R3 Foundation Privacy Policy

Information this Privacy Policy applies to

This Privacy Policy applies to the collection, use, disclosure and retention of information from and about you by R3 on https://breakpoint.corda.xyz/ (the "Website"), through email communications, and through other sources. This Privacy Policy does not apply to other websites which may be accessible through hyperlinks on the Website.

While the Website may include links to third-party websites, plug-ins and applications, linking to a third-party site, this does not necessarily mean that, in relation to such third-party site, we (i) endorse the site, (ii) endorse any products or services described on that site, or (iii) any other material contained on the site.

To the extent any linked websites you visit are not owned or controlled by us, we are not responsible for the sites' content, any use of the sites, or the privacy practices of those sites. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy policy, so please review the privacy policy on those other websites for details on how they handle your information.

If you do not agree with how your Personal Data will be processed as described in this Privacy Policy, you should refrain from using our Website. We may update or modify this Privacy Policy from time to time at our sole discretion, and will note the date of last update on the top of this page. We encourage you to visit this area frequently to stay informed. It is also important that the information we hold about you is accurate and current. Please therefore keep us informed if your information changes during your relationship with us.

What information R3 collects

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you:

1. Identity Data includes first name, last name, company, and title.
2. Contact Data includes email address and telephone numbers.
3. Technical Data includes internet protocol (IP) address, your login data, browser type and version, Media Access Control address, time zone setting and location, browser plug-in types and versions, operating system and platform, device information, domain, webpage address that linked you to our Website, pages visited, and whether you have visited us before or are new to the Website.
4. Usage Data includes information about how you use the Website, and our products and services.
5. Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data under law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data), nor do we collect any information about criminal convictions and offences.

How R3 collects your information

We may obtain about you from various sources.

We may collect this information when you provide it on our Website, in telephone or email communication, through third parties, or at one of our events. When you visit the Website, we may also collect certain information about your device or usage by automated means or by using technologies such as cookies, web server logs, and web beacons, as described below.

Information that You or Others Provide

You may choose to provide information (such as Identity Data or Contact Data) to us when you correspond with us by filling in forms, post, phone, email or otherwise. If you provide us with information regarding another individual, we will assume that you have that person's consent to give us their information.

Information Collected Automatically

When you visit the Website or open an email that we send you, we may collect Technical Data and Usage Data about your equipment, browsing actions and patterns by automated means or by using technologies such as cookies, web server logs, and web beacons, as well as other web-based technologies.

• Cookies: Cookies are small text files that websites send to your computer or other Internet-connected device to uniquely identify your browser or to store information or settings in your browser. Your browser may tell you how to be notified when you receive certain types of cookies and how to restrict or disable certain cookies. Some cookies may exist for only a single session and some are persistent for multiple sessions over time. We may use cookies that are managed by R3 or by third parties for the purposes provided in this Privacy Policy, including for session management, authentication, user preference storage, Website performance and personalization, Website analytics, content management, search, and social media integration. Further information is available in our Cookies Policy.
• Web server logs: In conjunction with obtaining information through cookies, our web servers may log details regarding your device, operating system, or information about your Website usage.
• Web beacons & pixels: To control which web servers collect information described above, we may place tags on our Website or in emails called "web beacons" or "pixels." These are computer instructions that link web pages to particular web servers and their cookies. Web beacons and pixels can be used to track the pages you view, links that you click, or other online behaviour. These tools may also be used to measure the effectiveness of our email campaigns by identifying the individuals who open or act upon an email message, when an email message is opened, how many times an email message is forwarded, the type of software, device, operating system and browser used to deliver the email, and any URL accessed through our email message.
• Other: We may use other technology to collect information for the purposes described in this Privacy Policy.

At this time, we do not honour "do not track" signals from website browsers. However, you may refuse or delete cookies. If you refuse or delete cookies, some of the functionality of the Website may be impaired. If you turn off cookies, web beacons and other technologies will still detect visits to the Website, but the information they generate cannot be associated with other non-identifiable cookie information and is disregarded. Please refer to your browser Help instructions to learn more about how to manage cookies and the use of similar technologies.

How R3 processes your information

We collect, maintain, and use your information for the following purposes:

• to send information to you about our products and services and marketing events (subject to you being able to opt out at any time);
• responding to your inquiries or feedback;
• analysing and improving the Website (including developing new services; improving safety; managing our communications; performing market research; performing data analytics; and performing accounting, auditing and other internal functions);
• entering into or performance of contractual obligations;
• contacting you in relation to promotions, competitions or prize draws;
• to safeguard legitimate interests;
• maintaining the security and integrity of our systems, including maintaining internal records;
• conforming to legal requirements or industry standards, complying with legal process, detecting and preventing fraud or misuse, defending our legal rights, or protecting others;
• on the basis of your consent; and/or
• as part of a merger, acquisition, bankruptcy, transfer, sale, corporate change, or any other transaction involving all or a portion of R3's assets.

