1. GENERAL

Vianet Group PLC together with any group companies (including Vendman System Ltd) (“we” “us” “our”) are committed to protecting and respecting your privacy. For the purposes of data protection legislation, we are the data controller and we will process your personal data in accordance with the General Data Protection Regulation (EU) 2016/679 and Data Protection Act 2018 which relate to the processing of personal data. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

2. VISITORS TO OUR WEBSITE / USERS OF MOBILE APPLICATIONS

2.1 We may collect and process personal data about you in the following circumstances:

2.1.1 when you complete forms on our website (“Site”). This includes name, address, email address, telephone number, date of birth and employer which is provided at the time of registering to use our Site, where you ask us to contact you about our goods or services, subscribe to our mailing list, or subscribe/request or goods or services;

2.1.2 whenever you provide information to us when reporting a problem with our Site and/or mobile applications, making a complaint, making an enquiry or contacting us for any other reason. If you contact us, we may keep a record of that correspondence;

2.1.3 details of your visits to our Site and/or mobile applications including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise, and the resources that you access (see section 2.2.2 on Cookies below).

2.1.4 whenever you disclose your information to us, or we collect information from you in any other way, through our Site and/or mobile applications.

2.2 We may also collect data in the following ways:

IP Address

2.2.1 We may collect information about your device, including where available your Internet Protocol address, for reasons of fraud protection. We may also collect information about your device’s operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual.

Cookies

2.2.2 Our Site uses cookies to distinguish you from other users of our Site. This helps us to provide you with a good experience when you browse our Site and also allows us to improve our Site. You can find our cookie policy here https://vianetplc.com/cookie-policy/

2.3 We may use your personal data for our legitimate interests in order to:

2.3.1 provide you with information, or services that you requested from us;

2.3.2 allow you to participate in interactive features of our Site and/or mobile applications, when you choose to do so;

2.3.3 ensure that content from our Site and/or mobile applications is presented in the most effective manner for you and for your device;

2.3.4 improve our Site, mobile applications and services;

2.3.5 process and deal with any complaints or enquiries made by you; and

2.3.6 contact you for marketing purposes where you have signed up for these (see section 7 for further details).

2.3.7 Website Links

2.3.8 Our Site may, from time to time, contain links to and from the websites of third parties. Please note that if you follow a link to any of these websites, such websites will apply different terms to the collection and privacy of your personal data and we do not accept any responsibility or liability for these policies. When you leave our Site, we encourage you to read the privacy notice/policy of every website you visit.

3. CUSTOMERS

3.1 We may collect details such as your name, contact details, bank details the equipment you use/our goods/services interact with, details of any work we undertake on your behalf, sales data and transaction history when you order or receive goods or services from us either via our Site, on the telephone or in person, trading names, shareholdings, trading history, details of how you process payments, the channel through which you generate sales, passport details, citizenship. We will use this information to process your order/provide you with services, confirm your identity, perform checks, monitor transactions to prevent or detect crime or comply with laws relating to anti-money laundering, assess suitability for credit and comply with our contractual obligations.

3.2 In order to perform our contact with you, we may also need to share personal data with third parties such as payment providers, credit agencies, payment processers such as Elavon Financial Services and postal service organisations to assist in the delivery of goods or services you have ordered.

3.3 We may also advertise your feedback on our website and marketing materials (subject to obtaining your prior consent where necessary);

3.4 We will retain your information as long as we require this to provide you with the goods or services ordered from us and for a period of 7 years afterwards.

4. CUSTOMERS’ CUSTOMERS

4.1 If a customer of ours provides services/goods to you, but instructs us to attend your premises so we may provide services to our customer as part of their arrangement with you, we may collect details such as your name, contact details and the equipment you use.

4.2 The information we collect will be used so we can perform our contractual obligations, for our legitimate interests, so we can contact you to arrange a access to your premises/the equipment and so we can address any other issues which may arise as part of the service/goods we supply.

4.3 We will retain your information as long as we require this to provide our customers with the goods or services ordered from us and for a period of 7 years afterwards.

5. SUPPLIERS

We will collect details such as name, contact details, bank details in order to contact you about goods or services ordered with you, to place further orders and to pay you for the goods and/or services supplied. We will keep the personal data for 7 years further to being provided with the goods/services.

6. IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide the data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example to provide you with our goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

7. MARKETING

7.1 In addition to the uses described in sections 2-5 above, we may use your personal data for our legitimate interests in order to provide you with details about our goods, services, business updates and events which we think may be of interest.

7.2 You have the right to opt-out of receiving the information detailed in section 7.1 at any time. To opt-out of receiving such information you can:

7.2.1 tick the relevant box situated in the form on which we collect your information;

7.2.2 clicking the unsubscribe button contained in any such communication received; or 7.2.3 email us at dpo@vianetplc.com providing us with your name and contact details.

