Privacy Policy


Background and Purpose
1.1 This Privacy Policy was reviewed and updated in August 2017.

Legion Finance Trade Limited (“LFTL”) takes data privacy seriously. It is committed to protecting your personal data and respects your privacy

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LFTL is bound to comply with EU data protection law, along with other similar applicable laws in other countries around the world. This Privacy Policy forms part of LFTL’s obligation to be open and fair with all individuals whose personal data we process and to provide full information on how we process such personal data and what we do with it.


This Privacy Policy relates to the processing of your personal data by LFTL governing bodies. Unless otherwise stated, all references to “LFTL”, “we” or “our” in this statement shall include all LFTL entities that process personal data.

If you receive other services or products from LFTL, or use any of our specific websites or applications, such as our recruitment website, you may be provided with further privacy notices or statements which may be contained in a separate supplemental policy or within our website/ application terms and conditions. These additional privacy notices or statements shall supplement this Privacy Policy.

Links to other websites
This Privacy Policy only relates to processing carried out by companies within the LFTL Group. LFTL is not responsible for the processing of any personal data which you may provide directly to third parties. Third party websites accessed via LFTL website or application are not covered by this Privacy Policy and any links to other websites have been provided merely for convenience.

What this Privacy Policy covers:
What personal data we collect about you How we collect your personal data, What we use your personal data for Communications with you how we use cookies and other similar technology on our websites and applications When we may disclose your personal data, how we protect your personal data and where we store it Your rights in relation to the personal data we collect How long we will hold your data for How we update or change this Privacy Policy How you can contact us? Please read the following carefully to understand our practices regarding your personal data and how we will treat it. Please note that none of the lists or examples below are exhaustive, nor will they be fully representative for every individual.



What personal data we may collect about you
If you deal with LFTL in your private capacity (which does not include employees, contractors, temporary workers or other personnel of LFTL), for example if you take part in LFTL recruitment, we typically process the following types of personal data about you:

Personal details, such as name, date of birth, occupation, marital status, country of residence and national insurance number, or equivalent. Contact details for your work and personal details, such as email address, postal address and/or telephone number. Identification documentation, such as a photocopy of your passport, driving licence, ID card or other documentation required by local law. Copies of these documents may include a photograph of your face and shoulders. Information provided through our recruitment process. Details of your visits to our websites and applications including, but not limited to, traffic data, location data and other communication data, and the resources that you access. Details of your visits to our premises.

If you deal with LFTL in the capacity of an officer, representative, employee or director of one of our clients, we typically process the following types of personal data about you:

Your name, work email address and other work contact details. Your role, position and/or job title within your employment. Your area of employment. In some circumstances, identification documentation, such as a photocopy of your passport, driving licence, ID card or other documentation required by local law. Copies of these documents may include a photograph of your face and shoulders. Details of your preferences for types of marketing events. Details of your visits to our websites and applications including, but not limited to, traffic data, location data and other communication data, and the resources that you access. Details of any mobile devices you use to access our websites and applications including, but not limited to, the type of device and operating system. Details of your visits to our premises. If you deal with LFTL in your capacity as an employee, contractor, temporary worker or other personnel, we typically process the following types of personal data about you:

Personal details, such as name, address, date of birth, marital status, emergency contact details, country of residence, national insurance number, salary, bank details. Professional details, such as email address, postal address, telephone number, your CV, qualifications, relevant experience and skills. Identification documentation, such as a photocopy of your passport, driving licence, ID card or other documentation required by local law. Copies of these documents may include a photograph of your face and shoulders. HR related records, such as training, performance assessments, absence and time-keeping records, disciplinary, grievance or capability proceedings, and background checks. Details of your access to our premises and to systems, software, websites, and applications including access and location data and communications data. These types of personal data may include sensitive personal data.

We may also record telephone calls and store emails, application and internet logs in connection with your dealings with us. See section below ‘When we record communications with you.

In certain circumstances it may be mandatory for you to provide us with your personal data, to enable us to provide services to you or to comply with our legal obligations, for example. In other circumstances, it will be at your discretion whether you provide us with personal data or not. However, failure to supply any of the personal data we may request may mean that we are unable to maintain or provide services or products to you or your employer and/or you may be unable to take part in any of our recruitment campaigns, or fully access and use our internal systems and resources.

