1. Introduction

This is the Privacy Policy for www.creditbenchmark.com (the “Site”) and the Credit Benchmark CB WebApp client
portal (the “Portal”). The Site and Portal are operated by Credit Benchmark Limited.

We recognise that many visitors and users of this Site and our Portal are concerned about the information
they provide to us, and how we treat that information. This privacy policy, explains who we are, why and how
we collect and process your personal information (also referred to here as personal data) what we do with it,
your rights and what controls you have.

For the purposes of United Kingdom (UK) and European Data Protection Law, we are the data controller in
relation to the personal data processed in accordance with this policy, (except where this policy explains
otherwise). Your use of this Site and where relevant our Portal indicates to us that you have read and
understood our privacy practices, as outlined in this privacy policy. If you have any questions or concerns
regarding this privacy policy, please contact: [email protected].

We may update this privacy policy from time to time by changing it on the Site and the Portal and will take
steps where possible to notify you in relation to any material changes. Please check this policy regularly
for changes. If you continue to use the Site or Portal or if you submit information to us following such
changes, we will take your continued use as acceptance of the new terms. This privacy policy was last updated
December 2024.

This policy sets out:

• What information we collect
  aboutyou
• Our use of Cookies and other technologies
• How we use the information we collect
• Our promotional updates
  and communications
• When we share the information we collect
• Where we store or transfer information
• Data security
• How long we keep your information
• Links
• Your rights
• Contacting us

What information we collect about you

Alongside to cookies, we use API to collect user navigation details and content viewed on our site.
Collected details are stored in our premises in secured storage. This data is used for aggregating and
analysing the usage. Analysed details are used to improve our product and also to understand user needs.
Certain cookies we use last only for the duration of your web session and expire when you close your browser.
Other cookies are used to remember you when you return to the Site and will last for longer. We use the
following categories of cookies:

Essential cookies:

These are cookies that are required for the operation of our Site and the Portal and our terms with you.

They help you to authenticate and navigate our content and use our online features, they ensure your
page requests are loaded in a smooth and secure manner and enable authorised users to login to our Portal.
Without these cookies we would not be able to provide our services to you through the Site or Portal.

Analytics cookies: From time to time we use third party services such as Google Analytics
to collect, and analyse information about how visitors interact with our Site and Portal.

This information is used in our legitimate interests to produce reports that help us to understand how our
Site and Portal is used and so that we can make improvements to each.

Click here for more information about privacy at
Google or to opt-out of Google Analytics.

In addition we have activated the IP masking feature when using Google Analytics which means that
Google anonymises the last octet of the IP address it receives from users’ devices. For more information
see: https://support.google.com/analytics/answer/6004245

Our use of Cookies and other technologies

Most web browsers automatically accept cookies but, if you prefer, you can change your browser to prevent that
or to notify you each time a cookie is set. You can also learn more about cookies by visiting www.allaboutcookies.org  which includes additional
useful information on cookies and how to block cookies using different types of browser. Please note however,
that by blocking or deleting cookies used on the Site you may not be able to access our site and also take
full advantage of the Site or Portal if you do so.

If you want to disable cookies on our Site, you need to change your website browser settings to reject
cookies. How you can do this will depend on the browser you use.   Further details on how to
disable cookies for the most popular browsers are set out below:

For Microsoft Internet Explorer:

• Choose the menu “tools” then “Internet Options”
• Click on the “privacy” tab
• Select the setting the appropriate setting

For Google Chrome:

• Choose Settings> Advanced
• Under “Privacy and security,” click “Content settings”.
• Click “Cookies”

For Safari:

• Choose Preferences > Privacy
• Click on “Remove all Website Data”

For Mozilla Firefox:

• Choose the menu “tools” then “Options”
• Click on the icon “privacy”
• Find the menu “cookie” and select the relevant options

For Opera 6.0 and further:

• Choose the menu Files”> “Preferences”
• Privacy

Where you have not set your permissions, we may also separately prompt you regarding our use of cookies on
the Site.

You can find more information about the individual cookies we use and the purposes for which we use them below:

Alongside of cookies we also use browser session/local storage to keep
Okta login user and web site navigation details to persist the state of filters of a page. This data is
temporary and lifetime of this data is limited to browse session and would be removed on closing the
browser.

2. How we use the information we collect

We use information held about you in the following ways:

(i) Directly identifiable information you choose to provide

We use your personally identifiable information to ensure in our legitimate interests that we provide you with
the information or content that you have requested. In some cases, we may contact you about our programs,
products, features or services provided you have given your consent to receive marketing material from us at
the point we collected your information where required or otherwise in our legitimate interests and where
these do not override your right to object to being contacted by us for these purposes. See ‘Our promotional
updates and communications’.

Where relevant we will take steps at your request to enter into any contract between you or the company
you work for and us in order to supply services to you or your employer,  in administering your/your
company’s account under the contract with us and where relevant to notify you of changes to our service.

We use information collected on our Site in our legitimate interests to better understand at an
aggregate level, your use of the Site and to enhance your enjoyment and experience. For example, we may use
the information to improve the design and content of our Site or to analise the programs and services that
we offer.

(ii) Information we receive from other sources

We use information provided by your employer to create, in our legitimate interests your account as
an authorized user of the Portal to facilitate your access to the Portal we may combine this information
with information you give to us and information we collect about you in our legitimate interests (where we
have considered that these are not overridden by your rights). We will use this information and the
combined information for the purposes set out above (depending on the types of information we receive).

(iii) Automatic and other information we collect

We will use this information in our legitimate interests, where we have considered these are not overridden by
your rights in order to administer our Site and the Portal and for internal operations,
including troubleshooting, data analysis, testing, research statistical and survey purposes. We also use
this information to keep our Site and Portal secure and to ensure that content is presented in the most
effective manner for you and your device.

