UNICAPITAL GROUP

DATA PROTECTION OFFICE

 

MESSAGE AND COMMUNICATION POLICY

I. Scope

This Policy governs the creation, sending, transmittal, receipt, access, use, processing, and storage of documents, instruments, files and data in any form or medium containing personal or confidential information (the “Private Information“) directly or indirectly by, originating from, pertaining to, under the possession of, owned by, or related to Unicapital, Inc., Unicapital Finance and Investments, Inc., Unicapital Securities, Inc., and their respective departments, personnel and representatives (the “Unicapital”). Examples are Private Information in messages and communications in emails, postal mail, meetings, telephone conversation, and video conference.

II. Personal and Confidential Information

Information is “personal” when it is defined by the Data Privacy Act of 2012 as personal information, sensitive personal information, or privileged information. This includes all information which can singly or cumulatively identify, discriminate, or damage clients, potential clients, counterparties, potential counterparties, shareholders, directors, officers, employees, contractors, agents and applicants, and other individuals with a legal or business relationship with Unicapital Group. Examples of personal information are name, signature and images of an individual. Examples of sensitive personal information are health information, educational information, political affiliations, social security number, and tax identification number of an individual.

Information is “confidential” when it is generally non-public data or information by, originating from, pertaining to, under the possession of, owned by, or related to Unicapital Group and its officers, employees, agents and representatives. This includes any part in any stage of market or business research, including processed or unprocessed data forming part of, related to, or arising from to such market or business research. Examples of confidential information are non-public business strategies, trade secrets, intellectual properties, financial information, and client lists.

“Messages and communications” are printed and electronic correspondences, regardless of the sender and recipient. Examples are letters, memorandums, notices, statements and vouchers transmitted physically or electronically.

III. Protection of Private Information

Private Information contained in or referenced by messages and communications are strictly confidential and exclusively for the intended recipient/s only.

All individuals, entities and parties accessing, possessing, or using the Private Information shall implement organizational, physical, and technical security measures for the privacy and protection of the Private Information as appropriate under the circumstances which shall not fall below regulatory and industry standards.

IV. Correspondences

No part of messages and communications containing or referencing Private Information may be reproduced, transmitted, or exhibited in any form or manner without the concurrent express written consents of the sender and Unicapital. The consent of Unicapital is not a substitute to the consents of the data subject, intellectual property owner, or the original source of the Information. Creation, access to, or receipt of messages and communications from Unicapital subjects the person, entity or party to this Policy and relevant data privacy regulations.

Printed and electronic messages and communications containing or referencing Private Information are required to state the following Privacy and Confidentiality Notice:

Privacy and Confidentiality

“This message, its thread, and any attachments are private and confidential. Except for the legitimate purpose of this message, no part of this message or identity of a person may be disclosed, reproduced or exhibited in any form or manner without the consent of the sender. In case of wrongful receipt of or unauthorized access to this message, please immediately inform the sender and permanently delete all wrongfully received copies. Your access to this information is merely permitted by the Unicapital Group which shall not be liable for claims, damages, and expenses directly or indirectly arising from or related to any part of this information, its use, or its processing.”

On a case-to-case basis, exemptions or modifications to the Privacy and Confidentiality Notice must be justified to and approved by the Unicapital Group Data Protection Officer.

All electronic and hard copies of messages and communications containing or referencing Private Information which are wrongfully received or accessed without authority should be permanently deleted and disposed of. Unicapital and the sender of the Private Information wrongfully received or accessed without authority should immediately be informed.

In case of doubt, it should be presumed that the privacy and confidentiality of data and information should be kept private and protected.

CCTV PRIVACY NOTICE

 

CCTV Privacy Notice

For security purposes, this building and its surrounding premises are monitored by Closed Circuit Television (CCTV) cameras which capture, record for thirty (30) days, and share to relevant parties footages which determine your identity, actions, and whereabouts. Your footage may be recorded for a longer duration and processed in other means if it involved in or of use to a security matter.

By entering these premises, you consent to the capture, recoding, processing, and sharing of all information directly and indirectly obtained by CCTV cameras.

All receiving areas where visitors log their information with a security guard or receptionist, the following Consent Notice must be posted near or on the logbook or e-logbook:

CCTV Consent Notice

By indicating your details in this logbook or by entering these premises, you undertake to have read, understood, and consented to our CCTV Privacy Notice.