Privacy

Privacy Notice

Bodycote is committed to protecting your privacy. You can read Bodycote’s Privacy Notice here in English and Bodycote local languages.

Website Privacy

The pages on the website (‘the website’) are published by Bodycote plc (’Bodycote plc’).

We will not collect any information about individuals, except where it is specifically and knowingly provided by them.

When you visit our website, our web server collects some basic information such as your internet service provider’s domain name, which pages you accessed on our site, and when.

We use this information only to analyse the use of our website to help guide improvements. We do not collect any personally identifiable information.

Cookies

When you visit our website, we use cookies, which are small pieces of information that allow us to maintain your connection to our website. These cookies do not collect or store any personally identifiable information. You can refuse the use of cookies.

Do Not Track

Bodycote  adhere to the standards set out in this Privacy Notice and does not monitor or respond to Do Not Track browser requests.

Individual users can enable their browsers to send DNT requests in addition to:

• The Network Advertising Initiative offers a central site where you can opt-out of certain kinds of tracking or ad targeting by its members.
• The Digital Advertising Alliance (DAA) provides a consumer opt-out page for the companies participating in their Self-Regulatory Program for Online Behavioural Advertising.

Google Analytics

This website uses Google Analytics, a web analytics service provided by Google, Inc. (‘Google’). Google Analytics uses cookies (text files placed on your computer) to help the website operators analyse how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

Data Collection Policy

In this section you can find out more about:

• the types of personal information we collect
• when we collect personal information
• how we use personal information
• the legal basis for using personal information
• When we collect information

We collect information about you if you:

• invest in our shares or are interested in investing in our shares
• register with or use one of our website(s) or online services
• purchase one of our services
• work with us as a business partner, collectively (“you”)

How Bodycote uses and manages your data

Personal information we collect and use if you invest in our shares or are interested in investing in our shares:

• your identity information and contact information
• your shareholding information

Personal information we collect and use if you use our websites or online services

• your identity information and contact information
• information you input into any forms
• details of your use of the websites and online services

Personal information we collect and use if you purchase one of our services

• your identity information and contact information
• bank account information and credit card information

Personal information we collect and use if you work with us as a business partner

• your identity information and contact information
• bank account information and credit card information

The legal basis for using your personal information

We will only collect, use and share your personal information where we are satisfied that we have an appropriate legalbasis to do th is. This may be because:

• you have provided your consent to us using the personal information
• our use of your personal information is in our legitimate interest as a commercial organisation – in these cases we will look after your information at all times in a way that is proportionate and respects your privacy rights and you have a right to object to processing as explained below
• our use of your personal information is necessary to perform a contract or take steps to enter into a contract with you
• our use of your personal information is necessary to comply with a relevant legal or regulatory obligation that we have

Sharing personal information within Bodycote with our service providers, with our regulators

In this section you can find out more about how we share personal information:

• within Bodycote
• with third parties that help us provide our products and services
• with our regulators

We share your information in the manner and for the purposes described below:

1. within Bodycote, where such disclosure is necessary to provide you with our services or to manage our business
2. with third parties who help manage our business and deliver services. These third parties have agreed to confidentiality restrictions and use any personal information we share with them or which they collect on our behalf solely for the purpose of providing the contracted service to us
3. with credit reference agencies and organisations working to prevent fraud in financial services
4. with our regulators, to comply with all applicable laws, regulations and rules, and requests of law enforcement, regulatory and other governmental agencies we may share in aggregate, statistical form, non-personal information regarding the visitors to our website, traffic patterns, and website usage with our partners, affiliates or advertisers
5. if, in the future, we sell or transfer some or all of our business or assets to a third party, we may disclose information to a potential or actual third party purchaser of our business or assets

Explaining for about processing shareholder personal information

As a Bodycote shareholder, we process your personal information in connection with your shareholding. We hold personal information on registered shareholders, beneficial holders, legal representatives, past shareholders with unclaimed assets and dissentient shareholders.

The basis on which we do so is set out below.

Company secretariat

What processing activities do you undertake that include my personal information?

• We administer and manage your shareholding with the Company and maintain the general records necessary to do so.

This includes the administrative and management activities that we undertake with respect to governance requirements, for example:

• Maintaining statutory registers
• Managing compliance with registrations and government agencies
• Complying with statutory reporting requirements

What categories of personal information are included in these processing activities?

• We process your identity information and contact information and other information which may be required in certain jurisdictions.

What is the reason for these processing activities?

• We use your personal information to manage our relationship with you and to administer your shareholding.

What are the legal grounds you rely on to carry these out?

