Updated: May 2018

Sapphire Systems Privacy Policy

1. Privacy Policy

Sapphire Systems (hereinafter "Sapphire" or "us" or "we") is committed to

respecting your privacy and is compliant with all data protection and privacy laws
governing the UK and Europe. Sapphire's Privacy Policy Statement is designed to
help you understand how we collect, use and protect your information when you
visit our website and when you generally request information on our products and
services – whether in person, via email, post, telephone or fax.

2. Collection of Personal Information

Sapphire endeavour to collect and use your personal information only with your
knowledge and consent. The use of this information is typically done when you
place an order, use Sapphire's products and services, make customer enquiries,
register and request product information, submit a job application or when you
respond to communications from us (such as questionnaires or surveys). The
personal information that we typically collect includes - your name, business and
email address, telephone and fax numbers, and any other relevant information
that is required and collected via requests, registrations or through surveys. On
occasions, Sapphire may also purchase mailing lists for the purposes of direct
marketing. However, we will only do this from an authorised and registered
provider that maintains a comprehensive Privacy Policy which safeguards your
rights as an individual. Once we obtain your data, it is processed and recorded on
secure databases, which are only accessible by authorised Sapphire personnel.

2.1. Cookies
Our website uses cookies. Cookies identify your computer or device rather than
you as an individual user and are used for different purposes. To read more about
which cookies we use and for their purpose, see below (Cookies 6.0).

2.2. IP address, browser settings and location

When you visit the website, we register your computer’s IP address and browser
settings. The IP address is the numerical address of the computer used to visit our
website. Browser settings can include the type of browser you use, browser
language and time zone. We collect this information so that we can trace the
computer used in cases of misuse or unlawful actions in connection with visits to
or use of the website. We also use the IP address to approximate your location by
the city.

2.3. We process personal information in order to:

 Perform a contract (see Article 6.1.b of the GDPR)

Sapphire Systems Ltd, The Shard, 32 London Bridge Street, London, SE1 9SG | +44 (0) 20 7648 2000
Registered Office: 843 Finchley Road, London NW11 8NA | Registered in England Number: 02777799 | VAT No: 597 4420 07
  Comply with our legal obligations (see Article 6.1.c of the GDPR)
 Pursue legitimate business interests of our own related to operating the
website and providing our services, or to pursue the legitimate interests of
third parties as long as your interests and fundamental rights do not
override those interests (see Article 6.1.f of the GDPR).

3. Use of Information
Sapphire may use this information for processing your orders; delivering services,
products or information; responding to complaints or account enquiries. Sapphire
may also undertake analysis based on past requests or your use of our services and
products to contact you with information on new developments, products,
services and special offers via post, telephone and other electronic means such as
email and on the Sapphire website (subject always to any preferences expressed
by you).

4. Disclosure of Information
Sapphire does not rent, sell, trade or otherwise share your information with any
third-party organisations. We may in future decide to tell you about the products
and services of carefully selected third parties and allow you to receive advertising
and marketing information from those selected third parties but we will not pass
control of your personal information to any third parties. This data is used to help
us to make you aware of products and services that we have specially sourced for
our customers and which we feel are of interest to you.
We may disclose information about you
a) to companies and departments within the Sapphire organisation, subject to
the terms of this Privacy Policy Statement; and
b) in the event that we undergo re-organisation or are sold to a third party, in
which case you agree that any personal information we hold about you may
be transferred to that re-organised company or third party for the purposes
described herein and subject always to the terms and guidelines of this
Privacy Policy Statement.

We may release information when Sapphire believes, in good faith, that such
release is legitimately necessary to
a) comply with the law,
b) enforce or apply the terms of any of our user agreements or
c) protect the rights, property or safety of Sapphire, our visitors, or others.
Sapphire may also be obliged to disclose your personal information to meet
any legal or regulatory requirements or obligations in accordance with
applicable law.

5. Other Websites & Privacy Concerns

Sapphire's website may contain links to other company and organisational
websites that are not owned or operated by us. We are not responsible for the

Sapphire Systems Ltd, The Shard, 32 London Bridge Street, London, SE1 9SG | +44 (0) 20 7648 2000
Registered Office: 843 Finchley Road, London NW11 8NA | Registered in England Number: 02777799 | VAT No: 597 4420 07
 privacy practices or the content of such websites. For more information on your
privacy rights with regards to these sites, please refer to the privacy policies of each
respective site that you visit.

6. Cookies
The Website uses cookies and similar technologies (“Cookies”). By using our
Website, you accept that we use Cookies as described below.

6.1. What types of Cookies do we use?

Cookies are small pieces of information that the Website places on your
computer's hard disk, on your tablet or on your smartphone. Note that HTML5
introduced Web Storage that has a similar nature to Cookies, and that we,
therefore, consider that as a Cookie in the following.

Cookies contain information that the Website uses to make the communication
between you and your web browser more efficient. Cookies identify your computer
or device rather than you as an individual user.

