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Privacy policy

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This Privacy Policy explains how we use the personal information that the Panel on Takeovers and Mergers collects or generates, both in relation to this website and in relation to the exercise of our regulatory functions.

The list below sets out what is covered in this Privacy Policy and you can click on the headings below to go to a specific section.

  1. BACKGROUND
  2. THE TYPES OF PERSONAL DATA WE COLLECT
  3. HOW AND WHY WE USE YOUR INFORMATION
  4. DISCLOSURE OF YOUR INFORMATION TO THIRD PARTIES
  5. INTERNATIONAL TRANSFERS OF PERSONAL DATA
  6. HOW WE SAFEGUARD YOUR INFORMATION
  7. HOW LONG WE KEEP YOUR PERSONAL DATA
  8. YOUR RIGHTS
  9. COOKIES NOTICE
  10. QUESTIONS AND CONCERNS
  1. BACKGROUND
    1. The Panel on Takeovers and Mergers, whose address is 1 Angel Court, London, EC2R 7HJ collects and uses certain Personal Data (as defined in paragraph 1.3, below). The Panel on Takeovers and Mergers is responsible for ensuring that we use Personal Data in compliance with data protection laws.
    2. At the Panel on Takeovers and Mergers we respect your privacy and we are committed to keeping all your Personal Data secure. This Privacy Policy governs the handling of Personal Data by the Panel on Takeovers and Mergers in the course of the exercise of our regulatory functions.
    3. We use the following definitions in this Privacy Policy:
      • “Panel”, “we” or “us” means the Panel on Takeovers and Mergers.
      • “Personal Data” means any data which relates to a living individual who can be identified from that data or from data and other information which is in the possession of, or is likely to come into the possession of, the Panel (or its representatives or service providers). In addition to factual information, it includes any expression of opinion about an individual and any indication of the intentions of the Panel or any other person in respect of an individual.
  2. THE TYPES OF PERSONAL DATA WE COLLECT
    1. When exercising our functions, operating our website (the “Panel Website”) and when carrying out our services generally, we will process the following categories of Personal Data about you:
      1. information that you provide to the Panel. This includes information about you that you provide to us. The nature of the activities that we carry out in accordance with our regulatory functions determines the kind of Personal Data we might ask for, though such information will include:
        1. basic Personal Data (such as first name and family name); as business-related personal information such as your job title and your business contact details (address, email, telephone); and
        2. Personal Data related to your professional life or financial or personal dealings (such as details of directorships, involvement in share transactions, shareholdings in companies, banking arrangements (including details of bank accounts and prime brokerage accounts), details of professional advisers, business associates, friends and family and general corporate activity/history).
      2. information that we collect or generate about you. This includes (by way of non-exhaustive list):
        1. information generated through your use of the Panel Website (e.g. any documents downloaded from the Panel Website, searches made on the Panel Website, etc.);
        2. information we receive or generate as a result of providing our publications or other information to you;
        3. information generated by us about you in the exercise of our regulatory functions, including during the course of our case work and investigations that relate in some way to you; and
        4. images of you generated by CCTV cameras in operation on our premises.
      3. information we obtain from other sources. This may include:
        1. information obtained from public websites and other public sources;
        2. information received from your advisers or intermediaries, including bankers, stockbrokers and financial advisers, with respect to transactions that you have engaged in or which are related to you;
        3. information obtained from third parties such as Bloomberg, Thomson Reuters, the London Stock Exchange and other financial information outlets;
        4. information from your business associates, friends and family;
        5. information obtained from employees of third party companies involved in your business transactions that fall within our regulatory scope; and
        6. information provided by other regulators, authorities and/or related third parties relating to activities falling within our regulatory functions.
      4. cookies
        1. When you visit the Panel Website, cookies are used to collect technical information about the services that you use, and how you use them.
        2. For more information on the cookies used by the Panel please see paragraph 9 below.
  3. HOW AND WHY WE USE YOUR INFORMATION
    1. Your Personal Data may be stored and processed by us in the following ways and for the following purposes:
      1. to ensure that we can exercise our regulatory functions properly and efficiently under, amongst other things, the Companies Act 2006 and the Takeover Code;
      2. to conduct administrative tasks within the Panel in aid of the exercise of our regulatory functions or otherwise administering our organisation;
      3. for record-keeping purposes required for the Panel’s internal business administration;
      4. to communicate with you in order to provide you with information about the Panel, the conduct of our functions and our publications;
      5. to communicate, as appropriate, with other regulators and authorities both within the UK and outside of the UK, in the exercise of our regulatory functions;
      6. for the management and administration of our organisation;
      7. for ongoing review and improvement of the operation of the Panel Website and information provided on the Panel Website to ensure that it is user-friendly and informative;
      8. in order to comply with, and to assess compliance with, applicable laws, rules and regulations, and internal policies and procedures; and/or
      9. for the administration and maintenance of databases storing Personal Data.
