Privacy Policy

ElecLink

Purpose of this privacy noticeElecLink Limited (“ElecLink”, “we” or “us” or “our”), in its capacity as an interconnector project developer and operator, potentially uses, stores and transfers personal data obtained from an identifiable user (“you”). The scope of the data we obtain from you is limited and is generally data we obtain directly from you, but it is important that you read this privacy notice together with any other privacy policy or notice we may provide on specific occasions when we are collecting or processing personal data about you. This privacy notice supplements other notices and privacy policies and is not intended to override them.

We want you to be fully aware of what data we collect and how and why we collect it, understand that we do not misuse it for unrelated purposes, and give you some additional information about how we keep your data safe. We wish to maintain an open and transparent approach in relation to the protection of personal information. If you have any questions about this privacy notice or our collection and processing of your data, please do not hesitate to contact privacy@eleclink.co.uk

The data we collect about you and how we collect it Personal data, or personal information, means any information about an individual from which that person can be identified. We use different methods to collect data from your and about you including through:

Direct interactions: This can be through your use of our website (including any data you may provide when you subscribe for updates on the ElecLink interconnector project or our Registration process or when you contact ElecLink in its capacity as a project developer to receive answers to any of your questions), through your use of ElecLink’s Nominations Platform (“Neptune Platform”) or through the course of our day-to-day dealings with you related to the ElecLink interconnector project (including any data you may provide as part of a service provider / customer relationship whether under non-binding discussions or commercial contracts).

Automated technologies or interactions: . As you interact with our website or the Neptune Platform, we will automatically collect Limited Technical Data, Communications Date and Aggregated Data (see below) about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.

Third party or publicly available sources. We may also receive identity, contact, financial and transaction data about you (or employees or personnel of your company in contact with, or providing services to, ElecLink) from various third parties and public sources such as search information providers or public records (e.g. Companies House).

The personal data we collect, use, store and transfer can include:

Your IP address is retained in accordance with your cookie preferences and browser settings. We also collect and use aggregated data such as statistical data. This aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

ElecLink does not collect or use any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data) unless you directly provide us with that personal data for a legitimate purpose connected with our dealings with you and we issue you with a specific privacy notice.

We may use your personal data to keep you informed about the ElecLink interconnector project and our services that may be of interest to you. This is how we decide which services may be relevant for you. You will receive communications from us if you have subscribed to receive updates on the ElecLink interconnector project or our Registration process.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, accounting, reporting or other requirements. Certain personal data will be retained in our backups after its deletion, for example where you have used the Neptune Platform, we will retain your personal data in the execution history and backups of the Neptune Platform for seven (7) years from when you cease to be a customer.

We may share your personal data with those who have a genuine business need to know it (including our affiliated entities and group companies, employees and personnel, representatives, technical consultants and/or professional advisers, third parties that we supply services to, third party suppliers/service providers who perform functions on our behalf under contract, support our systems and/or provide IT and system administration services, analytics and search engine providers that assist us in the improvement and optimisation of our site e.g. Google, HM Revenue & Customs, regulatory or similar governance and/or administrative bodies). We seek to ensure that any information sharing and processing is always proportionate and access is limited to those whom have a business need to know, and that those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for purposes compatible with which it was collected and in accordance with our instructions.

From time to time ElecLink may engage with third parties based outside the European Economic Area (EEA), so their potential processing of your data may involve a transfer of data outside the EEA. If we use those service providers in a country that is not subject to an adequacy decision by the EU Commission, we will require them to respect a similar degree of protection personal data is afforded in EEA countries by entering into EU approved standard contractual clauses or a vendor’s Processor Binding Corporate Rules.

Our website may contain links to enable you to visit other websites of interest easily. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.

Cookies What are “cookies”?

The term of cookies is to be taken in the broad sense and cover all the tokens that are attached to a user or a program during the consultation of a website, reading of emails, installation or use of software and mobile application.

During the course of any visit to a website, the pages you see, along with a cookie, are down-loaded to your device. Thus, cookies enable website publishers to do useful things like find out whether the device (and probably its user) has visited the website before. This is done on the next visit by checking and finding the cookie that was left there on the last visit.

How we use “cookies”

We use the following cookies:

We do not use cookies to target advertising or to share information with social networking sites or other services.

Your legal rights and choices The accuracy of the information that we hold about you is important to us. If any of the information that we hold is inaccurate or out of date, please let us know using the contact details set out at the end of this Privacy Policy. You also have the right:

Where we have asked for your consent, you may withdraw consent at any time. If you ask to withdraw your consent to Eleclink processing your personal data, this will not affect any processing which has already taken place at that time. You can also ask us not to send or to carry out profiling for direct marketing, at any time.

These rights may be limited in some situations – for example, where we can demonstrate that we have a legal requirement to process your data.

