Meiosis Limited Privacy and Cookies Notice

1. Introduction

1.1 Meiosis Limited is committed to protecting the privacy and security of your personal information.

1.2 This privacy notice describes how we collect and use personal information about you during and after your licence, agreement or contract with us, in accordance with the EU General Data Protection Regulation (GDPR).

1.3 It applies to all licensees, licensors, contractors and suppliers.

1.4 Meiosis Limited is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.

1.5 This notice applies to current and former licensees, licensors, contractors and suppliers. This notice does not form part of any licence, agreement or contract with Meiosis Limited or other contract to provide services. We may update this notice at any time.

1.6 It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.

2. Data protection principles

2.1 We will comply with the EU General Data Protection Regulation (GDPR) and other relevant UK and EU legislation. This says that the personal information we hold about you must be:

2.1.1 used lawfully, fairly and in a transparent way;

2.1.2 collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes;

2.1.3 relevant to the purposes we have told you about and limited only to those purposes;

2.1.4 accurate and kept up to date;

2.1.5 kept only as long as necessary for the purposes we have told you about and

2.1.6 kept securely.

3. The kind of information we hold about you

3.1 Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

3.2 There are “special categories” of more sensitive personal data which require a higher level of protection.
3.3 We will collect, store, and use the following categories of personal information about you:

3.3.1 Personal contact details such as name, title, address, telephone numbers and personal email.

3.3.2 Date of birth.

3.3.3 Gender.

3.3.4 Passport details.

3.3.5 Bank account details and tax status information.

3.3.6 Location of business, company, employment or workplace.

3.3.7 Work email addresses having your name.

3.3.8 Information about your use of our information and communications systems.

4. How is your personal information collected?

4.1 We collect most information from you directly. However, we may also collect information from publicly accessible sources e.g.:

4.1.1 Companies House

4.1.2 HM Land Registry

4.2 Directly from third party, e.g.:

4.2.1 Sanctions screening providers

4.2.2 Credit reference agencies

4.2.3 client due diligence providers

4.3 From a third party with your consent, e.g.:

4.3.1 Your bank or building society, another financial institution or advisor;

4.3.2 Consultants and other professionals engaged in relation to your matter;

4.3.3 Your employer or trade union, professional body or pension administrators;

4.4 Via our website:

4.4.1 We use cookies on our website (for more information on cookies, please see our cookies policy: https://www.meiosis.co.uk/privacy-cookies-policy/

4.4.2 Automated monitoring of our websites

4.5 Other technical systems such as our computer networks and connections, telecommunication systems, and email messaging systems.
activities throughout your period of licence, agreement or contract with Meiosis
Limited.

5. How we will use information about you?

5.1 We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:

5.1.1 where we need to perform the contract we have entered into with you;

5.1.2 where we need to comply with a legal obligation;

5.1.3 where it is necessary for our legitimate interests (or those of third parties like plant variety breeders/owners, sub-licensees or contractors) and your interests and fundamental rights do not override those interests;

5.2 We may also use your personal information in the following situations, which are likely to be rare:

5.2.1 where we need to protect your interests (or someone else’s interests); and

5.2.2 where it is needed in the public interest or for official purposes.

6. Situations in which we will use your personal information

6.1 We need all the categories of information in the list above at paragraph 3.3 primarily to allow us to perform our contract with you and to enable us to comply with legal obligations.

6.2 In some cases we may use your personal information to pursue legitimate interests of our own (i.e. business or commercial reasons) or those of third parties (plant variety breeders/owners or sub-licensees), provided your interests and fundamental rights do not override those interests.

6.3 The situations in which we will process your personal information are listed below.
We have indicated by asterisks [*], [**], [***] the purpose or purposes for which we are processing or will process your personal information, as well as indicating which categories of data are involved.

6.3.1 Making a decision about a contract, licence or agreement with you or your company or employer. [*]

6.3.2 Determining the terms of contract, licence or agreement with you or your company or employer. [*]

6.3.3 Checking you are legally entitled to run a business or work in the UK, EU or any other country you are a resident of. [**]

6.3.4 Paying you. [*]

6.3.5 Administering the contract, licence or agreement we have entered into with you. [*]

6.3.6 Business management and planning, including accounting and auditing. [*]
performance and determining business performance requirements. [*]

6.3.8 Making decisions about contracts, licence and agreements reviews. [*]

6.3.9 Assessing qualifications for a particular contract, licence or agreement including decisions about their renewals and cancellations. [*]

6.3.10 Gathering evidence for possible legal action. [*] [***]

6.3.11 Making decisions about your continued licencing, agreement, contract or engagement with Meiosis Limited. [*] [***]

6.3.12 Making arrangements for the termination of contracts, licences or agreements with Meiosis Limited. [*] [***]

6.3.13 Dealing with legal disputes involving you or your company. [*] [***]

6.3.14 Complying with health and safety obligations. [**]

6.3.15 To prevent fraud. [**] [***]

6.3.16 To monitor your use of our information and communication systems to ensure compliance with our IT policies. [*][***]

6.3.17 To ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution. [**][***]

6.3.18 To conduct data analytics studies to review and better understand commercial performance of Meiosis Limited managed varieties. [***]

6.4 Some of the above grounds for processing will overlap and there may be several grounds which justify Meiosis Limited’s use of your personal information.

