Data Privacy Policy

Introduction

Miller and Vincent Properties Limited (referred to as “MVP”, “We”, “Us”, “Our” from here
forward) understands that your privacy is important to you and that you care about how
your personal data is used. We respect and value the privacy of everyone who visits Our
website http://www.millerandvincentproperties.com (“Our Site”) and will only collect and
use personal data in ways that are described here and in a way that is consistent with Our
obligations and your rights under the regulation, the General Data Protection Regulations
2018 (“GDPR”, “the Regulation”). We will always treat your personal data with utmost
respect.

By providing your Personal Data, you are affirming that you are over 18 years of age.

For the purpose of the General Data Protection Regulations 2018, MVP are the data
controller and are registered with the Information Commissioner’s Office as such with
registration number ZA499542. Please see MVP - ICO Registration Page for further details.

Roles and Responsibilities
MVP’s Data Protection Officer is:
Dwayne Squires (Director)
Email: info@millerandvincent.com
Office Tel No: 01332 219001
In Writing: C/o Fraser Russell Accountants, 77 Francis Road, Edgbaston, Birmingham B16
8SP.

Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance
of this Privacy Policy is deemed to occur upon your first use of Our Site. If you do not accept
and agree with this Privacy Policy, you must stop using Our Site immediately.

If you are not happy with any aspect of how We obtain, hold or use your personal data then
you have a right to make a complaint to the Information Commissioners Office (ICO) –
www.ico.org.uk - We would however prefer that you contact Us first and be given an
opportunity to resolve any issue that you might have.

The Regulation defines “personal data” as any information relating to an identified or
identifiable natural person (a data subject); an identifiable natural person is one who can be
identified, directly or indirectly, in particular by reference to an identifier such as a name, an
identification number, location data, an online identifier, or to one or more factors specific to
the physical, physiological, genetic, mental, economic, cultural, or social identity of that
natural person.

This Policy sets out the procedures that are to be followed when dealing with personal data.
The procedures and principles set out herein must be followed at all times by MVP, its

employees, agents, contractors, or other parties working on behalf of MVP.
MVP is committed not only to the letter of the law but also to the spirit of the law and places
a high premium on the correct, lawful and fair handling of all personal data, respecting the
legal rights, privacy and trust of all individuals with whom it deals.

Summary
MVP will at all times:
a) Be transparent about what information:
i) We collect
ii) Why we collect it
iii) How we store it
iv) Where we store it
v) What we do with it
vi) When we dispose it
vii) How we dispose it
b) Have measures in place to protect your personal data and keep secure;
c) Respect your rights under GDPR and aim to give you control over your own personal
data;
d) Cease communication with you if requested to do so.

1. The Data Protection Principles

This Policy aims to ensure compliance with the Regulation. The Regulation sets out the
following principles with which any party handling personal data must comply. All
personal data must be:

a) Processed lawfully, fairly and in a transparent manner in relation to the data subject.

b) Collected for specified, explicit and legitimate purpose and not further processed in a
manner that is incompatible with those purposes; further processing for archiving
purposes in the public interest, scientific or historical research purposes or statistical
purposes shall not be considered to be incompatible with the initial purposes.

c) Adequate, relevant and limited to what is necessary in relation to the purposes for which
it is processed.

d) Accurate and, where necessary, kept up to date; every reasonable step must be taken to
ensure that personal data that is inaccurate, having regard to the purposes for which they
are processed, is erased or rectified without delay.

a) Kept in a form which permits identification of data subjects for no longer than is
necessary for the purposes for which the personal data is processed; personal data may
be stored for longer periods insofar as the personal data will be processed solely for
archiving purposes in the public interest, scientific or historical research purposes or
statistical purposes subject to implementation of the appropriate technical and
organisational measures required by the Regulation in order to safeguard the rights and
freedoms of the data subject.

b) Processed in a manner that ensures appropriate security of the personal data, including

protection against unauthorised or unlawful processing and against accidental loss,
destruction or damage, using appropriate technical or organisational measures.

