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Privacy Policy

Introduction

This privacy policy (this "Policy") describes the types of information The Addax and Oryx Group plc (the "Company" "we" "our" or "us") will collect from you or that you will provide when you visit our website (the "Website") and our practices for collecting, using, maintaining, protecting, and disclosing that information.

The Company is committed to protecting your privacy. Please read this Policy carefully. If any term in this Policy is unacceptable to you, please do not use the Website.

Information we process about you and how we process it

We collect several types of information from and about users of our Website, which will include information defined as personal data under applicable law ("Personal Data").

Information you give to us

The information we collect on or through our Website includes:

• Information that you provide as a visitor by filling in forms on our Website or by corresponding with us by post, phone, email, or otherwise. This includes information provided when we process and respond to your inquiries and requests. The types of data we collect include your name, email address, telephone number, country, occupation, and information related to your inquiries and requests; and
• Information that you provide as a job applicant by filling in forms on our Website or by corresponding with us by post, phone, email, or otherwise. This includes information provided when you apply for employment with us using the Website. The types of data we collect include the information included on your resume or CV and any other information required to verify your qualifications.

Information we collect about you

As with many other websites, as you navigate through and interact with our Website, we use automatic data collection technologies to collect certain information about your browsing actions and patterns, including:

• Details of your visits to our Website, including resources that you access and use on our Website, traffic data, location data, logs, language, date and time of access, frequency, and other communication data;
• Information about your computer and internet connection, including your operating system, host domain, and browser type; and
• Details of referring websites (URL).

The information we collect automatically is essentially statistical data that helps us improve our Website and deliver a better and more personalized service, including by enabling us to:

• Determine website traffic patterns;
• Count web visits;
• Determine traffic sources so we can measure and improve the performance of our Website;
• Determine which pages and content are the most and least popular;
• Observe site search patterns to provide more intuitive navigation cues; and
• Determine user frequency and time between user visits.

In particular, our Website uses single-session (temporary) and multi-session (persistent) cookies. Temporary cookies last only as long as your web browser is open, and are used for technical purposes such as enabling better navigation on our Website. Once you close your browser, the cookie disappears. Persistent cookies are stored on your computer for longer periods and are used for purposes including tracking the number of unique visitors to our Website and information such as the number of views a page gets, how much time a user spends on a page, and other pertinent web statistics. Cookies, by themselves, will not be used by the Company to disclose your individual identity. This information identifies your browser to our servers when you visit the Website.

The cookies declaration available on the Website under Cookies Declaration (the "Cookies Declaration") gives you additional details on the cookies used on our Website. You can use the Cookies Declaration to refuse all or some cookies. You can at any time change or withdraw your consent from the Cookies Declaration. If you disable or refuse cookies, please note that some parts of the Website will then be inaccessible or not function properly. To delete cookies already stored, please refer to the procedure provided by your operating system (Windows, OS X, etc.).

Why we process your information

Disclosure of your information

Subject to applicable law and regulations, we disclose Personal Data that we collect or that you provide as described in this Policy:

• to entities that we control, that control us, or that are under common control with us (each an "Affiliate");
• to contractors, service providers, and other third parties we use to support our business or in connection with the administration and support of the activities noted above and who are bound by contractual obligations to keep Personal Data confidential and use it only for the purposes for which we disclose it to them (e.g., database hosting providers, developers, or consultants);
• to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by the Company about our Website users is among the assets transferred;

Cross-border transfers of Personal Data

The Personal Data that we collect from you will be stored in Switzerland.

Whenever we transfer Personal Data across borders, we will take legally required steps to ensure that the relevant third country ensures an adequate level of protection or that adequate safeguards are in place to protect your Personal Data.

Data retention

Unless otherwise required by applicable law, the Company will erase Personal Data when it is no longer necessary in relation to the purposes for which it was collected or otherwise processed; when you withdraw your consent (where lawfulness of processing was based on your consent) and there is no other legal ground for the processing; when you object to the processing and there are no overriding legitimate grounds for the processing; when your Personal Data has been unlawfully processed; and when it is necessary to comply with legal obligations.

Your rights with regard to your Personal Data

We remind you that you may at any time exercise the following rights:

• The right to request access to your Personal Data, which includes the right to obtain confirmation from us as to whether or not Personal Data concerning you is being processed, and where that is the case, access to the Personal Data and information related to how it is processed;

• the right to rectification or erasure of your Personal Data, which includes the right to have incomplete Personal Data completed, including by means of providing a supplementary statement, and certain rights to request us to erase your Personal Data without undue delay;
  the right to restrict the processing of your Personal Data, which includes restricting us from continuing to process your Personal Data under certain circumstances (e.g., where you contest the accuracy of your Personal Data, processing is unlawful, your Personal Data is no longer needed for the purposes of processing, or you have otherwise objected to processing related to automated individual decision-making);
  the right to object to processing concerning your Personal Data, where your Personal Data is processed for direct marketing purposes, where processing is necessary for the performance of a task carried out in the public interest, or where processing is necessary for the purposes of the legitimate interests pursued by the Company or a third party, unless we demonstrate compelling legitimate grounds for the processing which override such interests;

• the right to data portability, which includes certain rights to have your Personal Data transmitted from us to another controller;

• where data processing is based on your consent, the right to withdraw consent at any time; and

• the right to lodge a complaint with a supervisory authority.

Any requests related to the above rights may be made by sending an email to privacy@aoginvest.com.

Data security

We have implemented measures designed to secure your Personal Data from accidental loss and from unauthorized access, use, alteration, and disclosure, including:

• identity and access management (IAM);

• access control monitoring through log management;

• real-time threat management; and

• deployment of leading firewall technologies and third-party DDoS protection for malicious activities.

Third-party websites

Our Website may contain links or references to other websites outside of our control. Please be aware that this Policy does not apply to these websites. The Company encourages you to read the privacy statements and terms and conditions of linked or referenced websites you enter. The Company does not control and is not responsible for what third parties do in connection with their websites, or how they handle your Personal Data. 

Children under the age of 16

Our Website is not intended for children under 16 years of age, and the Company does not knowingly collect or use any Personal Data from children under the age of 16. No one under the age of 16 may provide any information to or on the Website. If we learn we have collected or received Personal Data from a child under the age of 16, we will delete that information. If you believe we might have any information from or about a child under the age of 16, please contact privacy@aoginvest.com.

Revisions to our privacy policy

We reserve the right to change this Policy at any time without prior notice. Any changes we make will be posted on this page. If we make material changes to how we treat your Personal Data, we will notify you through a notice on the Website home page.

Data controller & contact information

The data controller for the purposes of this Website is The Addax and Oryx Group plc with a registered office at Level 13, Portomaso Business Tower, Portomaso, St. Julians, STJ 4011, Malta.

Should you have any questions or concerns about this Policy and/or our privacy practices, you may contact privacy@aoginvest.com.

Annex : List of Data Controllers