    2. However we use Personal Data, we will make sure that the usage complies with the law. The law allows us and requires us to use Personal Data for a variety of reasons. For example:
      1. we have legal and regulatory obligations that we have to discharge, including in relation to the exercise of our regulatory functions;
      2. we carry out tasks that are within the public interest or by virtue of our official authority under relevant statutes, such as the Companies Act 2006;
      3. we may need to use your Personal Data in order to perform our contractual obligations with you;
      4. we may have obtained your consent to use your Personal Data;
      5. we may need to use your Personal Data in order to establish, exercise or defend our legal rights or for the purpose of legal proceedings; or
      6. the use of your Personal Data may be necessary for our legitimate interests, such as:
        1. allowing us effectively and efficiently to manage and administer the Panel’s operations; and
        2. maintaining compliance with internal policies and procedures
    3. We will take steps to ensure that Personal Data is accessed only by employees of the Panel who have a need to do so for the purposes described in this Privacy Policy.
  4. DISCLOSURE OF YOUR INFORMATION TO THIRD PARTIES
    1. We may share your Personal Data within the Panel.
    2. We may also share your Personal Data outside of the Panel to the following recipients for the following purposes:
      1. with parties connected with the exercise of our regulatory functions in order to perform such functions, such as other regulators or official bodies (both in the UK and overseas), the Takeover Appeal Board and other third parties in the UK and overseasas as required in the exercise of our regulatory functions;
      2. with third party agents and contractors for the purposes of providing services to us (for example, the Panel’s accountants, professional advisers, IT and communications providers); and
      3. to the extent required by law or regulation, for example if we are under a duty to disclose your Personal Data in order to comply with any legal obligation (including, without limitation, in order to comply with our duty to cooperate with other regulators), or to establish, exercise or defend our legal rights.
  5. INTERNATIONAL TRANSFERS OF PERSONAL DATA
    1. In certain circumstances, we may transfer your Personal Data to locations outside of the UK, in particular where requested by an overseas regulator.
    2. Where we transfer your Personal Data to any country or territory outside the UK, we will ensure that it is protected and transferred in a manner consistent with legal requirements. For example, this may be done in one of the following ways:
      1. the country that we send your Personal Data to might be approved by the UK government and/or the Information Commissioner’s Office and/or such relevant authority in the UK as offering an adequate level of protection for Personal Data;
      2. the recipient might have signed up to the standard contractual clauses approved by the UK government and/or the Information Commissioner’s Office and/or such relevant authority in the UK obliging them to protect your Personal Data; or
      3. in other circumstances, where the law permits us to otherwise transfer your Personal Data outside of the UK.
    3. You can obtain more details of the protection given to your Personal Data when it is subject to international transfers outside of the UK (including a copy of any standard contractual clauses which we have entered into with non-UK recipients of your Personal Data) by contacting us as described in paragraph 10 below.
  6. HOW WE SAFEGUARD YOUR INFORMATION
    1. We have extensive controls in place to maintain the security of our information and information systems. Files are protected with safeguards according to the sensitivity of the relevant information. Appropriate controls (such as restricted access) are placed on our computer systems. Physical access to areas where Personal Data is gathered, processed or stored is limited to authorised employees.
    2. As a condition of employment, the Panel’s employees are required to follow all applicable laws and regulations, including in relation to data protection law and the statutory duties of confidence applied to the Panel. Access to sensitive Personal Data is limited to those employees who need to it to perform their roles. Unauthorised use or disclosure of confidential personal information by a Panel employee is prohibited and may result in disciplinary or punitive measures, in particular under the Companies Act 2006.
  7. HOW LONG WE KEEP YOUR PERSONAL DATA
    1. How long we will hold your Personal Data for will vary and will be determined by the following criteria:
      1. the purpose for which we are using it – the Panel will need to keep the data for as long as is necessary for that purpose; and
      2. legal obligations – laws or regulation may set a minimum period for which we have to keep your Personal Data.