2. Lawful, Fair, and Transparent Data Processing
The Regulation seeks to ensure that personal data is processed lawfully, fairly, and
transparently, without adversely affecting the rights of the data subject. The Regulation
states that processing of personal data shall be lawful if at least one of the following applies:

a) The data subject has given consent to the processing of his or her personal data for one
or more specific purposes.

b) Processing is necessary for the performance of a contract to which the data subject is a
party or in order to take steps at the request of the data subject prior to entering into a
contract.

c) Processing is necessary for compliance with a legal obligation to which the controller is
subject.

d) Processing is necessary to protect the vital interests of the data subject or of another
natural person.

e) Processing is necessary for the performance of a task carried out in the public interest or
in the exercise of official authority vested in the controller.

f) Processing is necessary for the purposes of the legitimate interests pursued by the
controller or by a third party, except where such interests are overridden by the
fundamental rights and freedoms of the data subject which require protection of
personal data, in particular where the data subject is a child.

3. Processed for Specified, Explicit and Legitimate Purposes

3.1 MVP collects and processes the personal data set out in Part 20 of this Policy. This may
include personal data received directly from data subjects (for example, contact details
used when a data subject communicates with us)

3.2 MVP only processes personal data for the specific purposes set out in Part 20 of this
Policy (or for other purposes expressly permitted by the Regulation). The purposes for
which we process personal data will be provided to data subjects via a link to our
company Data Privacy, Cookie & Retention Policy either at the time that their personal
data is collected or via a ‘Contact Us’ section (must tick to indicate they have read), or as
soon as possible (not more than one calendar month) after collection where it is
obtained from a third party.

A link to a copy of our Data Privacy, Cookie & Retention Policy is available at any time, at
the bottom of each page of our website: www.millerandvincentproperties.com .

4. Adequate, Relevant and Limited Data Processing

MVP will only collect and process personal data for and to the extent necessary for the
specific purpose(s) informed to data subjects as under Part 3, above.

5. Accuracy of Data and Keeping Data Up to Date
MVP shall ensure that all personal data collected and processed is kept accurate and up to
date. The accuracy of data shall be checked when it is collected and at 12 monthly intervals
thereafter. Where any inaccurate or out-of-date data is found, all reasonable steps will be
taken without delay to amend or erase that data, as appropriate.

6. Data Retention
MVP shall not keep personal data for any longer than is necessary in light of the purposes for

which that data was originally collected and processed. When the data is no longer required,
all reasonable steps will be taken to erase it without delay.
For full details of the Companies approach to data retention, including retention periods for
specific personal data types held by MVP, please refer to our Data Retention Policy section
later in this document.

7. Secure Processing
MVP shall ensure that all personal data collected and processed is kept secure and protected
against unauthorised or unlawful processing and against accidental loss, destruction or
damage. Further details of the data protection and organisational measures, which shall be
taken, are provided in Parts 22 to 28 of this Policy.

8. Accountability

8.1 MVP’s Data Protection Officer is Dwayne Squires (Director) Email:
info@millerandvincent.com .

8.2 The Data Protection Officer shall be responsible for overseeing the implementation of
this Policy and for monitoring compliance with this Policy, MVP’s other data protection-
related policies, and with the GDPR and other applicable data protection legislation.

8.3 MVP shall keep written internal records of all personal data collection, holding, and
processing, which shall incorporate the following information:

a) The name and details of MVP, its Data Protection Officer, and any applicable third-
party data processors.

b) The purposes for which MVP processes personal data.

c) Details of the categories of personal data collected, held, and processed by MVP; and
the categories of data subject to which that personal data relates.

d) Details (and categories) of any third parties that will receive personal data from MVP.

e) Details of any transfers of personal data to non-EEA countries including all
mechanisms and security safeguards.

f) Details of how long personal data will be retained by MVP; and

g) Detailed descriptions of all technical and organisational measures taken by MVP to
ensure the security of personal data.

9. Data Protection Impact Assessments
MVP shall carry out Data Protection Impact Assessments for any and all new projects and/or
new uses of personal data, which involve the use of new technologies, and the processing
involved is likely to result in a high risk to the rights and freedoms of data subjects under the
Regulations.