• This processing is necessary for the compliance with legal obligations to which the Company is subject. This processing is also necessary for the purpose of the legitimate interests pursued by the Company.

What are the ‘legitimate interests’ referred to above?

• The Company considers that it has a legitimate interest in operating its business and managing the information of its shareholders. This includes complying with statutory reporting requirements and compliance obligations for overseas registrations and government agencies.

Who do you share this personal information with?

• Your personal information is shared internally within Bodycote at a senior level. In addition, some of your personal information will be shared externally with company registries (such as Companies House in the UK), legal advisers, auditors, Company Secretarial providers, notaries and as otherwise set out in this Notice.

Share registers

What processing activities do you undertake that include my personal information?

• We administer and manage the Bodycote share register and additional share registers.

What categories of personal information are included in these processing activities?

• We process your identity information and contact information and share information.

What is the reason for these processing activities?

• We use your personal information to manage our relationship with you and to administer your shareholding. We do this to administer the share register effectively and ensure that shareholders receive the benefits and rights that they are legally entitled to.
  In addition, we use this information to respond to queries relating to shareholdings and/or unclaimed assets. Further, we analyse the share register for reporting and other purposes, including AGM attendance and voting.

What are the legal grounds you rely on to carry these out?

• This processing is necessary for the compliance with legal obligations to which the Company is subject. This processing is also necessary for the purpose of the legitimate interests pursued by the Company.

What are the ‘legitimate interests’ referred to above?

• The Company considers that it has a legitimate interest in operating its business and managing the information of its shareholders. This includes complying with statutory reporting requirements and compliance obligations for overseas registrations and government agencies. To the extent that you did not get this personal information from me, how did you collect this information?
• We may receive personal information from share / stock brokers, your agent or representative, share nominees/custodians, share plan administrators/trustees and companies (or their registrars) who are the subject of any takeover/merger and from other sources as set out in this Notice.
• In addition, we may also gather some personal information from publicly available sources.

Who do you share this personal information with?

• Your personal information is shared internally, as set out in this Notice.

In addition, some of your personal information will be shared externally with the Share Registrar, Equiniti (see https://privacy.equiniti.com for details of Equiniti’s own Privacy Statement applicable to the information they hold), with companyregistr ies (such as Companies House in the UK), analysts, legal advisers, auditors, Company Secretarial providers, notaries, asset tracing companies, print and mail house, and as otherwise set out in this Notice.

Explaining more about direct marketing and profiling

In this section you can find out more about:

• how we use personal information to keep you up to date with our products and services
• how you can manage your marketing preferences
• when and how we undertake profiling and analytics
• How we use personal information to keep you up to date with our services

We may use personal information to let you know about Bodycote services that we believe will be of interest to you. We may contact you by email, post, or telephone or through other communication channels that we think you may find helpful. In all cases, we will respect your preferences for how you would like us to manage marketing activity with you.

How you can manage your marketing preferences

To protect privacy rights and to ensure you have control over how we manage marketing with you:

• we will take steps to limit direct marketing to a reasonable and proportionate level and only send you communications which we believe may be of interest or relevance to you.
• you can ask us to stop direct marketing at any time.
• you can change the way your browser manages cookies, which may be used to deliver online advertising.

How to refuse the use of cookies

You may refuse the use of cookies by selecting the appropriate settings in your browser. However, if you do this you may lose some useful functionality such as personalisation and ‘keep me signed in’ and ‘remember me’ features.

How to disable cookies in your browser

Contact our privacy policy Officer(s)

The primary point of contact for all issues arising from this privacy notice, is our Group Data Protection Officer. The Group Data Protection Officer can be contacted in the following ways:

• [email protected]
• c/o Bodycote plc, Springwood Court, Springwood Close, Tytherington Business Park, Macclesfield, Cheshire SK10 2XF

If you have any questions, concerns or complaints regarding our compliance with this notice and the data protection laws, or if you wish to exercise your rights, we encourage you to first contact our Group Data Protection Officer or us. We will investigate and attempt to resolve complaints and disputes and will make every reasonable effort to honour your wish to exercise your rights as quickly as possible and in any event, within the timescales provided by data protection laws.

Children’s Online Privacy Protection

The Bodycote website is not aimed at and does not collect information from children.

Changes to our Privacy Policy

We may amend this notice from time to time to keep it up to date with legal requirements and the way we operate our business. Please regularly check www.bodycote.com for the latest version of this notice. You might find external links to third party websites on our website. This privacy notice does not apply to your use of a third party site.

Bodycote’s full website privacy notice is available for download in multiple languages