All information we collect may be aggregated and merged or enhanced with data from other sources, such as third parties. We may also collect and store information locally on your device using mechanisms such as browser web storage (including HTML 5) and application data caches.

The below table describes our use of your personal data, and the legal bases relied on, as well as our legitimate interests where appropriate.

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

We will not store your personal data for longer than required for the purposes described above, and will delete your personal data in accordance with our data deletion policy.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Please contact us if you need details about the specific legal grounds, we are relying on to process your personal data where more than one ground has been identified.

How R3 shares your information

1. To maintain the Website or for sales and marketing purpose.

We may disclose your information to third parties performing required services on our behalf or who help us maintain the Website or sales and marketing efforts. Examples of these service providers include entities that provide web hosting or analytics services. These service providers may be located around the world.

2. Third party advertising.

We may also contract with third-party advertising networks that collect IP addresses and other information through the use of cookies, web server logs and web beacons on the Website and emails; on third-party websites and emails; and on our advertising placed on third-party websites. They use this information to provide advertisements about products and services tailored to your interests (including for companies not affiliated with us). You may see these advertisements on other websites. This process also helps us manage and track the effectiveness of our and third-party marketing efforts. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

3. For legal reasons.

We may share your information if necessary to protect the safety, property, or other rights of us, our customers, or employees, or when otherwise required by law. We may also share your information with your consent in certain circumstances.

4. Business sale or reorganization.

We reserve the right to transfer information we have about you in the event we sell, transfer, or engage in another transaction involving all or a portion of our business or assets, or undertake another form of corporate change, including bankruptcy. Following such a sale, transfer, or transaction, or corporate change, you may contact the entity to which we transferred your information with any inquiries concerning the processing of that information.

5. Data hosting providers.

Your information may be stored in databases maintained by R3 (including local storage) or third parties providers, and may be disclosed to third parties for the purposes stated in this Privacy Policy.

Whenever we transfer your personal data out of the EEA and UK, we ensure that a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission and the UK's Information Commissioner's Office (ICO). For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries and ICO: Adequacy of the protection of personal data in non-UK countries.
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries and the UK International Data Transfer Agreement (IDTA) and the International Data Transfer Addendum to the new European Commission SSCs (Addendum).

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA or UK.

How R3 secures your information

R3 will take reasonable precautions and put in place appropriate security measures to protect your information from loss and unauthorized access, misuse, alteration or disclosure. In addition, we limit access to your information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your information on our instructions and they are subject to a duty of confidentiality. Please be aware, however, that any email or other transmission you send through the Internet cannot be completely protected against unauthorized interception.

We have also put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Information relating to children

R3 does not intentionally collect information from children under 13 years of age, and children under age 13 should not submit any information to us. If we become aware that a child has provided us with information without parental consent, or a parent or guardian of a child contacts us through the contact information provided below, we will use reasonable efforts to delete the child's information from our databases.

Data Retention

We only store data for as long as it is reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

Your rights under the California Consumer Privacy Act (and the California Privacy Rights Act)

If you are a California resident, you have the right to request information from R3 regarding the manner in which R3 shares certain categories of your personal information with third parties, for the third parties' direct marketing purposes. California law provides that you have the right to submit a request to R3 at its designated email address and receive the following information:

• The categories of information R3 disclosed to third parties for the third parties' direct marketing purposes during the preceding calendar year; and
• The names and addresses of third parties that received such information, or if the nature of their business cannot be determined from the name, then examples of the products or services marketed.

Your rights under the EU General Data Protection Regulation and the UK GDPR

If and insofar as the processing of your personal information is subject to the EU General Data Protection Regulation ("GDPR") or UK General Data Protection Regulation ("UK GDPR"), you have the following rights:

• Right of access — you have the right to request a copy of the data that we hold about you.
• Right of rectification — you have a right to correct data that we hold about you that is inaccurate or incomplete.
• Right to erasure — you can ask for the data we hold about you to be erased from our records.
• Right to restriction of processing — you can ask for us to restrict the way we process your data.
• Right to data portability — you have the right to have the data we hold about you transferred to another organisation.
• Right to object — you have the right to object to our processing your data where we are relying on a legitimate interest in order to process it.
• Right to withdraw your consent – where the processing of your personal data is based on consent, you have the right to withdraw your consent at any time.

Please note that these rights are not absolute and certain exemptions apply.

If and insofar the processing of your personal data is subject to the GDPR, you have the right to make a complaint at any time to a supervisory authority. If and insofar the processing of your personal data is subject to the UK GDPR, you have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

If you wish to exercise any of the rights set out above, please click here.

Contacting R3?

R3 is committed to working with you to obtain a fair and rapid resolution of any queries, complaints, or disputes about privacy. If you have submitted information to R3 and you would like to exercise your rights outlined in sections 9 or 10 above, or if you have any other questions or comments regarding our privacy practices, please email us at privacy@r3.com for more information.