8. MONITORING AND RECORDING

8.1 We may monitor and record communications with you (such as telephone communications and emails) for the purpose of quality assurance, training, fraud prevention and compliance. All telephone communication recordings are removed after 6 months.

9. AUTOMATED PROCESSING

We do not undertake automated decision making with your personal data.

10. LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA

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

10.1.1 for performance of a contract we enter into with you;

10.1.2 where necessary for compliance with a legal or regulatory obligation we are subject to; and

10.1.3 for our legitimate interests (as described within this policy) where your interests and fundamental rights do not override these interests.

11. DISCLOSURE OF PERSONAL DATA TO THIRD PARTIES

11.1 In addition to the third parties mentioned above, we may disclose your information to third parties for our legitimate interests as follows:

11.1.1 to staff members in order to facilitate the provision of goods or services to you;

11.1.2 to our affiliated entities to support internal administration;

11.1.3 IT software providers that host our website and/or mobile applications and store data on our behalf;

11.1.4 professional advisers including consultants, lawyers, bankers and insurers who provide us with consultancy, banking, legal, insurance and accounting services;

11.1.5 HM Revenue and Customs, regulators and other authorities who require reporting of processing activities in certain circumstances; and

11.1.6 third parties who we may choose to sell, transfer or merge parts of our business or assets. Alternatively, we may seek to acquire other business or merge with them. If a change happens to our business then the new owners may use your personal data in the same way as set out in this privacy policy.

11.2 We may disclose personal data to the police, regulatory bodies, legal advisors or similar third parties where we are under a legal duty to disclose or share personal data in order to comply with any legal obligation, or in order to enforce or apply our website terms and conditions and other agreements; or to protect our rights, property, or safety of our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

11.3 We will not sell or distribute personal data to other organisations without your approval.

12. CROSS-BORDER DATA TRANSFERS

12.1 We will not transfer your personal data outside the European Economic Area.

12.2 DATA SECURITY

12.3 Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Site and/or mobile applications, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

12.4 Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your information transmitted to our Site and/or mobile applications; any transmission is at your own risk.

12.5 Information you provide to us is shared on our secure servers. We have implemented appropriate physical, technical and organisational measures designed to secure your information against accidental loss and unauthorised access, use, alteration or disclosure. In addition, we limit access to personal data

to those employees, agents, contractors and other third parties that have a legitimate business need for such access.

13. ACCESS TO, UPDATING, DELETING AND RESTRICTING USE OF PERSONAL DATA

13.1 It is important that the personal data we hold about you is accurate and current. Please keep us informed if the personal data we hold about you changes.

13.2 Data protection legislation gives you the right to object to the processing of your personal data in certain circumstances or withdraw your consent to the processing of your personal data where this has been provided. You also have the right to access information held about you and for this to be provided in an intelligible form. If you would like a copy of some or all of your personal information, please send an email to dpo@vianetplc.com. In certain circumstances we reserve the right to charge a reasonable fee to comply with your request.

13.3 You can also ask us to undertake the following:

13.3.1 update or amend your personal data if you feel this is inaccurate;

13.3.2 remove your personal data from our database entirely;

13.3.3 send you copies of your personal data in a commonly used format and transfer your information to another entity; or

13.3.4 restrict the use of your personal data.

13.4 We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the personal data that we hold about you or make your requested changes. Data protection legislation may allow or require us to refuse to provide you with access to some or all the personal data that we hold about you or to comply with any requests made in accordance with your rights referred to above. If we cannot provide you with access to your personal data, or process any other request we receive, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

13.5 Please send any requests relating to the above to our Data protection officer/Data Lead at dpo@vianetplc.com specifying your name and the action you would like us to undertake.

14. RIGHT TO WITHDRAW CONSENT

14.1 Where you have provided your consent to the collection, processing and transfer of your personal data, you have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, please contact us at dpo@vianetplc.com.

15. CHANGES TO OUR PRIVACY POLICY

15.1 We reserve the right to update this privacy policy at any time, and any changes we make to our privacy policy will be posted on this page. Please check periodically for any updates. If we would like to use your previously collected personal data for different purposes than those we notified you about at the time of collection, we will provide you with notice and, where required by law, seek your consent, before using your personal data for a new or unrelated purpose. We may process your personal data without your knowledge or consent where required by applicable law or regulation.

16. CONTACT US

We have appointed a Data Lead to oversee compliance with this privacy policy. If you have any questions, comments or requests regarding this policy or how we use your personal data please contact our Data Lead at dpo@vianetplc.com. This is in addition to your right to contact the Information Commissioners Office if you are unsatisfied with our response to any issues you raise at https://ico.org.uk/global/contact-us/

Last updated: June 2021.