to them); payment processors, intermediaries, brokers, and other individuals and entities that partner with Betero;
competent authorities (including any national and/or international regulatory or enforcement body, agency, court or other form of tribunal or tax authority) or their agents where Betero is required or allowed to do so under applicable law or regulation;
(where applicable) a potential buyer, transferee, merger partner or seller and their advisers in connection with an actual or potential transfer or merger of part or all of Betero's business or assets, or any associated rights or interests, or to acquire a business or enter into a merger with it;
(where applicable) credit reference agencies (including professional and retail agencies) or other organisations that may help Betero to provide data, Products and Services and also to conduct anti-money laundering and anti-terrorist financing checks and to detect fraud and other potential criminal activity; or
any person to whom disclosure is allowed or required by local or foreign law, regulation or any other applicable instrument or agency.

6. Marketing and exercising your right to opt-out of marketing

Betero will not process your PI for marketing purposes if you have informed Betero that you do not wish to receive marketing materials. You can request that Betero stop processing your PI for marketing purposes at any time by clicking on marketing opt-out links in any electronic marketing materials Betero send you (unsubscribe) and/or by using the contact details set out in the "Contacting Betero" section of this Privacy Policy.

7. Third-party marketing/sale of PI

Betero do not share or sell your PI to third parties for the third-party to use for their own marketing or other purposes.

8. PI retention

Betero will process your PI for as long as is necessary to fulfil the purpose for which it was collected including to fulfil Site, Products and Services, until you opt-out or until Betero has met its obligations, for example to comply with legal, regulatory, accounting, auditing, reporting, internal policy requirements or for the establishment or defence of legal claims.

9. PI security

Betero may use a range of physical, electronic, and managerial measures to ensure a level of security appropriate to the risk of PI processing. These measures may include any or all the following:

education and training of relevant staﬀ to ensure they are aware of Betero privacy obligations when processing PI as well as training around social engineering, phishing, spear phishing, and password risks;
the ability to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services;
the ability to restore the availability and access to PI in a timely manner in the event of a physical or technical incident;
administrative and technical controls to restrict access to and process PI;
technological security measures, including firewalls, encryption, and anti-virus software;
segregation of networks and backup facilities;
application security;
endpoint security;
real-time monitoring of data leakage controls;
layered and comprehensive cybersecurity defences; and
security incident reporting and management.

The security of data transmitted over the internet (including by e-mail) cannot be guaranteed and carries a risk of access and interception by third parties. Betero endeavour to protect personal information but cannot guarantee the security of data transmitted to Betero or by Betero.

10. Your rights

In certain circumstances you may have the following rights in relation to the processing of your PI:

Access: To request a copy of the PI Betero process in relation to you and to be informed about how Betero use and (where applicable) share your PI – subject to any legal and regulatory obligations.
Object: To object to the processing of your PI if (i) Betero are processing your PI on the grounds of legitimate interests or for the performance of a task in the public interest (including profiling); or (ii) if Betero are processing your PI for direct marketing purposes.
Correction: To request that Betero update the PI it processes in relation to you, or to correct PI that you think is incorrect or incomplete.
Erasure: To ask that Betero delete PI that Betero process in relation to you where Betero do not have a legal or regulatory obligation or other valid reason to continue to process or retain it.
Restriction: To request that Betero restrict the way in which Betero processes your PI, for example, if you dispute the accuracy of your PI or have raised an objection which is under consideration.
Portability: To request a copy of your PI that you have provided to Betero in a commonly used electronic format such as through the completion of an application form.
Automated decision making: To request manual intervention if you are subject to automated decisions where the decision results in a legal or similar eﬀect to you.

You may exercise your rights at any time by using the details set out in the Contacting Betero section. To the extent permitted by applicable law or regulation Betero reserve the right to charge an appropriate fee in connection with you exercising your rights.

Betero may need to request specific information from you to help Betero confirm your identity and ensure your right to access to the PI requested, or to exercise any of your other rights. This is to ensure that PI is not disclosed to any person who does not have authority to receive it. Betero may also request further information in relation to your request to help Betero to locate the PI processed in relation to you, including, for example, the nature of your relationship with Betero.

Betero aim to respond to all legitimate requests within one calendar month. If Betero think it may take longer than one calendar month, (such as where your request is particularly complex or you have made a number of requests), Betero will notify you and keep you updated. You will not be disadvantaged in any way by exercising your rights in relation to the processing of your PI.

11. Contacting Betero

If you wish to exercise any of your rights or have any questions concerning this policy, please contact us. You also have a right to complain to a data protection or other competent authority with jurisdiction over privacy and data protection law in the country you live or work, or in the country where you believe an issue in relation to the processing of your PI has arisen. Please contact us for further details.

12. Linked websites

This Privacy Policy is not applicable to third-party websites that Betero do not own or control (including those that are linked, hyperlinked or otherwise to products, policies, terms, warranties, or any other information whatsoever), or to any third-party website where Betero advertisements and marketing are displayed.

13. Changes to this Privacy Policy

Betero may modify or amend this Privacy Policy from time to time and you are advised to visit our website and Privacy Policy regularly to check for any amendments and updates. Any material changes will be communicated to you through an appropriate channel, depending on how Betero normally communicates with you. It is your responsibility to ensure that you remain informed of our policies when interacting with any Betero Site, Products or Services.