  8. YOUR RIGHTS
    1. In all of the cases described in this Privacy Policy in which we collect, use or store your Personal Data, you may have the following rights and, in most cases, you can exercise them free of charge. These rights include:
      1. the right to obtain information regarding the processing of your Personal Data and access to the Personal Data which we hold about you;
      2. where you have given consent for any processing of your Personal Data, the right to withdraw that consent at any time. Please note, however, that we may still be entitled to process your Personal Data if we have another legitimate reason for doing so. For example, we may need to retain Personal Data to comply with a legal obligation or to enable us to exercise our regulatory functions;
      3. in some circumstances, the right to receive some Personal Data in a structured, commonly used and machine-readable format and/or request that we transmit those data to a third party where this is technically feasible. Please note that this right only applies to Personal Data which you have provided directly to the Panel;
      4. the right to request that we rectify your Personal Data if it is inaccurate or incomplete;
      5. the right to request that we erase your Personal Data in certain circumstances. Please note that there may be circumstances where you ask us to erase your Personal Data but we are legally entitled to retain it;
      6. the right to object to, or request that we restrict, our processing of your Personal Data in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your Personal Data but we are legally entitled to refuse that request; and
      7. the right to lodge a complaint with the Information Commissioner if you think that any of your rights have been infringed by us.
    2. There may be limitations or exemptions applicable to the exercise of your rights. If we do not comply with your request we will explain the reason when we respond to the request.
    3. You can exercise your rights by contacting us using the details listed in paragraph 10 below.
  9. COOKIES NOTICE
    1. This Cookies Notice provides you with information about the cookies we use and why we use them. It should be read together with the Privacy Policy outlining our practices regarding your Personal Data.
    2. Cookies are small text files that are sent to and temporarily stored on your computer, smartphone or other device for accessing the internet whenever you visit a website.
    3. We use cookies for a variety of reasons, including:
      1. to improve the functionality and performance of the Panel Website (including your user experience) and to make sure the Panel Website performs as you expect it to;
      2. to distinguish you from other users of the Panel Website; and
      3. to analyse how you use the Panel Website.
    4. We use the following types of cookies on the Panel Website:
      COOKIES DESCRIPTION DURATION
      Analytics and integrity cookies These help us analyse how you use the Panel Website and allow us to identify what you like and do not like and how we can improve things for you. They also allow for site integrity. We use Google Analytics, a web analytics platform provided by Google which places text files on your computer to help analyse how visitors use the Panel Website. These cookies will remain until they are deleted.
      Session cookies These cookies are essential to ensure performance of the Panel Website. We also use session cookies to display search queries. These cookies will expire when you leave the Panel Website.
      Content Management System Cookies These cookies remember selections or preferences that you have already made on the Panel Website through the software (WordPress) which displays our website content. These cookies typically expire after 1 year
    5. Most of the cookies we use do not save any information that can identify you as an individual. Instead, we receive general and anonymised information from these cookies regarding all users of the Panel Website.
    6. If you do not consent to the use of cookies on the Panel Website you should change your internet browser’s settings to block cookies. For more information about how to disable cookies, visit www.allaboutcookies.org.
    7. The browsers of most computers, smartphones and other web-enabled devices are typically set up to accept cookies. If you wish to amend your cookie preferences for the Panel Website, you can do this at any time and by changing your browser settings. Your browser’s ‘help’ function will tell you how to do this. You do not have to accept cookies. However, please note that cookies are often used to enable and improve certain functions on the Panel Website. If you choose to block cookies through your browser settings, it is may affect how the Panel Website works.
  10. QUESTIONS AND CONCERNS
    1. If you have any questions or concerns about the Panel’s handling of your Personal Data, or about either the Privacy Policy or the Cookies Notice, please contact our Privacy Officer using the following contact information:
      Address:
      The Takeover Panel
      One Angel Court
      London
      EC2R 7HJ
      Email address:
      supportgroup@thetakeoverpanel.org.uk
    2. We would always hope to be able to directly resolve any questions or concerns you may have around our use of your Personal Data. However, you do have the right to lodge a complaint with the applicable privacy regulator in your jurisdiction, which in the UK is the Information Commissioner’s Office (“ICO”) whose website is www.ico.org.uk.