Privacy Policy

At Hallgarten & Company, we’re committed to protecting and respecting your privacy.

This Policy explains when and why we collect personal information about people who visit our website,
how we use it, the conditions under which we may disclose it to others and how we keep it secure.

We may change this Policy from time to time so please check this page occasionally to ensure that you’re
happy with any changes. By using our website, you’re agreeing to be bound by this Policy.

Any questions regarding this Policy and our privacy practices should be sent by email to:
webmaster@hallgartenco.com.

Who are we?

Hallgarten & Company Ltd provides independent equities analysis focussed principally upon the mining and
metals sector. Hallgarten & Company Limited is a company limited by liability (no. 6825798). The registered
address is 51 Weyhill Rd, Andover, SP10 3AN.

How do we collect information from you?

We obtain information about you when you use our website, for example, when you contact us about products
and services, or if you present us with your business card.

What type of information is collected from you?

The personal information we collect might include your name, email address, IP address, and information
regarding what pages are accessed and when. We do not store physical addresses or telephone numbers.

How is your information used?

We may use your information to send you communications which you have requested and that may be of
interest to you.

We review our retention periods for personal information on a regular basis. We will hold your personal
information on our systems for as long as is necessary for the relevant activity, or as long as is set out in
any relevant contract you hold with us.

Who has access to your information?

We will not sell or rent your information to third parties.

We will not share your information with third parties for marketing purposes.

We do not provide information to Third Party Providers working on our behalf.

Please be reassured that we will not release your information to third parties unless we are required to do
so by law, for example, by a court order or for the purposes of prevention of fraud or other crime.

We may transfer your personal information to a third party as part of a sale of some or all of our business
and assets to any third party or as part of any business restructuring or reorganisation, or if we’re under a
duty to disclose or share your personal data in order to comply with any legal obligation or to enforce or apply
our terms of use or to protect the rights,property or safety of our supporters and customers. However, we will
take steps with the aim of ensuring that your privacy rights continue to be protected.

Your choices

You have a choice about whether or not you wish to receive information from us. If you do not want to receive
direct marketing communications from us then you can select your choices by ticking the relevant boxes situated
on the form on which we collect your information.

We will not contact you for marketing purposes by email, phone, post or text message unless you have given
your prior consent. We will not contact you if you have indicated that you do not wish to be contacted. You can
change your marketing preferences at any time by contacting us by email: webmaster@hallgartenco.com.

How you can access and update your information

The accuracy of your information is important to us. We’re working on ways to make it easier for you to review
and correct the information that we hold about you. In the meantime, if you change email address, or any of the
other information we hold is inaccurate or out of date, please email us at: webmaster@hallgartenco.com.

You have the right to ask for a copy of the information Hallgarten & Company holds about you (we may charge
£10 for information requests) to cover our costs in providing you with details of the information we hold about
you.

Security precautions in place to protect the loss, misuse or alteration of your information

When you give us personal information, we take steps to ensure that it’s treated securely.

Non-sensitive details (your email address etc.) are transmitted normally over the Internet, and this can never
be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, we cannot
guarantee the security of any information you transmit to us, and you do so at your own risk. Once we receive
your information, we make our best effort to ensure its security on our systems.

Profiling

We may analyse your personal information to create a profile of your interests and preferences so that we can
contact you with information relevant to you. We may make use of additional information about you when it is
available from external sources to help us do this effectively.

Use of 'cookies'

The Hallgarten & Company website does not use cookies.

Links to other websites

Our website does not contain links to other websites run by other organisations.

In addition, if you linked to our website from a third party site, we cannot be responsible for the privacy
policies and practices of the owners and operators of that third party site and recommend that you check the
policy of that third party site.

16 or Under

We are concerned to protect the privacy of children aged 16 or under. If you are aged 16 or under‚ please get
your parent/guardian's permission beforehand whenever you provide us with personal information.

Transferring your information outside of Europe

As part of the services offered to you through this website, the information which you provide to us may be
transferred to countries outside the European Union (“EU”). By way of example, this may happen if any of our
servers are from time to time located in a country outside of the EU. These countries may not have similar data
protection laws to the UK. By submitting your personal data, you’re agreeing to this transfer, storing or
processing. If we transfer your information outside of the EU in this way, we will take steps to ensure that
appropriate security measures are taken with the aim of ensuring that your privacy rights continue to be
protected as outlined in this Policy.

If you use our services while you are outside the EU, your information may be transferred outside the EU in
order to provide you with those services.

Website recording

Our web site does not use a web site recording service.

Review of this Policy

We keep this Policy under regular review. This Policy was last updated in May 2018.