Privacy Impact Assessments shall be overseen by MVP’s data protection officer and shall
address the following areas of importance:

a) The types of personal data that will be collected held and processed.

b) The purpose(s) for which personal data will be used.

c) The Companies objectives.

d) How personal data is to be used.

e) Any parties (internal or external) who may be consulted.

f) The necessity and proportionality of the data processing with respect to the
purpose(s) for which it is being processed.

g) Risks posed to data subjects.

h) Risks posed both within and to MVP; and

i) Proposed measures to minimise and handle identified risks.

10. The Rights of Data Subjects

The GDPR sets out the following rights applicable to data subjects (please refer to the parts
of this policy indicated for further details):

a) The right to be informed (Part 11);
b) The right of access (Part 12);
c) The right to rectification (Part 13);
d) The right to erasure (also known as the ‘right to be forgotten’) (Part 14);
e) The right to restrict processing (Part 15);
f) The right to data portability (Part 16);
g) The right to object (Part 17);
h) Rights with respect to automated decision-making and profiling (Parts 18 and 19).

11. Keeping Data Subjects Informed

11.1 MVP shall ensure that the following information is provided to every data subject when
personal data is collected:
a) Details of MVP including, but not limited to, the identity of Dwayne Squires
(Director), its Data Protection Officer;

b) The purpose(s) for which the personal data is being collected and will be processed
(as detailed in Part 20 of this Policy) and the legal basis justifying that collection and
processing;

c) Where applicable, the legitimate interests upon which MVP is justifying its collection
and processing of the personal data;

d) Where the personal data is not obtained directly from the data subject, the categories
of personal data collected and processed;

e) Where the personal data is to be transferred to one or more third parties, details of
those parties;

f) Where the personal data is to be transferred to a third party that is located outside of
the European Economic Area (the “EEA”), details of that transfer, including but not
limited to the safeguards in place (see Part 28 of this Policy for further details
concerning such third country data transfers);

g) Details of the length of time the personal data will be held by MVP (or, where there is
no predetermined period, details of how that length of time will be determined);

h) Details of the data subject’s rights under the Regulation;

i) Details of the data subject’s right to withdraw their consent to MVP’s processing of
their personal data at any time;

j) Details of the data subject’s right to complain to the Information Commissioner’s

Office (the ‘supervisory authority’ under the Regulation);

k) Where applicable, details of any legal or contractual requirement or obligation
necessitating the collection and processing of the personal data and details of any
consequences of failing to provide it;

l) Details of any automated decision-making that will take place using the personal data
(including but not limited to profiling), including information on how decisions will
be made, the significance of those decisions and any consequences.
11.2 The information set out above in Part 10.1 shall be provided to the data subject at the
following applicable time:
11.2.1 Where the personal data is obtained from the data subject directly, at the
time of collection;
11.2.2 Where the personal data is not obtained from the data subject directly
(i.e. from another party):
a) If the personal data is used to communicate with the data subject, at
the time of the first communication; or
b) If the personal data is to be disclosed to another party, before the
personal data is disclosed; or
c) In any event, not more than one month after the time at which MVP
obtains the personal data.

12 Data Subject Access
12.1 A data subject may make a subject access request (“SARs”) at any time to find out more
about the personal data which MVP holds about them. MVP is normally required to
respond to SARs within one month of receipt (this can be extended by up to two
months in the case of complex and/or numerous requests, and in such cases the data
subject shall be informed of the need for the extension).

12.2 All subject access requests received must be forwarded to Dwayne Squires (Director)
MVP’s Data Protection Officer. Email: info@millerandvincent.com .

12.3 MVP does not charge a fee for the handling of normal SARs. MVP reserves the right to
charge reasonable fees for additional copies of information that has already been
supplied to a data subject, and for requests that are manifestly unfounded or excessive,
particularly where such requests are repetitive.

13 Rectification of Personal Data

13.1 If a data subject informs MVP that personal data held by MVP is inaccurate or
incomplete, requesting that it be rectified, the personal data in question shall be
rectified, and the data subject informed of that rectification, within one month of
receipt the data subject’s notice (this can be extended by up to two months in the case
of complex requests, and in such cases the data subject shall be informed of the need
for the extension).

13.2 In the event that any affected personal data has been disclosed to third parties, those
parties shall be informed of any rectification of that personal data.