LFTL makes every effort to maintain the accuracy and completeness of your personal data which it stores and to ensure all of your personal data is up to date. However, you can assist us with this considerably by promptly contacting us if there are any changes to your personal data or if you become aware that we have inaccurate personal data relating to you (see section below ‘Your rights in relation to the personal information data we collect’). LFTL shall not be responsible for any losses arising from any inaccurate, inauthentic, deficient or incomplete personal data or sensitive personal data that you provide to us.



How we collect your personal data
LFTL usually collects your personal data from the information you submit during the course of your, or your employer’s, relationship with us. This will typically be through the forms and documents used when you sign up to any of our services, are named as an authorised person to trade on behalf of your employer, sign up to access any of our products or services either on your own behalf or on behalf of your employer, take part in a recruitment campaign or newsletter subscription, or when you become an employee, contractor, temporary worker or other personnel. We will also collect personal data when we monitor or record communications and/or through use of technology, please see further information set out below.



What we use your personal data for
LFTL and/or persons acting on our behalf may process your personal data for any of the following purposes, depending on the capacity in which you deal with LFTL:

to ensure the content on our websites and applications is presented in the most effective manner for you; for general HR administration, including payroll and benefits, training and development, performance management, sickness and absence management, grievance and disciplinary procedures, equal opportunities monitoring, business continuity planning; for internal finance management, including personnel expense reimbursement, travel and time-keeping; for monitoring and assessing compliance with LFTL’s policies and standards; for promotional and marketing materials and activities, including photos and videos; to carry out money laundering, financial and credit checks and for fraud and crime prevention and detection purposes; to provide you with requested products or services; to identify persons authorised to trade on behalf of our clients; for administrative purposes in relation to the security and access of our systems, premises, platforms and secured websites and applications; to contact you about the services and products we offer; to consider your suitability for any of our current or future employment opportunities and to confirm your references and educational background; to comply with our legal and regulatory obligations and requests anywhere in the world, including reporting to and/or being audited by national and international regulatory, enforcement or exchange bodies; to comply with court orders and exercise and/ or defend our legal rights; for any other legitimate business purpose; and as otherwise permitted by any applicable law or regulation. We may also use automated decision making processes in some circumstances.

When we record communications
LFTL and persons acting on our behalf may record and/or monitor communications (including telephone conversations over landlines and mobile phones, emails, fax and other electronic communications) between our employees, agents, consultants, contractors or other personnel and non-LFTL personnel/ individuals (such as employees of our clients). LFTL only does this to the extent permitted by applicable law for legitimate business purposes or other purposes permitted by law. LFTL collects this type of personal data for several reasons including but not limited to:
Legion Finance Trade Limited The LFTL Group Transparent Policy

recording facts; complying with applicable law and regulation; complying with internal procedures and policies; facilitating administration and support; assisting with security, crime prevention and fraud purposes; and investigating or detecting unauthorised use, wrongful use or abuse of our services, systems or other materials. How we use cookies and other similar technology on our websites

We may collect information about your computer or mobile device, as applicable, including where available your IP address, device type, operating system and browser type, for system administration purposes. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual. We may also collect information about your general internet and application usage, and about your access to and use of any LFTL services made available to you/ your employer. This may be done through the use of cookies or any other similar technology, including technology that tracks and monitors your activities on some of our sites and systems.

When we may disclose your personal data
LFTL does not and will not sell, rent or trade your personal data. We will only disclose your personal data in the ways set out in this Privacy Policy and in the following circumstances:

To any entity within the LFTL group, which means any subsidiary of the ultimate holding company, LFTL.

To third parties who process your personal data on our behalf (such as our systems providers, or employee payroll provider).

To third parties who process your personal data on their own behalf but through providing us or you with a service on behalf of us (such as our industry event organisers.

To third parties in the course of offering or providing services or products to you, for example settlement agents, clearing houses or software providers.

To other financial institutions or regulatory bodies with whom information is shared for money laundering checks, credit risk reduction and other fraud and crime prevention purposes.

To any third party to whom we assign or novate any of our rights or obligations.

