BECKWAY PRIVACY PRACTICES

Below you will find Beckway Group, LLC’s Privacy Policy, Cookie Policy, and Policy on EU-US Data Privacy Framework (DPF), and UK Extension to the EU-US DPF (“Privacy Practices”). These policies apply to Beckway Group, LLC and its affiliated companies and subsidiaries (collectively “Beckway”). PLEASE READ THESE POLICIES CAREFULLY. Our Asia Pacific Privacy Supplement contains additional information regarding certain laws in Asia and Australia.

Beckway Privacy Policy

Effective Date: March 1, 2024

Beckway 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 Beckway handles and protects your personal information in connection with the hosting of this website, and the provision of its diverse business advisory services (“Services”), as explained in more detail here: https://beckway.com/services/professional-services/

Notice at Collection

Beckway collects the personal information described below for the purposes and for the period described below. We do not sell your personal information or disclose it for cross-context behavioral advertising (“sharing”). We also do not collect or process sensitive personal information for the purpose of inferring characteristics about you. To the extent you provide Beckway with personal information about others, you are responsible for providing this notice to them.

These Privacy Practices covers the following topics:

• Scope of this policy
• Quick read
• Who is your controller?
• When do we collect personal information?
• What types of personal information are collected and what do we use them for?
• What is our legal basis for collecting personal information?
• Disclosure of personal information to third parties
• International hosting and transfer of information
• Information security
• Retention of your personal information
• Your rights in jurisdictions covered by the GDPR and similar laws
• Important additional information for California residents
• Marketing
• Children
• Links
• Changes to this policy
• Contact us

Scope of this policy

This policy applies to personal information which is collected and/or used by Beckway in its capacity as a controller as that term (or another term with equivalent meaning) is defined in the EU General Data Protection Regulation (GDPR) and other similar laws. California residents should also review the section of this policy addressing their rights. 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 (for example, the hosting of client data on our one of our platforms). 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.

For purposes of these Privacy Practices, “Personal information” means information that is related to an identified or identifiable individual or is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or with a household.

Quick Read

Beckway 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, Beckway also collects some personal information from visitors to this website, recruitment applicants, and attendees at Beckway events.

Beckway uses personal information to deliver its Services to clients. For its own purposes, it also uses personal information to analyze 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 Beckway 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 Beckway uses your information.

The primary point of contact at Beckway for questions regarding your personal information is admin@beckway.com.

Who is your controller?

The Beckway 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 Beckway (for example, you attend a Beckway 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 Beckway 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 Beckway 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 Beckway 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. Please see the additional information under the heading “Legal” for more information about our on-line terms of use and policies in general.

When do we collect personal information?

We collect information about you if:

• you use this (or any other Beckway) website;
• you inquire about, or engage Beckway 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 Beckway;
• you attend a Beckway hosted or sponsored event or webinar;
• you visit a Beckway exhibit booth at a conference or industry event;
• you contact us with any other inquiry, complaint or notice; or
• we acquire a company or employer, or assets of a company or employer that has your information.

What types of personal information are collected and what do we use them 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

Beckway collects your name, address, e-mail address, telephone number and any other personally-identifiable information which you voluntarily provide.

Beckway may also 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 Beckway uses cookies.

In certain instances, Beckway may use IP addresses to help identify you when Beckway 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, affiliates, users, customers or others, or when required by law or for law enforcement purposes.

Beckway’s Former, Current and Prospective Clients

If you submit an inquiry to Beckway 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 inquiry.

If you attend a Beckway event or webinar, or if you associate with a Beckway colleague at, for example, an industry event or conference, then Beckway 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 organization you are associated with becomes a Beckway client, then we may process your personal information in order to:

• carry out checks and screening prior to starting a new engagement (as well as basic contact information, this may mean processing compliance related information such as proof of your identity, information about your professional background, history of directorships and, in some circumstance, details of any criminal convictions or adverse media coverage);
• carry out background checks for the purposes of complying with anti-money laundering and terrorist financing laws;
• carry out client communication, service, billing and administration;
• deal with client complaints; and
• 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.