We use session cookies, persistent cookies, HTML5 sessionStorage and HTML5

localStorage session cookies and HTML5 sessionStorage objects are temporary in
nature and are deleted when you exit your web browser. Persistent cookies are
permanent in nature and are stored and remain on your computer until they are
deleted. Persistent cookies expire or auto-delete after a certain period of time,
which is set per cookie but are renewed each time you visit the Website. HTML5
localStorage objects are permanent in nature and remain on your computer until
they are deleted.

6.2. What do we use Cookies for?

We use Cookies for:

Generating statistics
Measuring Website traffic such as the number of visits to the Website, which
domains the visitors come from, which pages they visit on the Website and in
which overall geographical areas the visitors are located.

6.3. Monitoring Website performance and your use of our Website

Monitoring the performance of the Website, our applications and TrustBoxes and
how you use our Website, applications and TrustBoxes.

6.4. Authentication and improving the functionality of our Website

Optimising your experience with the Website, which includes remembering your

Sapphire Systems Ltd, The Shard, 32 London Bridge Street, London, SE1 9SG | +44 (0) 20 7648 2000
Registered Office: 843 Finchley Road, London NW11 8NA | Registered in England Number: 02777799 | VAT No: 597 4420 07
 username and password when you return to the Website, and remembering
information about your browser and preferences (e.g. which language you prefer).

6.5. Connecting you to Social Networks

We give you the option of connecting with Social Networks, such as Facebook.

6.6. Quality Assurance

Ensuring the quality of reviews and to prevent misuse or irregularities in
connection with writing reviews and using the Website.

6.7. Targeted advertisements

Displaying relevant advertisements on the Website, including interest-based
advertisements, which we believe are of interest to you. We use third parties to
provide these advertisements when you visit the Website and other websites.
These third parties may use Cookies alone or in conjunction with web beacons or
other tracking technologies to collect information about your use of our Website
and other websites.

6.8. Third Party Cookies

Third-party Cookies are set by third party websites – not our Website. When you
visit our Website, the following third-party Cookies may be set:

 Facebook cookies, set when you log in to our Website with Facebook.

 Google cookies, set when you log in to our Website with Google.

 Google AdSense cookies, set when displaying relevant targeted

advertisements on our Website. Some cookies may be set as DoubleClick,
which is part of Google.

 New Relic cookies, set when monitoring and analysing the performance of
our applications and metrics from user sessions.

 Hotjar localStorage, set for managing how and when surveys are displayed.

6.9. Deletion of Cookies

You can delete the cookies already on your device. You can typically delete cookies
from the Privacy or History area, available from the Settings or Options menu in
the browser.

In most browsers, the same menu can be reached through the Ctrl+Shift+Del
keyboard shortcut or Command+Shift+Del if you're on a Mac.

Sapphire Systems Ltd, The Shard, 32 London Bridge Street, London, SE1 9SG | +44 (0) 20 7648 2000
Registered Office: 843 Finchley Road, London NW11 8NA | Registered in England Number: 02777799 | VAT No: 597 4420 07
 If you do not accept Cookies from our Website, you may experience inconvenience
in your use of the Website.

7. Data Retention
We keep the Master Data and other personal data you provide with our services. If
you choose to delete your details, we will delete this information upon your
request and we will only save a log with the following information: your name,
email address for the purposes of logging your request and to ensure that you are
no longer contacted.

8. Security
We have gone to great lengths to protect your personal information within our
organisation and regularly audit our systems for vulnerabilities.

9. Changes to the Policy

We may change this Policy at any time. The date shown at the start of this Policy
indicates when it was last revised. Any changes will become effective when we
post the revised Policy on the Website. You agree that your continued use of the
Website after any posted modifications constitutes your acceptance of the new
version of the Policy.

10. Enquiries regarding the website or the Policy

If you have questions or concerns about our Policy, how we process your personal
information or would like us to correct your personal information, please contact
us at: GDPR.enquiries@sapphiresystems.com

In addition to the rights set out above regarding your personal data, you also have
the following rights:

 You also have the right to object to the processing of your personal data –
the unconditional right to object to the processing of your personal data for
direct marketing purposes.

If our processing of your personal information is based on your consent, you have
the right to withdraw your consent at any time. Your withdrawal will not affect the
lawfulness of the processing of data carried out before you withdrew your consent.
You may withdraw your consent by contacting us at:
GDPR.enquiries@sapphiresystems.com

Sapphire Systems Ltd, The Shard, 32 London Bridge Street, London, SE1 9SG | +44 (0) 20 7648 2000
Registered Office: 843 Finchley Road, London NW11 8NA | Registered in England Number: 02777799 | VAT No: 597 4420 07
 Sapphire Systems Ltd, The Shard, 32 London Bridge Street, London, SE1 9SG | +44 (0) 20 7648 2000
Registered Office: 843 Finchley Road, London NW11 8NA | Registered in England Number: 02777799 | VAT No: 597 4420 07