What and how information is collected:
LFG may request and collect information from visitors to the sites and/or our premises, recipients of any investor communications or where you or one of our suppliers or other business partners provide your contact details in order for us to send you information about LFG, our products and services.
We may collect and process the following information about you:
• Information that you give usThis is information about you that you give to us by filling in forms on the sites (or other forms that we ask you to complete), signing up to our newsletters or events, giving us a business card or CV (or similar) or corresponding with us by telephone, post, email or otherwise. It may include, for example, your name, address, email address, telephone number, fax number; information about your place and work and business relationship with LFG, and; information about your professional role, background and interests.
Information that our website and other systems collect about you
o If you visit the sites they will automatically collect some information about you and your visit, including the Internet protocol (IP) address used to connect your device to the Internet and some other information such as your browser type and version and the pages on the site that you visit.
o The sites may also download "cookies" to your device – this is described in our separate cookie notice.
o If you exchange emails or other electronic communications with our employees and other staff members, our information technology systems will record details of those conversations, sometimes including their content. LFG Investor Relations Division may also record business telephone calls.
o Some of our premises have CCTV systems which may record you if you visit our premises, for security and safety purposes.
• We may also collect some information from other sources. For example, if we have a business relationship with the organisation that you represent, your colleagues or other business contacts may give us information about you such as your contact details or details of your role in the relationship
• We may sometimes collect information from third party data providers or publicly available sources for anti-money-laundering, background checking and similar purposes, and to protect our business and comply with our legal and regulatory obligations.
We may use your information for the following purposes:
• to operate, manage, develop and promote our business and, in particular, our relationship with you or the organisation you represent (if any) and related transactions;
• to operate, administer and improve the sites and premises and other aspects of the way in which we conduct our operations;
• to protect the security of our premises;
• to determine your suitability for a role at LFG (where you have sent us your CV);
• to protect our business from fraud, money-laundering, breach of confidence, theft of proprietary materials and other financial or business crimes; and
• to comply with our legal and regulatory obligations and bring and defend legal claims.
We may from time to time review information about you held in our systems – including the contents of and other information related to your email and other communications with us – for compliance and business-protection purposes as described above. This may include reviews for the purposes of disclosure of information relevant to litigation and/or reviews of records relevant to internal or external regulatory or criminal investigations.
To the extent permitted by applicable law these reviews will be conducted in a reasonable and proportionate way and approved at an appropriate level of management. They may ultimately involve disclosure of your information to governmental agencies and litigation counterparties as described below. Your emails and other communications may also occasionally be accessed by persons other than the member of staff with whom they are exchanged for ordinary business management purposes (for example, where necessary when a staff member is out of the office or has left LFG).
We will only process your personal information as necessary so that we can pursue the purposes described above, and then only where we have concluded that our processing does not prejudice you or your privacy in a way that would override our legitimate interest in pursuing those purposes.
In exceptional circumstances we may also be required by law to disclose or otherwise process your personal information. We will tell you, when we ask you to provide information about yourself, if provision of the requested information is necessary for compliance with a legal obligation or, on the other hand, if it is purely voluntary and there will be no implications if you decline to provide the information. Otherwise, you should assume that we need the information for our business or compliance purposes (as described above). If you are uncertain as to LFG's need for information that we request from you, please contact us (see below).
We may disclose personal information about you, where reasonably necessary for the various purposes set out above:
• to the other members of the LFG group of companies;
• to your colleagues within the organisation that you represent;
• to service providers who host the sites or other information technology systems or otherwise hold or process your information on our behalf, under strict conditions of confidentiality and security;
• to a person who takes over our business and assets, or relevant parts of them; or
• in exceptional circumstances:
• to competent regulatory, prosecuting and other governmental agencies, or litigation counterparties, in any country or territory; or
• where we are required by law to disclose.
These disclosures may involve transferring your personal information overseas. If you are dealing with us within the European Economic Area (or the UK, after it has left the European Economic Area), you should be aware that this may include transfers to countries outside the European Economic Area / UK, which do not have similarly strict data privacy laws. In those cases, where we transfer personal data to other members of the LFG or our service providers, we will ensure that our arrangements with them are compliant with applicable law, including, where necessary, being governed by data transfer agreements, designed to ensure that your personal information is protected, on terms approved for this purpose by the European Commission. Please contact us (see below) if you would like to know whether any such agreements are in place or, if so, to see a copy.
Retention and deletion of your information
We will delete the information that we hold about you when we no longer need it. Specific information about our record retention policies is available on request. Please contact us (see below).
Note that we may retain some limited information about you even when we know that you have left the organisation that you represent, so that we can maintain a continuous relationship with you if and when we are in contact with you again, representing a different organisation.
You may have a right of access to the personal information that we hold about you, and to some related information, under data protection law. You can also require any inaccurate personal information to be corrected or deleted. You can object to our use of your personal information for direct marketing purposes at any time and you may have the right to object to our processing of some or all of your personal information (and require them to be deleted) in some other circumstances.
If you wish to exercise any of these rights, please contact us (see below).
If you do not want LFG to send you e-mail or postal mail, you can opt out at any time by contacting LFG by e-mail at email@example.com
Links to other sites
Updating your personal information
If for any reason you wish to access, review, correct or delete the personal information collected about you, you may do so by emailing firstname.lastname@example.org. You must be able to provide your name and e-mail address or other information sufficient to allow us to identify you. Once identified, we will be happy to review, update or remove your information as appropriate.
Changes to this policy