Other Uses

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

If you inquire about, or decide to purchase stock in Beckway, then we will collect (either from you or from your broker / investment manager) basic personal information required to register you as a stockholder.

If we hire you as a vendor, supplier or contractor, we will need to collect personal information in order to complete transactions and, where applicable, complete appropriate screening activities.

Finally, 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 inquiry, in order to resolve that inquiry.

What is our legal basis for collecting personal information?

Certain laws, including the GDPR, require us to establish a ‘lawful basis’ for our processing of your personal information. 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); or
• the processing is necessary for the performance of a task carried out in the public interest (e.g. background checks for anti-money laundering and terrorist financing purposes); or
• 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 as an equivalent term is defined by other privacy laws), 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 defense by us or third parties of legal claims; or
• 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 and similar privacy laws, 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

Beckway will not disclose your personal information to third parties other than as described in this Privacy Policy unless Beckway has your permission or is required or permitted by law. Beckway may share such information with its affiliates as necessary to carry out the purposes for which the information was supplied or collected. Similarly, third party contractors, consultants and/or vendors engaged by Beckway 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 Beckway and in most instances will also have entered into a written agreement with Beckway which addresses the protection of your personal information.

Beckway 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 Beckway is subject;
• preventing risk of harm to an individual.

International Hosting and Transfer of Information

Beckway is a global organization and may transfer certain personal information collected on its websites across geographical borders to Beckway offices, personnel, or third parties located throughout the world. Beckway may also store such information in a jurisdiction other than where you are based including outside of the European Economic Area (“EEA”).

Beckway will take appropriate steps to ensure that transfers of personal information are in accordance with applicable law and carefully managed to protect your privacy rights and interests and transfers are limited to countries which are recognized as providing an adequate level of legal protection or where we can be satisfied that alternative arrangement are in place to protect your privacy rights.

You have a right to contact us for more information about the safeguards we have put in place (including a copy of relevant contractual commitments) to ensure the adequate protection of your personal information when this is transferred as mentioned above.

Information Security

Beckway 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 Beckway personnel. We also maintain comprehensive policies addressing data incident response protocols. Our IT Security Program is audited on a regular basis.

Despite Beckway’s best efforts, however, security cannot be absolutely guaranteed against all threats.

Retention of your personal information

Beckway 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 Beckway policy requirements. This period of time will usually be the period of your, or the relevant client’s, relationship or contract with Beckway 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 a Beckway 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 Rights in Jurisdictions Covered by the GDPR and Similar Laws

If your personal information is processed by a Beckway entity in the EEA or another jurisdiction that has adopted the GDPR or similar rules, then, subject to certain exemptions, and dependent on how and why we use it, you have certain rights in relation to your personal information. The rights described below may vary depending on the specific laws that apply to you.

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 honor 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 Beckway 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; or
• the processing is unlawful, but you do not want it erased; or
• 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; or
• 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 Beckway 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 Beckway 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 have any specific concerns about this privacy policy or your data (including, without limitation, if you would like to exercise your right to access, review, erase, correct or discuss how your personal information is processed), please contact us via admin@beckway.com or Data Protection Officer, c/o Legal Department, Beckway Group, LLC, 450 Lexington Avenue, 4 ^th Floor, New York, NY 10017.

Beckway 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.

Important Additional Information for California Residents

This section provides information for California residents, as required under California privacy laws, including the California Consumer Privacy Act and its implementing regulations (“CCPA”). The CCPA generally requires that businesses provide California consumers information about how we use their personal information, whether collected online or offline, and this document is intended to satisfy that requirement. However, the CCPA notice requirement does not apply where we are providing services to our clients, receive personal data and use it solely to provide service to a client and function as a “service provider” within the meaning of the CCPA.

Job applicants should review the Notice at Collection and Privacy Policy for California Job Applicants .

Under the CCPA, “personal information” is any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household.