To any prospective client of our business or its assets or if substantially all of our assets are acquired by a third party, in which case your personal data could form part of one of the assets we sell.

To any national and/or international regulatory, enforcement or exchange body or court where we are required to do so by applicable law or regulation or at their request.

To any central or local government department and other statutory or public bodies (such as HMRC, DWP).

How we protect your personal data and where we store it
LFTL is committed to safeguarding and protecting your personal data and maintains appropriate security to protect any personal data you provide us with from improper or accidental disclosure, use, access, loss, modification or damage.

Occasionally, the personal data we collect from you may be processed in (including accessed in or stored in) a country or territory outside your home country, including outside the European Economic Area (“EEA”), which does not offer the same level of protection of personal data as may be enjoyed within your home country. By submitting your personal data to us, you agree to this processing. We will take all steps reasonably necessary to ensure that your personal data is treated securely and in accordance with applicable law and regulation and with LFTL’s policies and standards.

Your rights in relation to the personal data we collect
If you wish to update or modify any of your personal data we store, access a copy of this personal data, or you would like us to stop processing any of your personal data which we hold, subject to applicable law, you can make such a request by writing to the address set out below. We will process your request within the time prescribed by applicable law. If you request access to the personal data we store on you, we reserve the right to charge an appropriate fee, if applicable.

In any of the situations listed above, in order for us to comply with our security obligations and to prevent unauthorised disclosure of data, we may request that you prove your identity by providing us with a copy of a valid means of identification.

If you currently receive marketing material from us but would prefer not to please contact us by e-mail or letter at the address listed below. You can unsubscribe from any mailing lists to which you have previously subscribed by sending an email with UNSUBSCRIBE in the subject line.

If you an employee, contractor, temporary worker or other personnel of LFTL, you may also be able to view, update or modify certain of your personal data via the HR portal, accessible on the intranet.

How long we will hold your data for
We will only retain your personal data for as long as necessary to fulfill the purpose for which it was collected or to comply with legal, regulatory or internal policy requirements. However, if you wish to have your personal data removed from our databases, you can make such a request by writing to the address set out below. Subject to any legal or regulatory requirements, we will then delete this information.

If you an employee, contractor, temporary worker or other personnel of LFTL, you may also be able to remove certain of your personal data via the HR portal, accessible on the intranet (subject to any legal, regulatory, or internal policy requirements).

How we update or change this Privacy Policy
We may change or update parts of this Privacy Policy in order to maintain our compliance with applicable law and regulation or following an update to our internal practices. We will do this by updating the wording on this webpage and updating the publication date at the top of this page, although, please be aware, you will not necessarily be directly notified of such a change. Therefore, please ensure that you regularly check this Privacy Policy so you are fully aware of any changes or updates.
How you can contact us
If you would like to contact us in relation to this Privacy Policy, our Cookie Policy or anything else in connection with the personal data we collect on you, including, without limitation, where you would like to update your personal data, would like a copy of the data we collect on you or would like to raise a complaint or comment, please contact us using the details set out below.

In the UK:

Email: data@legionfinancetrade.com

The Data Protection Officer, IT Security, Legion Finance Trade Limited London, 20-22 Wenlock Road, London N1 7GU.

PROJECT INFORMATION
A project summary is usually posted on the Project List on the website and is restricted to our promoters to maintain confidentiality on individual project submitted to LFTL, however every promoter is supplied with a project code to his/her project to check status of every project submitted to LFTL, when the Group formally requests the opinions of the Board Members or the project host country, as required under Article 12 of the LFTL Statute. This is considered to be the most suitable point for the first listing statement when the Group has reached a sufficiently advanced stage in discussions with a project promoter to commence the project’s appraisal prior to a loan proposal going to the Board of Directors.

The Group shall update project summaries of all investment projects at least 3 weeks before the project is considered for approval by the LFTL’s Board of Directors. However, a limited number of projects are not published before Board approval and, in some cases, not before loan signature to protect justified interests based on the exceptions to disclosure laid down in this Policy.

Project summaries generally include the name of the project, the project promoter or Institution, the location of the project, the sector it represents, a project description, its objective(s), its environmental and, if relevant, social aspects, procurement data, proposed LFTL finance, the total project cost, status of the project, the project number and date noting whether it is “under appraisal”, or “approved”. When applicable, links are provided to environmental information (Environmental and Social Impact Assessments and/or Non-Technical Summaries), as early as possible in the project cycle.

