Privacy Policy - Breedon Bow Highways

Privacy Notice: All Breedon Group Customers

This privacy notice describes how the Breedon Group (We/Us) collects and uses information about its customers, before, during and after the contractual relationship, to the extent such information is personal data in accordance with the EU Regulation 2016/679 General Data Protection Regulation (GDPR). This document also satisfies our obligations under Article 30 of the GDPR. It applies to all customers of the Breedon Group (You).

Data Controller Details

The Company is a data controller for the purposes of the GDPR and every customer on behalf of itself and any of its directors, shareholders, members, employees, servants and agents (“associates”) acknowledges the use and processing of personal data described in this privacy notice. Company means the member of the Breedon Group selling goods and/or associated services to the relevant customer. Breedon Group means any of the companies within the Breedon group of companies, including, without limitation, Breedon Trading Limited, Breedon Cement Limited, Breedon Holdings Limited, Breedon Group Services Limited, Lagan Materials Limited, Lagan Asphalt Limited, Whitemountain Quarries Ltd, Alpha Resource Management Ltd, Breedon Cement Ireland Limited, Breedon Employee Services Ireland Limited and/or Breedon Brick Limited further details of which can be found at www.breedongroup.com

Categories of Data Subjects

Whilst the majority of our customers are “corporates”, some may be sole traders, partnerships or consumers. We may therefore collect personal data from those types of customers and any employees or individuals working for that customer (collectively “customers”).

Categories of Personal Data

We may collect the following categories of personal data about customers:

• Personal details including name, address, email, telephone number including mobile phone or other contact information;

• Date of birth and/or age;

• Banking, taxation and financial information including VAT details;
• Credit information (through an external third party);

• Electronic identification data including IP address collected through our websites;

• Contractual details including the goods and services provided, trading history with the Company, insurance details and buying status;

• Audio recordings of all telephone orders, enquiries and customer communications (Audio Data); and/or

• Images (still or video) from the closed circuit television (CCTV) on the Company’s sites or from onboard vehicle monitoring (CCTV Data).

Due to the Coronavirus pandemic, in addition to the collection of personal data as mentioned above, Breedon may also be required to collect the following information from 2 customers when attending at one of our Breedon sites in order to comply with the Government’s legislation/guidelines in respect of any track and trace system:

• information to determine whether a customer has experienced or are maybe experiencing Covid-19 symptoms (which may include temperature checks) or are in any of the high-risk categories which are most vulnerable to become infected and seriously ill (Health Information); and/or

• a positive result for Covid-19; details of anyone a customer may have been in contact with who has tested positive for Covid-19 or presented with symptoms; whether a customer has been asked to self-quarantine within the preceding 14 days; and/or where a customer has travelled to in the preceding 14 days (Contact History).

Source of personal data

Most of the information we obtain comes directly from customers or in the case of Audio Data and CCTV Data from our IT systems. Some information may come from external third-party credit reference agencies or credit insurers. If you don’t provide us with this data we may be unable to enter into or conclude a contract with you.

Purposes of Data Processing

The Company collects and processes data about customers, some of which may be
personal data as defined under GDPR, for purposes which include:

• As necessary to perform a contract with a customer including:
o To take steps at the customer’s request prior to entering into a contract;
o To decide whether to enter into a contract;
o To make credit decisions about the customer or its associates regarding the contract or the entering into of a new contract with us;
o To manage, perform and operate the contract and the customer’s account;
o To update our records;
o To resolve any complaints in relation to the contract;
o To recover debts.

• As necessary for our own legitimate interests or those of other persons and organisation, for example:
o For good governance, accounting and managing and auditing our business operations;
o To search credit reference agencies;
o To protect the health and safety of workers and others;
o Maintaining, monitoring, improving and enhancing our goods and services;
o To monitor Audio Data and CCTV Data for quality control and training or for the detection and prevention of crime or unauthorised use of our systems.