Categories of Personal Information that We Collect, Disclose, and Sell or Share

Below please find the categories of personal information about California residents that we may collect and may disclose to third parties or service providers for a business purpose. We describe the purposes of using the personal information in the “What types of personal information are collected and what do we use it for?” section, above.

Disclosures for Business Purposes

Beckway does not disclose personal information for commercial purposes. Beckway has disclosed each of the categories of personal information that it collects for the following “business purposes”, as that term is defined under the CCPA, in the last 12 months:

• SERVICE PROVIDERS: For the business purpose of performing services on Beckway’s behalf and, in particular, for the specific purposes described in “What types of personal information are collected and what do we use it for?” section, above, and, in more detail in Annex I, below.
• AUDITORS, LAWYERS, CONSULTANTS, and ACCOUNTANTS engaged by Beckway: For the business purpose of auditing compliance with policies and applicable laws, in addition to performing services on Beckway’s behalf.
• AFFILIATED COMPANIES: To other companies within the BECKWAY family of companies for the business purposes of (1) auditing compliance with policies and applicable laws, (2) helping to ensure security and integrity, (3) debugging, (4) short-term transient use, (5) performing services on behalf of Beckway, (6) internal research, and (7) activities to maintain or improve the quality or safety of a service or device.

No Sales or Sharing

We do not sell or share your personal information¸ where “share” means disclosing personal information to third parties for cross-context behavioral advertising. Without limiting the foregoing, we have not, and have no actual knowledge that we have, sold or “shared” the personal information of individuals of any age, including the personal information of children under 16, in the last 12 months.

Note on Sensitive Personal Information: Beckway does not infer characteristics from sensitive personal information. Beckway only uses sensitive personal information as necessary to perform its services, to ensure security and integrity, or for other purposes permitted by the CCPA without the right to opt out.

The Categories of Sources from Which We Collect Personal Information

• You, as described in the section above titled “When do we collect personal information”.
• Service providers, for example, analytics providers, IT, and system administration services.
• Affiliated companies, for example, so that we can assist other companies in the Beckway family of companies in providing you with products or services.
• Automated technologies, for example, browsing activity collected by automated technologies on the website.
• Third parties, for example, lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance, and accounting services.
• Public sources, for example, public databases.
• Marketing/advertising companies, for example, from social media platforms, consumer research companies, and analytics or marketing/advertising companies.
• Surveillance/recording technologies installed by Beckway, for example, video surveillance in common areas of Beckway facilities, voicemail technologies, and audio recording technologies with consent to the extent required by law.
• Government or administrative agencies, for example, law enforcement, public health officials, and other government authorities.
• Acquired entity, if Beckway acquired another entity, we might collect personal information from that entity.

Aggregated and Deidentified Information

We may aggregate and/or deidentify information, use it internally, and disclose to third parties. Neither Aggregated Information nor Deidentified Information (defined below) is personal information.

• “Aggregated Information” refers to information about a group of individuals from which the individually identifiable information has been removed. An example of Aggregated Information would be the statistic that 20 people used our website’s contact form on a given day.
• “Deidentified Information” means information subjected to reasonable measures to ensure that the deidentified information cannot be associated with the individual. An example of Deidentified Information would be the data point that an unidentified visitor first entered the website through our main web page. We maintain Deidentified Information in a deidentified form and do not attempt to reidentify it, except that we may attempt to reidentify the information just to determine whether our deidentification processes function correctly.

California Residents’ Rights

California law grants California residents certain rights and imposes restrictions on particular business practices as set forth below.

Notice at Collection. We are required to notify California residents, at or before the point of collection of their personal information, the categories of personal information collected and the purposes for which such information is used.

Right of Deletion: California residents have the right to submit a verifiable request for the deletion of their personal information that we have collected about them, subject to certain exemptions, and to have such personal information deleted, except where necessary for any of a list of exempt purposes.