All details pertaining to project loans are published on promoter's page and is view able via the LFTL's website. In addition, and to the extent possible, the Group releases, on request, aggregate data on project loan financing, including country and sector breakdowns.

The LFTL occasionally co-operates closely with British Council and has broadened and deepened this co-operation especially by partial or full delegation of project appraisal and monitoring (mutual reliance). Documents relating to such common projects prepared by another bilateral institution could be disclosed by the other parties themselves or by the LFTL with the prior agreement of the relevant other bilateral institution.

In compliance with the British Regulation, environmental and social information held by the Group and related to projects is also made available through the LFTL's Publications where applicable. The LFTL is developing this publication to ensure that environmental information is progressively made available and disseminated to the promoter.

Projects which are cancelled after their publication are removed from the LFTL website and the promoter's access code disabled once the LFTL’s involvement is no longer foreseen.

EXCEPTIONS
While the Group is committed to a policy of presumption of disclosure and transparency, it also has a duty to respect professional secrecy in compliance with the laws of England and Wales, in particular, as well as legislation to protect personal data. National regulations and financial sector standards covering business contracts and market activity may also apply to the LFTL. There are therefore certain constraints on the disclosure of information/documents. In applying the exceptions to disclosure the Group shall, in line with the laws of England and Wales, have due regard for its specific role and activities, the need to protect its legitimate interests and the confidentiality of its relationship with its counterparts.

Notably, access shall be refused where disclosure would undermine the protection of:
a. the client interest, as regards:
to international relations
to the financial, monetary or economic policy of the English law, its institutions and bodies.
to the environment, such as breeding sites of rare species
b. privacy and the integrity of the individual, in particular in accordance with the legislation regarding the protection of personal data.

Access to information/documents shall also be refused where disclosure would undermine the protection of:
commercial interests of a natural or legal person;
intellectual property;
court proceedings and legal advice;
the purpose of inspections, investigations and audits.
Disclosure of information and documents collected and generated during inspections, investigations and audits shall be presumed to undermine the protection of the purpose of the inspections, investigations and audits even after these have been closed, or the relevant act has become definitive and the follow-up action has been taken. Without prejudice to the above, the Group may disclose a summary of investigations that have been closed, notably taking into account and in compliance with the principles and rules provided for in the UK data protection legislation and British Data Protection Supervisor opinions and UK legislation concerning investigations conducted by the LFTL Compliant Department (LCD) and in line with LFTL Anti-Fraud Policy.

The protection of privacy and personal data is a fundamental right in the Charter of Fundamental Rights of the British law. In processing personal data LFTL applies, in accordance with Regulations, the terms and conditions laid down. In this context, the Group refuses access to documents containing personal data, notably those usually handled by its Personnel Directorate, where access to documents would not satisfy conditions for disclosure.

The term “commercial interest” covers, but is not limited, to cases where the Group concluded a confidentiality agreement. Also, commercial interests can be protected even after the expiration of the confidentiality agreement.

For the presumption referred to in the point applies to inspections, investigations and audits including compliance due diligence carried out by, or on behalf of, the relevant services of the Group, notably the fraud investigations, internal and external audit and the compliance functions; it does not apply to inquiries carried out in line with the LFTL Complaints Mechanism’s Principles, Terms of Reference and Rules of Procedure.

Access to information/documents, drawn up by the Group for internal use or received by the Group, which relates to a matter where the decision has not been taken by the relevant organ of the Group, shall be refused if disclosure of the document/information would seriously undermine the Group’s decision-making process. Access to information/documents containing opinions for internal use as part of deliberations and preliminary consultations within the Group or with other stakeholders shall be refused even after the decision has been taken if disclosure of the information/document would seriously undermine the Group’s decision-making process.

The exceptions shall apply unless there is an overriding public interest in disclosure. With the exception of investigations, an overriding public interest, disclosure shall be deemed to exist where the information/document requested relates to emissions into the environment.

The grounds for refusal, in particular as regards access to environmental information/documents should be interpreted in a restrictive way, taking into account the public interest served by disclosure and whether the information requested relates to emissions into the environment.