14 Erasure of Personal Data

14.1 Data subjects may request that MVP erases the personal data it holds about them in the
following circumstances:

a) It is no longer necessary for MVP to hold that personal data with respect to the

purpose for which it was originally collected or processed.

b) The data subject wishes to withdraw their consent to MVP holding and processing
their personal data.

c) The data subject objects to MVP holding and processing their personal data (and
there is no overriding legitimate interest to allow MVP to continue doing so) (see Part
17 of this Policy for further details concerning data subjects’ rights to object).

d) The personal data has been processed unlawfully.

e) The personal data needs to be erased in order for MVP to comply with a particular
legal obligation.

14.2 Unless MVP has reasonable grounds to refuse to erase personal data, all requests for
erasure shall be complied with, and the data subject informed of the erasure, within
one month of receipt of the data subject’s request (this can be extended by up to two
months in the case of complex requests, and in such cases the data subject shall be
informed of the need for the extension).

14.3 In the event that any personal data that is to be erased in response to a data subject
request has been disclosed to third parties, those parties shall be informed of the
erasure (unless it is impossible or would require disproportionate effort to do so).

15 Restriction of Personal Data Processing

15.1 Data subjects may request that MVP ceases processing the personal data it holds about
them. If a data subject makes such a request, MVP shall retain only the amount of
personal data pertaining to that data subject that is necessary to ensure that no further
processing of their personal data takes place.

15.2 In the event that any affected personal data has been disclosed to third parties, those
parties shall be informed of the applicable restrictions on processing it (unless it is
impossible or would require disproportionate effort to do so).

16 Data Portability

16.1 MVP processes personal data using automated means:

a) Athur CRM – Customer Relationship Management system

b) Conjuncto - Customer Relationship Management system

c) We Handle Calls – Telephone call handling system

d) Virtual Landline - Telephone call handling system

e) Wix – Website – Contact Us and/or Request further information Forms

f) Paypal – Receive payment for services

g) Xero – Send Invoices for payment

h) WeTransfer – File transfer system

i) Asana – Project Management System

j) PayProp – Payment Management System

k) DPS – Deposit Protection Scheme

l) FLS Tenant Referencing – Tenant Referencing System

m) Inventory Hive – Property Management System

n) Transfer Wise – Paying Invoices

o) Google Drive – File storage and transfer system

16.2 Where data subjects have given their consent to MVP to process their personal data in
such a manner or the processing is otherwise required for the performance of a
contract between MVP and the data subject, data subjects have the legal right under
the Regulation to receive a copy of their personal data and to use it for other purposes
(namely transmitting it to other data controllers, e.g. other organisations).
16.3 To facilitate the right of data portability, MVP shall make available all applicable
personal data to data subjects in the following format(s):

16.3.1 Exported data in csv file format;
16.3.2 Access to MVP Registration Agreements, Documents & Forms via
upon request, Google Drive shared access to file;
16.3.3 Copies of MVP Registration Agreements, Documents or forms –
Word Document(s) – Email or WeTranser (Data Owner choice).

16.4 Where technically feasible, if requested by a data subject, personal data shall be sent
directly to another data controller.

16.5 All requests for copies of personal data shall be complied with within one month of the
data subject’s request (this can be extended by up to two months in the case of
complex requests in the case of complex or numerous requests, and in such cases the
data subject shall be informed of the need for the extension).

17 Objections to Personal Data Processing

17.1 Data subjects have the right to object to MVP processing their personal data based on
legitimate interests (including profiling), direct marketing (including profiling).

17.2 Where a data subject objects to MVP processing their personal data based on its
legitimate interests, MVP shall cease such processing forthwith, unless it can be
demonstrated that MVP’s legitimate grounds for such processing override the data
subject’s interests, rights and freedoms; or the processing is necessary for the conduct
of legal claims.

17.3 Where a data subject objects to MVP processing their personal data for direct
marketing purposes, MVP shall cease such processing forthwith.

18 Automated Decision-Making

18.1 In the event that MVP uses personal data for the purposes of automated decision and
those decisions have a legal (or similarly significant effect) on data subjects, data
subjects have the right to challenge to such decisions under the Regulation, requesting
human intervention, expressing their own point of view, and obtaining an explanation
of the decision from MVP.