Right to Correct: California residents have the right to submit a verifiable request for the correction of inaccurate personal information maintained by Beckway, taking into account the nature of the personal information and the purposes of processing the personal information.

Right to Know – Right to Specific Pieces: Up to twice in a 12-month period, California residents have the right to submit a verifiable request for specific pieces of personal information and to have this delivered, free of charge, either (a) by mail or (b) electronically in a portable and, to the extent technically feasible, readily useable format that allows the individual to transmit this information to another entity without hindrance. Please note that the CCPA’s right to obtain “specific pieces” does not grant a right to the whole of any document that contains personal information, but only to discrete items of personal information.

Right to Know – Right to Information: California residents have the right to submit a verifiable request that we provide them certain information about how we have handled their personal information, including the:

• categories of personal information collected;
• categories of sources of personal information;
• business and/or commercial purposes for collecting and selling their personal information; and
• categories of personal information that we disclosed for a business purpose, and for each category identified, the categories of third parties to whom we disclosed that particular category of personal information.

Submitting Requests. Requests to exercise these California rights may be submitted to admin@beckway.com. We will respond to verifiable requests received from California consumers as required by law.

How We Will Verify Your Request. To verify your request, we match personal information that you provide us against personal information we maintain in our files. The more risk entailed by the request (e.g., a request for specific pieces of personal information), the more items of personal information we may request to verify your identity. If we cannot verify your identity to a sufficient level of certainty to respond securely to your request, we will let you know promptly and explain why we cannot verify your identity.

Right to Non-Discrimination, and Incentives. The CCPA prohibits discrimination against California residents for exercising their rights under the CCPA and imposes requirements on any financial incentives offered to California residents related to their personal information.

Authorized Agents. You may designate an authorized agent to exercise your right to know, to correct, or to delete. If an authorized agent submits a request on your behalf, the authorized agent must submit with the request another document signed by you that authorizes the authorized agent to submit the request on your behalf. In addition, we may ask you or your authorized agent to follow the applicable process described above for verifying your identity. You can obtain the “Authorized Agent Designation” form by contacting us at admin@beckway.com.

In the alternative, you can provide a power of attorney compliant with the California Probate Code.

Marketing

Beckway 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 Beckway you can (i) unsubscribe from Beckway communications sent by email using a link provided in marketing emails sent from Beckway; or (ii) contact us to exercise your right to prevent all forms of marketing (both post and email).

Children

Beckway’s websites are not intentionally designed for or directed at children under the age of 16. It is Beckway’s policy never to knowingly collect or maintain information about anyone under the age of 16, except as part of an engagement to provide professional services.

Links

Beckway websites may contain links to other sites, including websites maintained by Beckway affiliates 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 Beckway provides links to third party websites, such links do not constitute an endorsement, sponsorship, or recommendation by Beckway of the third parties, the third-party websites, or the information contained on those websites, and Beckway 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 Beckway websites you consent to the collection, use and storage of personal information as described in this Privacy Policy and elsewhere on the websites. Beckway reserves the right to make changes to this Website Privacy Policy from time to time. Beckway 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 Beckway’s personal data processing policies, please contact us at admin@beckway.com or Data Protection Officer, c/o Legal Department, Beckway Group, LLC, 450 Lexington Avenue, 4 ^th Floor, New York, NY 10017.

Beckway Cookie Policy

Effective Date: March 1, 2024.

This policy applies to Beckway and its affiliated companies (collectively “Beckway”).

Beckway 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 Beckway to improve and enhance your user experience when using our websites. This Cookie Policy should read in conjunction with the Beckway Privacy Policy, above.

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 Beckway’s websites is used for authentication and identification of your session and allows Beckway to display the correct information on the website. Beckway 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. By clicking the “Allow all cookies” button on the cookies notice that appears on our website, you agree to our use of all cookies described in our cookie policy.

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

Cookie retention: This website uses cookies which are persistent and non-persistent (session-based). While many of the cookies used on this website only last for the duration of your use of this website (session-based cookies), other cookies are persistent, i.e., stay in one of your browser’s subfolders until you delete them manually or your browser deletes them.