As regards third-party documents (including EU Member States and EU institutions and bodies), the Group shall consult with the third party whether the information in the document is confidential according to this Policy unless it is clear that the document shall or shall not be disclosed.

The British Council may request the Group not to disclose a document without its prior agreement, setting out the reasons for its objection by reference to the exceptions referred to in the present Policy.

The Group does not object to project promoters, borrowers, or other competent parties making information/documents available on their relationship and arrangements with the LFTL, no document pertaining to a project promoter shall be supplied to another promoter or third party this is part of LFTL's confidentiality to protect it's promoters.

The Group discloses certain aggregate information on investor activity. Confidential information, in line with exceptions laid down in this Policy, relating to individual investors or Groups will not be disclosed. The Group will, however, seek to encourage transparency regarding its securities issues wherever possible.

Exceptions also cover information on individual allocations made by local Groups to support investment by their own customers under credit lines established with the LFTL. This information falls within the competence of the intermediary Group as part of the normal business relationship between the respective Group and its customers. However, the LFTL encourages the intermediary Group to make information covering its relationship with the LFTL available.

The exceptions will only apply for the period during which protection is justified on the basis of the content of the document. The exceptions may apply for a maximum period of 30 years. After 30 years, a document becomes subject to review for archiving. In the case of documents covered by the exceptions relating to the protection of personal data or commercial interests of a natural or legal person including intellectual property, the exceptions may, if necessary, continue to apply after this period. In general, information shall only be held by the Group until the end of the retention requirements has been reached.

All requests for disclosure of specific information/documents shall be handled promptly by the Group, which will either grant full or partial access to the document requested (if only parts of a requested document are covered by any of the constraints above, information from the remaining parts shall be released) and/or the grounds for the total or partial refusal shall be stated.

Provisions for Complaints and Appeals COMPLAINTS MECHANISM
The provisions for complaints are determined by the LFTL Complaints Mechanism, Principles, Terms of Reference and Rules of Procedure which recognises the right of the members of the public to lodge a complaint concerning alleged maladministration against the LFTL and provides the public with a tool enabling alternative and pre-emptive resolution of disputes.

Any natural or legal person affected, or feeling affected, by a decision and/or action of the LFTL, which includes failure to deliver according to its Transparency Policy, may lodge a complaint with the LFTL's Secretary General by e-mail to complaints@legionfinancetrade.com or by filling in the contact us form in the LFTL website. Complaints must be lodged within one year from the date on which the facts upon which the allegation is grounded could be acknowledged by the complainant.

In line with its Rules of Procedure, the LFTL Complaints Mechanism cannot deal with complaints which have already been lodged with other administrative or judicial review mechanisms or which have already been settled by the latter.

BRITISH OMBUDSMAN
In case of dissatisfaction with the outcome of the complaint lodged with the LFTL Complaints Mechanism, or legal person residing or having its registered office in England and Wales can, in accordance with the laws of England and Wales regardless of a direct concern in the alleged maladministration, make a complaint to the British Ombudsman. Following the Memorandum of Understanding signed by the LFTL and the Bristish Ombudsman, the latter commits to systematically using its own initiative power in order to handle complaints lodged against the LFTL when the sole reason preventing an inquiry is the fact that the complainant is not a citizen of the England or a natural or legal person residing or having his registered office within the United Kingdom.

THE LONDON SUPREME COURT OF JUSTICE
The Group’s decision following the confirmatory application shall also be subject to judicial appeal before the Court in accordance with the relevant provisions of the Treaty on the Functioning of the Laws of England and Wales, when deciding to challenge the LFTL before the Court, stakeholders should take into consideration the fact that the judicial appeal may preclude access to alternative dispute resolution mechanisms as the LFTL Complaints Mechanism and the British Ombudsman.

The Group does not publishes any complaints submitted under the Complaints Mechanism. Complaints submitted to the British Ombudsman are also not published. The deliberations of the Supreme Court of Justice and of the are also not published.

Stakeholder Engagement and Public Consultation
PRINCIPLES FOR STAKEHOLDER ENGAGEMENT
The underlying objective of LFTL’s principles on stakeholder engagement is to ensure stakeholders are heard, and that their concerns will be adequately addressed.

