UK Privacy Notice

STAFF PRIVACY NOTICE

POINT72 UK LIMITED / POINT72 EUROPE (LONDON) LLP

In this privacy notice, “Point72“, “we”, “us” and “our” means: the entity employing or proposing to employ you; or to which you may be contracted to provide services as a contractor; or in which you are or may become a partner on the date that you receive this document, which will be one of either Point72 UK Limited or Point72 Europe (London) LLP.

Point72 UK Limited and Point72 Europe (London) LLP are registered in the UK with their registered address at 8 St James’s Square, London SW1Y 4JU.

About this privacy notice

Please take the time to read and understand this privacy notice in conjunction with Point72’s Global Privacy Policy which can be found here.

For the purposes of data protection law, we are a data controller in respect of your personal data.

This privacy notice applies if: you are, or applying to be, an employee of our organisation; you are contracted to provide services as a contractor to our organisation; or you are or may become a partner of our organisation, and sets out the basis on which any personal data about you will be processed by us.

We will only process your personal data as necessary to fulfil the purposes set out in this privacy notice as they apply to you.

Personal data that we collect about you

Subject to applicable law, we will collect and process the following personal data about you:

• Information that you provide to us or one of our affiliates. This includes information about you that you give to us by filling in forms or by communicating with us, whether face-to-face, by phone, email or otherwise through the recruitment process and during your relationship with us. This information may include (but may not be limited to):
  • your full name (and any previous names), gender, curriculum vitae, place of birth, date of birth, nationality, education and qualification details, marital status, home address and home telephone number, mobile telephone number, next of kin, emergency contact details, bank account details, social security / national insurance number, passport number, driver license details, tax details and your date of hire;
  • information relating to your work permit (including, where required by applicable laws, your entry authorisation, visa or extension of stay) which entitles Point72 to hire you in the UK or any other country;
  • details of your personal investment holdings in accordance with our internal policies on personal account dealing;
  • subject to compliance with local law / regulation, and if it directly affects your ability to perform your job or if there are specific health and safety reasons that make disclosure necessary, whether you have ever consulted a doctor or received any medical treatment while in the UK and certain details concerning the same;
  • other information concerning you or any of your dependent family members as may be required by applicable law or regulation (for example, in the UK, to allow us to lawfully sponsor / hire you or register you as an Approved Person with the Financial Conduct Authority); and
  • diversity monitoring information (including race, ethnic origin, gender and sexual orientation).
• Information we collect or generate about you. This may include:
  • work-related details such as your job title and job description, contact details, performance at work, absences, pay and benefits information, service history, a copy of your agreement with us, passport details, residence permit details, your photograph, health information, pregnancy and/or disability status;
  • personal data that we collect through your use of our email system (including but not limited to your full name, email address and the content, date and time of your email correspondence);
  • information we record through your use of our telephone system where such telephone lines are recorded for regulatory purposes; and
  • information obtained through an exit interview with you (upon your departure from our organisation), including your reasons for leaving.
• Information we obtain from other sources. This includes:
  • information from recruitment agencies, background check providers and your named referees (such as your employment history, professional qualifications, education, right to work in the UK and, subject to any specific authorisation requirements, whether you have any criminal convictions in the UK or any other country (including traffic offences) or any civil judgments made against you);
  • details of your personal investment holdings in accordance with our internal policies on personal account dealing from investment platforms and brokers; and
  • health data from third party providers who carry out occupational health assessments.

Uses of your personal data

Your personal data may be stored and processed by us for the following purposes:

• to meet our obligations under your contract with us. For example, we use your personal data to pay you, to evaluate your individual performance, and to provide benefits in connection with your engagement;
• to comply with any legal or regulatory obligation to which we are subject (including compliance with any request from regulatory authorities or other relevant public authorities). For example, we may be obliged to record certain individuals’ phone lines and process certain data for trade/transaction reporting purposes;
• to manage our information technology and to ensure the security and use in accordance with our policies and procedures of our systems (including our email system);
• to enable us to contact you or your next of kin in the event of an emergency; and
• in order to carry out diversity monitoring as required by law and / or permitted by law.

In the event you do not provide the information necessary for us to manage your engagement with us and/or the formalities with the relevant authorities, we may not be able to proceed with the hiring process.

We are entitled to use your personal data in these ways because:

• we have legal and regulatory obligations to discharge;
• we may need to for the purposes of occupational health and to take decisions regarding your fitness for work;
• it is necessary for reasons of substantial public interest, such as to monitor diversity and equality statistics; and
• the use of your personal data as described may be necessary for our legitimate business interests (or the legitimate interests of one or more of our affiliates), such as:
  • allowing us to effectively and efficiently administer and manage the operation of our business including establishing, exercising or defending our legal rights for the purposes of legal proceedings;
  • protecting information which is proprietary to us;
  • ensuring a consistent approach to the management of our staff and the staff of our affiliate companies worldwide;
  • maintaining compliance with internal policies and procedures, and if appropriate conducting internal investigations; and/or
  • an emergency may arise in which we need to contact you or members of your family.