What types of Cookies may be used?

First party cookies – First party cookies are set by the Beckway website you are visiting and they can only be read by Beckway.

Session cookies – Session cookies are used by the server to store information about user page activities so users can easily pick up where they left off on the server’s pages. These are temporary cookie files, which are erased when you close your browser, and when you restart your browser and go back to the site that created the cookie, the website will not recognize you. You will have to log back in (if login is required) or select your preferences/themes again if the website uses these features. A new session cookie will be generated, which will store your browsing information and will be active until you leave the site and close your browser.

Persistent cookies – Persistent cookies are employed to store user preferences. These files stay in one of your browser’s subfolders until you delete them manually or your browser deletes them based on the duration period contained within the persistent cookie’s file.

Third party cookies – Third party cookies are set by a different organization to the owner of the website you are visiting. For example, the website might use a third-party analytics company that will set its own cookies to perform this service (for example, as described below, this website uses Google Analytics).

What cookies does Beckway websites use?

The cookies used on our site may fall into the following categories:

• Necessary – Necessary cookies help make a website usable by enabling basic functions like page navigation and access to secure areas of the website. The website cannot function properly without these cookies.
• Preference – Preference cookies enable a website to remember information that changes the way the website behaves or looks, like your preferred language or the region that you are in.
• Statistics – Statistics cookies help website owners to understand how visitors interact with websites by collecting and reporting information anonymously.
• Marketing – Marketing cookies are used to track visitors across websites. The intention is to display ads that are relevant and engaging for the individual user and thereby more valuable for publishers and third-party advertisers.
• Unclassified – Unclassified cookies are cookies that we are in the process of classifying, together with the providers of individual cookies.

A list of all the cookies used on this site by category is detailed below.

Note: This website does not use any cookies which retain personal information about you after your session ends.

The table below provides additional details on the specific cookies used on Beckway’s website:

As noted, Beckway websites use Google Analytics, a web analytics service provided by Google, Inc. (“Google”) to help analyze how users use the site, for example which pages are most frequently visited. The information generated by a Google Analytics cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

If the way Beckway uses cookies changes significantly (e.g. a new cookie being added with different functionality), Beckway 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 clicking the “I Accept” button on the cookies notice that appears on our website, you agree to our use of all cookies described in our cookie policy. If you do not accept the use of cookies, only “essential” cookies will be placed, but some functionality of the site may be affected. 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 Beckway websites or degrade your browsing experience.

Contact Us

If you have questions or concerns regarding this policy or Beckway’s personal data processing policies, please contact Beckway at: admin@beckway.com.

POLICY ON EU-US DATA PRIVACY FRAMEWORK (DPF), UK EXTENSION TO THE EU-US DPF, AND SWISS-US DPF

Beckway complies with the EU-U.S. DPF-, the UK Extension to the EU-US DPF, and the Swiss-US DPF (collectively the “DPF”) as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the member countries of the European Union (EU), the European Economic Area (EEA), the UK, and Switzerland to the United States (“Personal Information”). Beckway has certified to the Department of Commerce that it adheres to the DPF Principles. If there is any conflict between the terms in this policy and the DPF Principles, the DPF Principles shall govern. To learn more about the DPF program, and to view Beckway’s certifications, please visit www.dataprivacyframework.gov/s/.

Beckway’s participation in the DPF applies to personal data received from the EU/EEA, the UK, and Switzerland. Beckway will comply with the DPF Principles in respect of such personal data. Some types of Personal Information may be subject to additional privacy-related requirements and policies, which are consistent with the DPF Principles. For example:

• Personal Information regarding and/or received from clients is also subject to any specific agreement with, or notice to, the client, as well as additional applicable laws and professional standards.
• Personal Information regarding Beckway personnel is subject to internal human resource policies.
• Personal Information received via Beckway’s websites is subject to this Web Privacy Policy.