(IV) Microsoft clarity and microsoft advertising

We partner with Microsoft Clarity and Microsoft Advertising to capture how you use and interact with
our website through behavioral metrics, heatmaps, and session replay to improve and market
our products/services. Website usage data is captured using first and third-party cookies and other
tracking technologies to determine the popularity of products/services and online activity. Additionally, we
use this information for site optimization, fraud/security purposes, and advertising. For more information
about how Microsoft collects and uses your data, visit the Microsoft Privacy Statement.

3. Our promotional updates and communications

You can tell us not to contact you with information regarding our services either at the point any
such information is requested by us on the Site or, where you no longer wish to receive communications,
including press releases or any other type of information from us, by following the unsubscribe instructions
on any communications we send to you. You can also exercise the right at any time by sending us an email
to [email protected] or through our “Contacting
Us” details below to change your preferences.

4. When we share the information we collect

We may employ other companies and individuals who assist us in providing the services through the
Site, fulfilling requests for information, and providing support to perform functions on our behalf from time
to time. In particular:

• Any member of our group which means our subsidiaries, our ultimate holding company and its subsidiaries,
  who support our processing of personal data under this policy;
• Other organizations who process your personal data on our behalf and in accordance with our instructions
  and UK, EEA or EEA member state Data Protection Law. This includes in supporting the services we provide
  in particular those providing website and data hosting services, providing fulfilment services,
  distributing any communications we send, supporting or updating marketing lists, facilitating feedback on
  our services and providing IT support services from time to time. These organizations (which may include
  third party suppliers, agents, sub-contractors and/or other companies in our group) will only use your
  information to the extent necessary to perform their support functions.
• Analytic and search engine providers who assist us in the improvement and optimization of our
  site and subject to the cookie section of this policy; and
• Our auditors, legal advisors and other professional advisors.

Our employees, agents and contractors who have access to personally identifiable information will only use the
information necessary to perform their functions and are required to protect the information in a manner that
is consistent with this privacy policy.

We may also provide access to your personally identifiable information when legally required to do so,
to cooperate with police investigations or other legal proceedings, to protect against misuse or
unauthorized use of our Site or Portal, to limit our legal liability and protect our rights, or to protect
the rights and safety of visitors to this Site or of any person. In those instances, the information is
provided only for that limited purpose.

In the event that we undergo a re-organization or are sold to a third party, you agree that any
personal information we hold about you may be transferred to that re-organised entity or third party.

We may disclose aggregate statistics about visitors to our Site in order to describe our Site and services to
prospective partners and other reputable third parties and for other lawful purposes but these
statistics will include no personally identifiable information.

5. Where we store or transfer information

We may transfer your personal information outside the UK or the EEA:

• In order to store it
• In order to enable us to provide our Site or Portal to you and fulfil our contract with your company
• Where we are legally required to do so
• In order to facilitate the operation of our group of businesses, where it is in our legitimate interests
  and we have concluded these are not overridden by your rights.

We transfer data to the USA, for the purpose of sharing data with our US based employees

We also transfer your information to our partners abroad. For a full, current list of who we share
your personal data with internationally, please contact us at [email protected].

6. Data security

Have put in place measures to seek to maintain the security of the personally identifiable information that we
collect, including limiting the number of people who have physical access to our database servers, as well as
installing electronic security systems that guard against unauthorised access.

Please note however that although SSL encryption is in place for the Site no data transmission over
the Internet can be guaranteed to be completely secure. Accordingly, we cannot ensure or warrant the security
of any information that you transmit to us over the internet and any such submission is at your own
risk. Where we have given you (or you have chosen) a password that enables you to access the Portal, you
are responsible for keeping this password confidential. We ask you not to share a password with anyone.

7. How long we keep your information

For job applications, we usually would limit the processing of the personal information gathered for up to one
year, and delete thereafter unless required to hold longer to satisfy legal, contractual or
legitimate interests.

For all other personal data gathered, we would hold for up to seven years, or longer if required to
satisfy legal, contractual or legitimate interests.

8. Links

This Site contains links to third party web sites. Please be aware that Credit Benchmark is not
responsible for the privacy practices of any third party sites. Please also be aware that the privacy
policies of other sites may differ significantly from the privacy policy of this Site. We encourage our users
to read the privacy statement of each and every web site that collects personally identifiable information.
This privacy policy applies solely to information collected by this Site.

9. Your rights

You have the right under certain circumstances:

• (a) To be provided with a copy of your personal data held by us;
• (b) To request the rectification or erasure of your personal data held by us;
• (c) To request that we restrict the processing of your personal data (while we verify or investigate
  your concerns with this information, for example);
• (d) To object to the further processing of your personal data, including the right to object to
  marketing (as mentioned in ‘Our promotional updates and communications’ section)
• (e) To request that your provided personal data be moved to a third party.

You can also exercise the rights listed above at any time by contacting us at [email protected], for the attention of the
Data Protection Officer

If your request or concern is not satisfactorily resolved by us, you may approach your local data
protection authority, (see http://ec.europa.eu/justice/data
protection/bodies/authorities/index_en.html).

The Information Commissioner is the supervisory authority in the UK
and can provide further information about your rights and our obligations in relation to your personal data,
as well as deal with any complaints that you have about our processing of your personal data.

10. Contacting us

Please submit any questions concerns or comments you have about this privacy policy or any requests concerning
your personal information by email to [email protected] or write to us at: Credit
Benchmark, 131 Finsbury Pavement, London EC2A 1NT.