If you wish to exercise these rights, please contact us using the details below.

If you have unresolved concerns you have the right to complain to an EU data protection authority where you live, work or where you believe a breach may have occurred.

Updates to this Policy We keep our Privacy Policy under regular review and may update it periodically. We will update the date at the top of this Privacy Policy accordingly. On some occasions, we may also actively advise you of specific data handling activities or significant changes to this Privacy Policy as required by applicable law.

Contact us We hope that we can satisfy queries you may have about the way we process your data. If you have any concerns about how we process your data, feel free to discuss these with our legal department or the Getlink group Data Protection Officer, who can be contacted as follows: Getlink group Data Protection Officer:

Email: DPO@getlinkgroup.com

By post in the UK: Getlink Data Protection Officer, UK Terminal, Ashford Road, Folkestone, Kent CT18 8XX

By post in France: Getlink Data Protection Officer, Siege Exploitation B.P. 69 62904 Coquelles. Cedex. France

Who is my data controller? Your data controller will be the Eleclink entity with which you have a relationship.

Email: privacy@eleclink.co.uk

Post: Legal Team, ElecLink Limited, 4 Kingdom Street, London W2 6BD

Thank you for your interest in our project.

Groupe Eurotunnel

Getlink is committed to ensuring that the personal information you give us is kept private and protected. Our privacy policies explain how we do this.

We hope the following information will answer any queries you may have, however should you require any additional information, please contact the Getlink Data Protection Officer using the contact details at the end of this Notice.

What does this notice cover?
The diverse and bi-national nature of companies within Getlink means that each company issues Privacy Notices for their staff and their customers as appropriate. You can read these Notices by checking the company website below. Each Privacy Notice describes how the company uses personal data.

What personal data do Getlink companies collect?We collect and process personal data when you interact with us. The type of personal data collected depends on your relationship with each group company and is specified on each Privacy Notice.

What personal data do Getlink companies receive from third parties?Getlink companies work with trusted partners to ensure we provide high quality services and comply with the law and best practice. The range of services provided is diverse and set out within each group company’s website.

How do Getlink companies use personal data and what is the legal basis for its use?Each Privacy Notice describes how the company uses personal data and the legal basis for its use. The legal basis for use depends on your relationship with the Getlink companies but includes:

How long will we keep your personal data?That depends on your relationship with us and the type of information we keep. Timescales vary if, for example you are a customer of Eurotunnel or a staff member with Europorte. The time for which data is kept is set out in each group company Privacy Notice.

How will the companies of Getlink share
your personal data?

We share personal data with other members of the Getlink companies to administer and manage group functions, with trusted third parties, such as our professional advisers and auditors, with government authorities and/or law enforcement officials and with other third parties providing services for the purposes set out in each group company Privacy Notice.

What are your choices and rights? The accuracy of the information that we hold about you is important to us. If any of the information that we hold is inaccurate or out of date, please let us know using the contact details set out at the end of this Privacy Notice. You have the right:

Where we have asked for your consent, you may withdraw consent at any time but this will not affect any processing which has already taken place at that time.

These rights may be limited in some situations – for example, where we can demonstrate that we have a legal requirement to process your data.

If you wish to exercise these rights, please contact us using the details below.

If you have unresolved concerns you have the right to complain to an EU data protection authority where you live, work or where you believe a breach may have occurred.

How do we protect your personal Information? We take security seriously. We employ security measures to protect your information from access by unauthorised persons and against unlawful processing, accidental loss, destruction and damage.

What about links to other websites? Some Getlink companies’ websites contain links to third party websites. Those third parties are required to comply with data protection principles and legal obligations. While we do our best to ensure that any linked websites associated with us operate to the highest standards we do not control the way they may process your personal data. We recommend that you read the Privacy Notice when you enter a new site and do not proceed unless you are sure your personal data will be treated properly.

What about cookies? Getlink companies’ websites contain cookies. Our Cookie Policies explain how cookies work and how you can manage them.

Updates to Getlink Companies’ Privacy Notices We keep our Privacy Notices under regular review, and may update them periodically. When necessary we may also actively advise you of specific data handling activities or significant changes to our Privacy Notices as required by applicable law.

Contact us We hope that we can satisfy queries you may have about the way we process your data. If you have any concerns about how we process your data, feel free to discuss these with our Data Protection Officer, who can be contacted at:

Email: DPO@getlinkgroup.com

By post in the UK: Getlink Data Protection Officer, UK Terminal, Ashford Road, Folkestone, Kent CT18 8XX

By post in France: Getlink Data Protection Officer, Siege Exploitation B.P. 69 62904 Coquelles. Cedex. France

Who is my data controller? You data controller will be Getlink S.E with which you have a relationship. Please check the appropriate Getlink company Privacy Notice for details.