Disclosure of your information to third parties

We may disclose your personal data to our affiliates within the Point72 group for the purposes of:

• the management and administration of our business and our affiliates’ business;
• complying with the functions that each of them may perform relating to regional or global HR operations;
• benchmarking employee salaries and benefits with similar organisations;
• assessing compliance with applicable laws, rules and regulations, and internal policies and procedures across our business and our affiliates’ business;
• where your personal data is held as part of an internal directory, enabling adequate communication with you for the performance of your duties or for emergency reasons; and
• the administration and maintenance of the databases storing personal data relating to our staff or to staff of our affiliates.

We will take steps to ensure that the personal data is accessed only by staff of our affiliates that have a need to do so for the purposes described in this privacy notice.

We may also share your personal data with third party agents and contractors outside of our corporate group for the purposes of providing services to us, including payroll service providers, IT and communications providers, law firms, accountants, auditors and Approved Publication Arrangement and Approved Reporting Mechanism service providers. These third parties will be subject to confidentiality requirements and they will only use your personal data as described in this privacy notice.

We may also share your personal data with our business partners (including banks, brokers and trading counterparties) to the extent it is necessary for them to receive this information as part of Point72’s general business operations.

In case of a potential sale of the company or of its assets, we may communicate your personal data to a potential buyer for the purpose of due diligence operations.

Disclosure of your personal data may also, under certain circumstances, be required by law. Your personal data will also, if necessary, be shared with judicial, tax or regulatory authorities acting in the performance of their duties and the exercise of their powers.

Recording phone conversations

Point72 may record phone conversations relating to certain financial transactions in order to prevent market abuse and insider dealing. These recordings will only be shared in accordance with the “Disclosure of your information to third parties” section above, and in accordance with applicable law to satisfy regulatory requirements.

The recordings will be kept for a maximal duration of 5 years.

You will be able to exercise your rights relating to these recordings as described in the section below “Your rights”.

Transfers of personal data outside the UK

The personal data that we collect from you may be transferred to, and stored at, a destination outside the UK, in particular, the United States. It may also be processed by individuals operating outside of the UK who work for our affiliates in the United States or elsewhere or for one of our suppliers.

Where we transfer your personal data outside the UK, we will ensure that it is protected in a manner that is consistent with how your personal data will be protected by us in the UK.

This can be done in a number of ways, for instance:

• the country that we send the data to might be approved by the Secretary of State in the UK as offering a sufficient level of protection (for example, transfers of personal data from the UK to countries in the European Economic Area (and vice versa) are approved and can take place freely); or
• the recipient might have signed up to a contract based on “model contractual clauses” issued or approved by the Information Commissioner’s Office, obliging them to protect your personal data.

In other circumstances the law may permit us to otherwise transfer your personal data outside the UK. In all cases, however, we will ensure that any transfer of your personal data is compliant with data protection law.

You can obtain more details about the protection given to your personal data when it is transferred outside the UK (including a copy of the standard data protection clauses which we have entered into with certain recipients of your personal data) by contacting us in accordance with the “Contacting us” section below.

Retention of personal data

How long we hold your personal data for will vary. The relevant retention period will be determined by various criteria including:

• the duration of your contract with us;
• legal obligations which require Point72 to keep your personal data as archives after the expiration of your agreement with us; and
• the establishment, exercise or defence of Point72’s rights, which will require us to store your personal data as archives after the expiration of your contract with us and until the expiration of the applicable limitation period.

Your rights

You have a number of legal rights in relation to your personal data held by us. You can ask us to:

• provide you with information regarding the processing of your personal data, and access the personal data which we hold about you;
• in certain circumstances, provide you with a copy of your 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 to us;
• correct your personal data if it is inaccurate or incomplete;
• erase your personal data; or
• restrict our processing of your personal data. In certain circumstances you can also object to our other processing of your personal data.

These rights will be limited in some situations; for example, where we are required to process your personal data by applicable law or where we are legally entitled to refuse your request.

You can also lodge a complaint with the data protection regulator (details of which are provided below) if you think that any of your rights have been infringed by us.

You can find out more information about your rights by contacting the Information Commissioner’s Office, or by searching their website at https://ico.org.uk/.

To exercise your rights, please contact us using the details set out below.

Contacting us

If you would like further information on the collection, use, disclosure, transfer or processing of your personal data or the exercise of any of the rights listed above, please address questions, comments and requests to DataPrivacy@Point72.com.

Changes to this Privacy Notice

This privacy notice takes effect on 15 October 2024. If we change it, to keep you fully aware of our processing of your personal data and related matters, we will post the new version to Connect.