HAMMERSON – SHAREHOLDERS & INVESTOR RELATIONS PRIVACY NOTICE
Introduction.
This privacy notice (the “Notice”) details how Hammerson (as defined below) gathers and uses personal information about its current, former or prospective shareholders and, where applicable, their respective representatives.
About us and how to contact us.
This Notice explains how Hammerson PLC, a company incorporated and registered in England and Wales (company number 00360632) which has its registered office at Marble Arch House, 66 Seymour Street, London, W1H 5BX (“Hammerson”), collects, uses, and manages your personal data in compliance with applicable data protection law.
This Notice extends to the share registry services, which are set out in more detail below, provided by Link Market Services Limited, our registrar appointed under the rules of the Companies Act 2006 to manage our register of shareholders (our “Registrar”). If you use any of the apps, engagement tools or other services made available to you by our Registrar, you should be aware of the additional privacy notices which they make available for the relevant services provided. This Notice is intended to supplement those notices.
If you have any questions relating to this Notice or would like to exercise your legal rights set out in this Notice, please contact our data protection officer by email to [email protected].
How we collect and use your personal data
We either collect information from you directly, for example when you become a shareholder, when you communicate with us, when you exercise your rights in respect of your shares at meetings and voting in person or by proxy; from third parties acting on your behalf, such as your agent, stockbroker or share administrator; or from third parties who perform services on our behalf such as our Registrar. We may also capture your image and/or your voice on visual and/or audio recording equipment, for example on any recordings made of our general meetings if you attend such meetings, and on any recordings made of other presentations to shareholders if you attend such presentations.
How we use your personal data and our legal basis for doing so
We collect and use your personal data as follows:
Management of shareholdings: to manage your shareholding in compliance with Hammerson’s articles of association, including providing you with related shareholder information - such as notices of meetings and financial reports - and communicating with you in the ways referred to therein, completing transactions that you instruct us to undertake and any pursuant legal obligations, and to provide you with dividends, certificates and notices;
Administration of shareholdings: to give instructions to manage and operate your shareholder account to facilitate the administration of your shareholding. This includes retaining records of your instructions and keeping your shareholder records up to date, allowing you to exercise your rights as a shareholder; contacting you with shareholder related information including general meetings;
Relationship management: to enable us to manage our relationship with you, including by meeting with you, communicating with you and answering questions you ask of us, responding to any complaints and data rights that you invoke and keeping your shareholder records up to date; and providing you with information about relevant products and services;
Compliance with laws and regulations: to comply with laws and regulations to which Hammerson is subject, including those that require us to keep records and file returns about the shareholdings in Hammerson, pay you amounts due on your shares (including laws and regulations relating to sanctions and other financial crime), send you information about Hammerson and comply with disclosure requirements imposed or enforced by governmental authorities and regulatory agencies, including law enforcement agencies and tax authorities or requests under the Companies Act 2006;
Analytics: to administrate investor analytics, statistical analysis and share register analysis;
Safety and security: to seek to ensure the safety and security of attendees at our general meetings and at presentations to shareholders, to keep records of those events, and to keep our websites secure;
Other legal purposes: to enable us to enforce or defend our legal rights, including by bringing or defending legal claims that may be made by or against Hammerson in relation to your shareholdings or interests in shares.
We collect and use your personal information in the ways described in this Notice because:
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Legal obligation: we are required to comply with our legal obligations as UK listed company and in compliance with laws and regulations to which Hammerson is subject;
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Contract: it is necessary to perform our contract(s) with you as a shareholder and/or holder of interests in shares in Hammerson;
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Legitimate interests: it is in our legitimate interests, in the course of running our business, or to establish, exercise and defend our legal rights or otherwise to achieve the purposes referred to above that do not relate to complying with a legal obligation or performing our contract with you. Where we process your personal data only on the basis of our legitimate interest, you have the right to object to that use, please refer to the ‘Your data protection rights’ section below.