18.2 The right described in Part 18.1 does not apply in the following circumstances:

a) The decision is necessary for the entry into, or performance of, a contract between
MVP and the data subject;

b) The decision is authorised by law; or

c) The data subject has given their explicit consent.

19 Profiling

MVP does not use personal data for profiling purposes. If it did the following would apply:

a) Clear information explaining the profiling will be provided, including its
significance and the likely consequences;

b) Appropriate mathematical or statistical procedures will be used;

c) Technical and organisational measures necessary to minimise the risk of errors and
to enable such errors to be easily corrected shall be implemented; and

d) All personal data processed for profiling purposes shall be secured in order to
prevent discriminatory effects arising out of profiling (see Parts 22 to 28 of this Policy
for more details on data security).

20 Personal Data
The following personal data may be collected, held, and processed by MVP:

21 Marketing Communications

You may receive marketing communications from Us if you have:

Requested information, purchased goods or services from Us. Or
Completed one of Our ‘Contact Us’ forms and ticked the box requesting

information.

Not opted out of receiving marketing from Us.

You can opt–out at anytime by using the ‘Unsubscribe me’ option at the bottom of the email
or by emailing Us at info@millerandvincent.com and typing STOP in the subject line.

22 Data Protection Measures
MVP shall ensure that all its employees, agents, contractors, or other parties working
on its behalf comply with the following when working with personal data:

a) No personal data is to be automatically sent via an email(s) system unless expressly
requested by the data owner.

b) All emails containing personal data must be marked “confidential”;

c) Where any personal data is to be erased or otherwise disposed of for any reason
(including where copies have been made and are no longer needed), it should be
securely deleted and disposed of. Hardcopies should be shredded (in MVP office
before recycling), and electronic copies should be deleted securely using
‘CleanMyMac3’ and ‘HP Secure Erase’ (where held on Director(s) Laptop) or third-
party system deletion.

d) Personal data may be transmitted over secure networks only; transmission over
unsecured networks is not permitted in any circumstances;

e) Personal data may not be transmitted over a wireless network if there is a wired
alternative that is reasonably practicable;

f) Personal data should not be transferred via email, however if this happens, whether
sent or received, it should be copied from the body of that email and stored securely.
The email itself should be deleted. All temporary files associated therewith should
also be deleted ‘CleanMyMac3’ or ‘HP Secure Erase’ (where held on Director(s)
Laptop);

g) Where Personal data is to be sent by facsimile transmission it should be marked as
“confidential”, and the recipient should be informed in advance of the transmission
and should be waiting by the fax machine to receive the data;

h) Where Personal data is to be transferred in hardcopy form it should be marked as
“confidential” and passed directly to the recipient or sent using Royal Mail (receipt
signature required) Postal Service;

i) No personal data may be shared informally and if an employee, agent, sub-contractor,
or other party working on behalf of MVP requires access to any personal data that
they do not already have access to, such access should be formally requested from
Dwayne Squires (Director).

j) All hardcopies of personal data, along with any electronic copies stored on physical,
removable media should be stored securely in either the locked filing cabinet or
locked, fireproof safe.

k) No personal data may be transferred to any employees, agents, contractors, or other
parties, whether such parties are working on behalf of MVP or not, without the
authorisation of Dwayne Squires (Director);

l) Personal data must be handled with care at all times and should not be left
unattended or on view to unauthorised employees, agents, sub-contractors or other
parties at any time;

m) If personal data is being viewed on a computer screen and the computer in question
is to be left unattended for any period of time, the user must lock the computer and
screen before leaving it.