7. If you fail to provide personal information

If you fail to provide certain information when requested, we may not be able to perform the contract or agreement we have entered into with you, as well as with Meiosis Limited licensors (such as ensuring Plant Variety Rights are not infringed upon and accurate plant sales declarations are made).

8. Change of purpose

8.1 We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

8.2 Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

9. How we use particularly sensitive personal information

9.1 “Special categories” of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We may process special categories of personal information in the following circumstances:

9.1.1 in limited circumstances, with your explicit written consent;

9.1.2 where we need to carry out our legal obligations or exercise rights in relation to your contract, licence or agreement with us. We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data;

9.1.3 less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public. We may also process such information about sub-licensees or licensors as well as former sub-licensees or licensors in the course of legitimate business activities with the appropriate safeguards.

10. Do we need your consent?

We do not need your consent if we use special categories of your personal information in accordance with our written policy to carry out our legal obligations or exercise specific rights as per contracts and agreements signed between you and Meiosis Limited. In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your contract with us that you agree to any request for consent from us.

11. Data sharing

11.1 We may have to share your data with third parties, including Meiosis Limited licensors, licensees, plant variety breeders/owners, third-party service providers and other entities in the group.

11.2 We require third parties to respect the security of your data and to treat it in accordance with the law.

11.3 We may transfer your personal information outside the EU or EEA if licensors are based there. If we do, you can expect a similar degree of protection in respect of your personal information.

11.4 We may need to share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest such as fulfilling Meiosis Limited’s obligations to licensors in doing so.

11.5 “Third parties” includes third-party service providers (including breeders or licensors and designated agents, IT services providers, software as a service suppliers) and other entities within our group. The following activities are carried out by third-party
service providers: intellectual property management system supply, accounting and payroll systems supplies and information technology services.

11.6 All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

11.7 We will share your personal information with other entities in our group as part of our regular reporting activities on company performance, in the context of a business reorganisation or group restructuring exercise, for system maintenance support and hosting of data.

11.8 We may share your personal information with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal information with a regulator or to otherwise comply with the law.

12. Transferring information outside the EEA

12.1 To deliver services to you, it is sometimes necessary for us to share your personal data outside the European Economic Area (EEA), e.g.:

12.1.1 With the Meiosis plant variety breeders/owners located outside the EEA;

12.1.2 If you are based outside the EEA; or

12.1.3 Where there is an international dimension to the licence, agreement or contract under consideration.

12.2 These transfers are subject to special rules under European and UK data protection law. Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

12.2.1 We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.

12.2.2 Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.

12.2.3 Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

13. Data security

13.1 We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way,
altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

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

13.3 Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.

14. Data retention

14.1 We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Details of retention periods for different aspects of your personal information are available in our retention policy which is available from the Company Secretary. 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 requirements.

14.2 In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no longer a licensee, licensor or supplier of the company we will retain and securely destroy your personal information in accordance with our data retention policy.

15. Rights of access, correction, erasure, and restriction

15.1 It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your contractual relationship with us.

15.2 Under certain circumstances, by law you have the right to:

15.2.1 Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.

15.2.2 Request correction of the personal information that we hold about you.
This enables you to have any incomplete or inaccurate information we hold about you corrected.

15.2.3 Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).

15.2.4 Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about
your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.

15.2.5 Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.

15.2.6 Request the transfer of your personal information to another party.

15.3 If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact The Company Secretary in writing (by email or post).

15.4 You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

15.5 We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights) such as a copy of your passport or driving licence (this is not an exhaustive list). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

15.6 In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact the Company Secretary. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

16. Data protection compliance

16.1 The Company Secretary oversees compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the Company Secretary.

17. How to complain

17.1 You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues, who may be contacted at https://ico.org.uk/concerns or telephone: +44 0303 123 1113.]

17.2 The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union or EEA state where you work, normally live or where any alleged infringement of data protection laws occurred.

18. Changes to this privacy notice

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.

If you have any questions about this privacy notice, please contact the Company Secretary on +44 (0)1732 872711 or by email at meiosis@meiosis.co.uk.

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