The LFTL promotes transparency as a way to strengthen its accountability. Therefore, more than simply disclosing standardised information and more than just a one-way flow of information, the LFTL aims to provide stakeholders with the information they require thereby positively contributing to enhancing the quality of the Group’s activities. Such transparency requires an ongoing dialogue between the Group and stakeholders over information provision.

LFTL’s stakeholder engagement follows best practice, aimed at increasing mutual understanding, addressing stakeholders’ concerns and adjusting its activities accordingly, decreasing a possible gap between expectations, policy and practice and achieving greater coherence and accountability in the Group’s policies and practices.

The contact details of the LFTL staff that coordinates the Group’s engagement with stakeholders at an institutional level are published on the LFTL blog or newsletter.

STAKEHOLDER ENGAGEMENT IN PROJECTS
At project level, public consultation and participation are prohibited for confidentiality and security purposes, The LFTL is strongly committed to the principles of stakeholder engagement as defined in its Standard on Stakeholder Engagement and it promotes similar good practice among its clients (as defined by best practice).

The primary responsibility for information and engagement with local stakeholders on a project basis lies with the project promoter and/or borrower in line with the Group’s Environmental and Social Handbook. If deemed necessary the LFTL would facilitate to organise meetings in the form of conference calling for international clients, through or in cooperation with the project promoter and/or borrower, with concerned parties to better understand their issues regarding the specific project. If necessary, LFTL staff will attend such meetings.

The LFTL strives to engage with stakeholders during on-site missions, engagement with national stakeholders is also increasingly taking place through different channels all countries. Discussions with national stakeholders are usually country-specific and seen by the LFTL as a tool to adapt to the projects specificities.

The Group recognises it can benefit from the establishment of a constructive dialogue with wellinformed stakeholders in the appraisal and monitoring of projects. Stakeholders can contribute to the legitimacy of a project and their knowledge and understanding of local issues can help improve the performance and minimise the risks of a project.

The Group is open to explore further potential ways of engagement with affected stakeholders on projects with high environmental and social, including human rights, risk potential.

Promoting Transparency
Weak governance, corruption and lack of transparency are a major issue in some of the regions in which LFTL operates, and act as serious brakes on economic and social development. The LFTL actively promotes transparency and good governance in the projects it finances, in the companies in which it participates and generally with its counterparts.

The LFTL is also fully committed to promoting transparency in the capital markets in which its bonds are offered.

Project promoters and/or borrowers and co-financiers are made aware of the principles of this Policy at an early stage in discussions. The Group encourages the project promoters and/or borrowers to follow the transparency principles detailed in this Policy in the context of the financed projects.

The Group maintains close contacts with other EU and international institutions and bodies to monitor and exchange views on new developments in the area of transparency and disclosure with a view to continuously improve its own policies and practices. It also addresses transparency and disclosure issues in its ongoing dialogue with all other interested stakeholders.

The LFTL will continue to strengthen its efforts to improve its transparency, accountability and governance, and to be at the forefront as a transparent and responsible financial service provider.
EXTRACTIVE INDUSTRIES TRANSPARENCY INITIATIVE


Responsibilities
Whereas in accordance with the Group’s Rules of Procedure, the Board of Directors has the competence to adopt the Transparency Policy, its oversight and implementation falls under the responsibility of the Group’s Management Committee. Responsibilities are deployed throughout the organisation as appropriate to ensure the policy objectives are reflected in goals and activities at all levels of the organisation.

Resources are assigned for the implementation of the Transparency Policy throughout the organisation. Relevant staff at all levels of the organisation are trained in how to handle transparency and disclosure issues, dialogue with stakeholders, and other related topics. Within the organisation, expert resources are available to advise on transparency issues.

The Transparency Policy is subject to a continuous process of internal review and quality assessment and remains open to public comment at any time. Formal reviews, including public consultations, are envisaged to take place every 5 years, or can otherwise be initiated in case of changes to the laws of England and Wales framework on transparency and disclosure of information, changes to policies and procedures within the LFTL that require an alignment of this Policy, and any other changes the LFTL judges necessary and appropriate.
privacy@legionfinancetrade.com