23 Data Security - Storage

MVP shall ensure that the following measures are taken with respect to the storage of
personal data:

a) All electronic copies of personal data should be stored securely using an encrypted
and password protected file on MVP Laptops.

b) All hardcopies of personal data must be stored in the locked filing cabinet in the MVP

office all electronic copies stored on physical, removable media should be stored in
the locked, fireproof safe located in the MVP office.

c) Personal data may be stored on a mobile device which must have a secure password
system in place (including, but not limited to, laptops, tablets and smartphones), for
the purpose of recording a copy of an original document to prove client identification,
home address, proof of funds or proof of source of funds, and within 24 hours
transferred to an encrypted and password protected desktop file and deleted from
the device which captured the image, as well as any ‘back up’ files of data fulfilled in
the time period since the image(s) were captured.

d) No personal data should be transferred to any device personally belonging to an
employee and personal data may only be transferred to devices belonging to agents,
contractors, or other parties working on behalf of MVP where the party in question
has agreed to comply fully with the letter and spirit of this Policy and of the
Regulation (which may include demonstrating to MVP that all suitable technical and
organisational measures have been taken);

e) All passwords used to protect personal data should be changed regularly and should
not use words or phrases that can be easily guessed or otherwise compromised. All
passwords must contain a combination of uppercase and lowercase letters, numbers,
and symbols.

f) Under no circumstances should any passwords be written down or shared between
any employees, agents, contractors, or other parties working on behalf of MVP,
irrespective of seniority or department. If a password is forgotten, it must be reset
using the applicable method. IT staff do not have access to passwords;

g) Where personal data held by MVP is used for marketing purposes, it shall be the
responsibility of Dwayne Squires (Director) to ensure that no data subjects have
added their details to any marketing preference databases including, but not limited
to, the Telephone Preference Service, the Mail Preference Service, the Email
Preference Service, and the Fax Preference Service. Such details should be checked at
least annually.

24 Data Security - Disposal
When any personal data is to be erased or otherwise disposed of for any reason
(including where copies have been made and are no longer needed), it should be
securely deleted and disposed of. For further information on the deletion and disposal
of personal data, please refer to MVP’s Data Retention Policy below.

25 Data Security - Use of Personal Data
MVP shall ensure that the following measures are taken with respect to the use of personal
data:

25.1 No personal data may be shared informally and if an employee, agent, sub-contractor,
or other party working on behalf of MVP requires access to any personal data that they
do not already have access to, such access should be formally requested from Dwayne
Squires (Director) – The Data Protection Officer - Email: info@millerandvincent.com ;

25.2 No personal data may be transferred to any employees, agents, contractors, or other
parties, whether such parties are working on behalf of MVP or not, without the
authorisation of Dwayne Squires (Director) – The Data Protection Officer – Email:
info@millerandvincent.com ;

25.3 Personal data must be handled with care at all times and should not be left unattended
or on view to unauthorised employees, agents, sub-contractors, or other parties at any
time;

25.4 If personal data is being viewed on a computer screen and the computer in question is
to be left unattended for any period of time, the user must lock the computer and
screen before leaving it; and

25.5 Where personal data held by MVP is used for marketing purposes, it shall be the
responsibility of Dwayne Squires (Director) – The Data Protection Officer – Email:
info@millerandvincent.com to ensure that the appropriate consent is obtained and
that no data subjects have opted out, whether directly or via a third-party service such
as the TPS.

26 Data Security - IT Security

MVP shall ensure that the following measures are taken with respect to IT and information
security:

26.1 All passwords used to protect personal data should be changed regularly and should
not use words or phrases that can be easily guessed or otherwise compromised. All
passwords must contain a combination of uppercase and lowercase letters, numbers,
and symbols.

26.2 Under no circumstances should any passwords be written down or shared between
any employees, agents, contractors, or other parties working on behalf of MVP,
irrespective of seniority or department. If a password is forgotten, it must be reset
using the applicable method. IT staff do not have access to passwords.

26.3 All software (including, but not limited to, applications and operating systems) shall be
kept up-to-date. MVP’s Director’s shall be responsible for installing any and all
security-related updates as soon as reasonably and practically possible, unless there
are valid technical reasons not to do so; and

26.4 No software may be installed on any Company-owned computer or device without the
prior approval of the Dwayne Squires (Director) – The Data Protection Officer – Email:
info@millernandvincent.com .