Types of Personal Information Collected and Purpose for Collection

Personal Information from Client Engagements: Beckway provides professional consulting services to its clients. Beckway’s clients may send Personal Information to it for processing on their behalf as part of the consulting services they have purchased. For example, Beckway may receive Personal Information such as name, email address, employment information, or financial data. Beckway uses any such Personal Information to perform services for its clients and to administer and manage its relationships with its clients.

In the event that a client engagement involves a transfer of Personal Information from the EU to the United States, the relevant clients are responsible for providing appropriate notice, where required, to the individuals whose Personal Information may be transferred to Beckway, including providing individuals with certain choices with respect to the use or disclosure of their Personal Information, and obtaining any requisite consent. Beckway handles such Personal Information in accordance with its clients’ instructions.

Personal Information from Beckway Website Use: Beckway may collect Personal Information when you choose to access and use Beckway’s websites. Please see the Website Privacy Policy for more information regarding the types of Personal Information collected and the purposes of collection.

Personal Information Regarding Beckway Employees: Beckway may transfer Personal Information regarding Beckway personnel. This Personal Information may include, without limitation, business contact information, employee ID, job role and reporting line, demographic information, work history, compensation and performance ratings. Beckway uses such information to administer and manage its business.

Choice and Accountability for Onward Transfer

Beckway will not transfer, disclose, sell, distribute, or lease your Personal Information to third parties other than as described in this Privacy Policy unless it has your permission or is required or permitted by law (including to meet national security or law enforcement requirements). Beckway may share such information with its affiliates as necessary to carry out the purposes for which the information was supplied, collected, or received. Similarly, third party contractors, consultants and/or vendors engaged by Beckway to assist it in providing its services may have access to such Personal Information (these third parties must first agree to maintain the strict confidentiality of such information and provide the same level of data security as provided by Beckway). Beckway remains responsible and liable under the DPF Principles if third party agents that it engages to process the personal data on its behalf do so in a manner inconsistent with the Principles.

Information Security and Data Integrity

Beckway has reasonable security policies and procedures in place to protect Personal Information from unauthorized loss, misuse, alteration, or destruction.

Despite Beckway’s best efforts, however, security cannot be absolutely guaranteed against all threats. To the best of Beckway’s ability, access to your Personal Information is limited to those who have a need to know.

Access

If Beckway holds your Personal Information, under most circumstances you have the right to reasonable access to that data to correct any inaccuracies. You can also make a request to update or remove information about you by contacting admin@beckway.com, and Beckway will make all reasonable and practical efforts to comply with your request, so long as it is consistent with applicable law and professional standards.

Recourse, Enforcement and Liability

Beckway commits to resolve complaints about your privacy and its collection or use of your Personal Information in compliance with the EU-US DPF, the UK Extension to the EU-US DPF, and the Swiss-US DPF Principles. Please contact Beckway at: admin@beckway.com should you have a DPF-related (or general privacy-related) complaint.

If you are a resident of the EU/EEA or UK, and you have a complaint related to this Policy that cannot be resolved with Beckway directly, you may report your claim to the Data Protection Authorities located in your jurisdiction. If you are a resident of Switzerland, and you have a complaint related to this Policy that cannot be resolved with Beckway directly, you alternatively may report your claim to the Swiss Data Protection Authority (Federal Data Protection and Information Commissioner). As further explained in the DPF Principles, a binding arbitration option will also be made available to you in order to address residual complaints not resolved by any other means.

Beckway is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).

Changes to this Policy

Beckway reserves the right to make changes to this Policy on EU-US Data Privacy Framework (DPF), UK Extension to the EU-US DPF, and Swiss-US DPF from time to time. Beckway will notify you by posting amendments on this website.

Questions and Comments

If you have questions or concerns regarding this policy or Beckway’s Personal Information processing policies, please contact Beckway at: admin@beckway.com.

**This policy covers Beckway and its subsidiaries including: Hemingway Capital, Steinbeck Investment Company, Beckway Ventures, and Embassy Park Investment Company.