What personal data we collect
We may collect and use all or any of the following categories of personal information, with the support of our Registrar:
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personal details such as name and address, occupation, contact details, email address, telephone number, and contact preferences where you have provided these to us;
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documentation confirming your identity when you contact or engage with us;
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details of your past or present holdings of shares and/or interests in shares in Hammerson, whether you hold or held these as legal owner or have or had a beneficial interest in them;
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your bank or building society account details into which dividends and other income or capital returns on your shares have in the past, or should in the future, be paid;
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your image/voice, where and if it is captured by visual or audio recording equipment;
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information about the transactions and investments you make or have made, in your own name, in the past, including financial data and voting and preference instructions; and
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information about other people, such as your spouse, joint holders, appointed proxies, corporate representatives and other connected parties, as necessary for us to administer your shareholding and allow you to exercise your rights.
How long will we hold your information
We retain the personal information we collect for as long as necessary for the purposes described in this Notice. Where you are a shareholder, this will be for as long as you hold shares or an interest in shares in Hammerson, and we will also retain your personal data after you cease to hold shares or an interest in shares in Hammerson for a period of 12 years or so as long as necessary to deal with any outstanding matters relating to your holding or interest, including where legal claims have arisen or might arise.
To determine the appropriate period for holding your personal data, we consider the applicable legal requirements, the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes we process your personal data for, and whether we can achieve those purposes through other means.
Sharing your personal data
We share your personal data with our Registrar for the purposes set out in this Notice. We may also share your personal data with carefully selected third party suppliers and service providers to Hammerson and its group companies and affiliates, for example professional advisors.
We may also share your personal data with our group companies and affiliates who may process data on our behalf to enable us to comply with our legal obligations.
We may also disclose your personal data, where disclosure is necessary to protect our rights, investigate fraud, or comply with the law, including valid legal requests from the regulator, or other government agencies or departments.
Where your personal data is held
We may store or process your personal data outside the United Kingdom (UK) or the European Economic Area (EEA). Whenever we transfer your personal data out of the UK or EEA to countries which have laws that do not provide the same level of data protection as UK and EU law, we always ensure that a similar degree of protection is afforded to it by ensuring that appropriate safeguards are implemented, such as the use of standard contractual terms approved for use in the UK and EU respectively, which give the transferred personal data the same protection as it has in the UK and EU .
Your data protection rights
Under data protection law, you have the following rights in relation to the personal data we are processing about you. The rights available to you depend on our reason for processing your information.
Right to be informed: You have the right to be provided with concise, transparent and easily understandable information about how we collect and process your personal data. This Notice sets out this information.
Right of access: You have the right to ask us for copies of your personal information. This right always applies. There are some exemptions, which means you may not always receive all the information we process.
Right to rectification: You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete. This right always applies.
Right to erasure: You have the right to ask us to erase your personal information in certain circumstances, for example where you request erasure and there is no other legal justification for the use of your information.
Right to restriction of processing: You have the right to ask us to restrict the processing of your information in certain circumstances, for example where you have requested an update to your personal data.
Right to data portability: This only applies to personal data you have given us. You have the right to ask that we transfer the information you gave us from one organisation to another, or give it to you. The right only applies if we are processing information based on your consent or under, or in talks about entering into a contract and the processing is automated.
Right to object and/or to withdraw consent: You have the right to ask us to stop processing your personal data, and we will do so, unless we can demonstrate compelling legitimate grounds for the processing; or the need to use your personal data in connection with any legal claims. If you have provided your consent to process your personal data and that is our legal basis for processing, you have the right to withdraw that consent at any time.
Right to not be subject to a decision based solely on automated processing: You have the right not to be subject to a decision when it is based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you. This right is not applicable if profiling is necessary for the performance of a contract between you and us.
If you wish to make a request, please email [email protected]. We may require additional information to either confirm your identity before we can process your request and/or to assist us in responding to your request.
Right to complain to a data protection supervisory authority
If you have a concern about any aspect of our data protection practices, including the way we are processing your personal data, you have the right to report it to the supervisory authority in the United Kingdom (the Information Commissioner’s Office (ICO) - www.ico.org.uk) or any other competent supervisory authority in the country of residence.
Modifications of this policy
We may revise this Notice from time to time. If we make any changes to this Notice that may materially impact you or our processing of your personal data, we will notify you by email (sent to the email address provided to our Registrar) or by means of a notice on our website prior to the change becoming effective.
Date issued: 16 December 2024