27 Organisational Measures

MVP shall ensure that the following measures are taken with respect to the collection,
holding, and processing of personal data:

a) All employees, agents, contractors, or other parties working on behalf of MVP shall be
made fully aware of both their individual responsibilities and MVP’s responsibilities
under the Regulation and under this Policy, and shall be provided with a copy of this
Policy;

b) Only employees, agents, sub-contractors, or other parties working on behalf of MVP
that need access to, and use of, personal data in order to carry out their assigned
duties correctly shall have access to personal data held by MVP;

c) All employees, agents, contractors, or other parties working on behalf of MVP
handling personal data will be appropriately trained to do so;

d) All employees, agents, contractors, or other parties working on behalf of MVP
handling personal data will be appropriately supervised;

e) Methods of collecting, holding and processing personal data shall be regularly
evaluated and reviewed;

f) The performance of those employees, agents, contractors, or other parties working
on behalf of MVP handling personal data shall be regularly evaluated and reviewed;

g) All employees, agents, contractors, or other parties working on behalf of MVP
handling personal data will be bound to do so in accordance with the principles of the

Regulation and this Policy by contract;

h) All agents, contractors, or other parties working on behalf of MVP handling personal
data must ensure that any and all of their employees who are involved in the
processing of personal data are held to the same conditions as those relevant
employees of MVP arising out of this Policy and the Regulation;

i) Where any agent, contractor or other party working on behalf of MVP handling
personal data fails in their obligations under this Policy that party shall indemnify
and hold harmless MVP against any costs, liability, damages, loss, claims or
proceedings which may arise out of that failure.

28 Transferring Personal Data to a Country Outside the EEA

a) MVP does not transfer any personal data to any country outside the EEA, unless:

b) The transfer is made with the informed consent of the relevant data subject(s);

c) The transfer is necessary for the performance of a contract between the data subject
and MVP (or for pre-contractual steps taken at the request of the data subject);

d) The transfer is necessary for important public interest reasons;

e) The transfer is necessary for the conduct of legal claims;

f) The transfer is necessary to protect the vital interests of the data subject or other
individuals where the data subject is physically or legally unable to give their
consent; or;

g) The transfer is made from a register that, under UK or EU law, is intended to provide
information to the public and which is open for access by the public in general or
otherwise to those who are able to show a legitimate interest in accessing the
register.

29 Data Breach Notification

29.1 All personal data breaches must be reported immediately to MVP’s Data Protection
Officer Dwayne Squires.

29.2 If a personal data breach occurs and that breach is likely to result in a risk to the rights
and freedoms of data subjects (e.g. financial loss, breach of confidentiality,
discrimination, reputational damage, or other significant social or economic damage),
the data protection officer must ensure that the Information Commissioner’s Office is
informed of the breach without delay, and in any event, within 72 hours after having
become aware of it.

29.3 In the event that a personal data breach is likely to result in a high risk to the rights and
freedoms of data subjects, the Data Protection Officer must ensure that all affected data
subjects are informed of the breach directly and without undue delay.

29.4 Data breach notifications shall include the following information:

a) The categories and approximate number of data subjects concerned;

b) The categories and approximate number of personal data records concerned;

c) The name and contact details of MVP’s Data Protection Officer (or other contact point
where more information can be obtained);

d) The likely consequences of the breach;

e) Details of the measures taken, or proposed to be taken, by MVP to address the breach
including, where appropriate, measures to mitigate its possible adverse effects.

30 Third Party Links

Our website may include links to ‘third party websites’, applications or plugins. By clicking
on any of those links you are enabling those connections and that may allow third party
websites to collect data about you.
We do not control those third-party websites and cannot be held responsible for their
privacy policies. We advices that if you leave Our website, that you read privacy notices for
all other websites that you may visit. For more information, please refer to Our Data
Retention Policy section later in this document.

31 Cookies

You are able to set your browser to refuse some or all cookies. You can also set to alert you
when a website sets or adds cookies. If you disable or refuse cookies, some parts of Our
website may become inaccessible or fail to function as meant to. You can gain more
information about cookies at: Wikipedia - Guide - HTTP Cookies . For more information,
please refer to Our Cookie Policy section later in this document.

32 Implementation of Policy

This Policy shall be deemed effective as of 3 rd November 2025. No part of this Policy shall
have retroactive effect and shall thus apply only to matters occurring on or after this date.

This Policy has been approved & authorised by:
Name: S. S. Miller
Position: Director
Date: 3 rd November 2025
Next Review Date: 3 rd November 2026
Signature: S. S Miller