• As necessary to comply with our legal obligations for example:
o Where disclosure is necessary for or in connection with any legal
proceedings (including prospective legal proceedings), for obtaining legal
advice or for establishing, exercising or defending legal rights;
o For tax collection purposes;
o To comply with any regulatory obligations to which we are subject;
o Where we are required to do so by law (including under any legislation, or by a court or tribunal in any jurisdiction);3
o All Health Information and Contact History will be obtained in order that we can keep you and others safe and/or where we are required to comply with Government legislation/guidelines in respect of any track and trace system as part of a response to Covid-19;
o For fraud prevention and money laundering purposes in compliance with our statutory obligations.

Categories of Personal Data Recipients

We disclose personal data to a number of recipients which includes the following categories of persons:

• Other companies within the Breedon Group;

• Auditors and professional advisors, such as our bankers, lawyers and consultants;

• Law enforcement officials and statutory or regulatory authorities;

• Third-party service providers, such as providers of CCTV management; Audio Data management; IT system management; credit checks, debtor tracing; hauliers, contractors or subcontractors or associated services necessary to perform the contract.

We may use and replace any third party which we wish to use to assist us in meeting its obligations under the contract, and where such third party is a processor of personal data, this constitutes prior general written authorisation as envisaged by Article 28(2) of the GDPR.

We may transfer personal data outside the EEA in accordance with the principles of the
GDPR.

Data Protection Principles

We will comply with data protection law which includes the GDPR (Data Protection Laws) applicable in the country in which the Company operates. This says that the personal information we hold must be:

Used lawfully, fairly and in a transparent way.
Collected only for valid purposes that have been clearly explained and not used in anyway that is incompatible with those purposes.
Relevant to the purposes we have told you about and limited only to those purposes.
Accurate and kept up to date.
Kept only as long as necessary for the purposes we have told you about.
Kept securely.

Personal Data Retention Periods

We typically retain personal data obtained from customers for 6 years after the completion or termination of the contract, save for Audio Data which is retained for 6 months and CCTV Data which is retained for 30 days.

Technical and Organisational Security Measures

We have implemented technical and organisational security measures to protect personal data.

Duty to inform us of changes

It is important that the personal information we hold about customers is accurate and current. We ask all our customers to keep us informed if personal information changes during your contractual relationship with us.

Customers’ rights in connection with personal information

Under certain circumstances, by law customers have the right to:

• Request access to personal information.

• Request correction of the personal information that we hold.

• Request erasure of personal information.

• Object to processing of personal information where we are relying on a legitimate interest (or those of a third party) and there is something about the particular situation which makes you want to object to processing on this ground.

• Request the restriction of processing of personal information.

• Request the transfer of personal information to another party.

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 Breedon Group. You may make a complaint to the local data commissioner’s office in which the Company operates if you are dissatisfied as to how your personal data is being processed.

Data Processors

For the purposes of the contract and GDPR, we are of the view that it is the Company which is the data controller. However, if the Company is deemed to be acting as data processor for the purposes of the contract (or the customer is held to be a data processor in relation to any of the Company’s personal data they receive during the contract) then the relevant processor shall:

• only act on the written instructions of the controller (unless required by law to act without such instructions);

• ensure that people processing the data are subject to a duty of confidence;

• take appropriate measures to ensure the security of processing;

• only engage a sub-processor with the prior consent of the data controller and a written contract;

• assist the data controller in providing subject access and allowing data subjects to exercise their rights under the GDPR;

• assist the data controller in meeting its GDPR obligations in relation to the security of processing, the notification of personal data breaches and data protection impact assessments;

• delete or return all personal data to the controller as requested at the end of the contract;

• submit to audits and inspections, provide the controller with whatever information it needs to ensure that they are both meeting their Article 28 obligations, and tell the controller immediately if it is asked to do something infringing the GDPR or other data protection law of the EU or a member state. Each of the parties, shall, comply with its obligations under the GDPR, shall co-operate with the relevant supervisory authorities and upon request provide the other with reasonable assistance, information and cooperation, at its own expense, to ensure the other party’s compliance with their respective obligations

Changes to this Record of Processing Activities

We reserve the right to amend this Privacy Notice from time to time consistent with the GDPR and other applicable data protection requirements.

You can contact us at Compliance.Officer@breedongroup.com.

Breedon Group plc 1 April 2021

Privacy Notice: All Breedon Group Suppliers

This privacy notice describes how the Breedon Group (We/Us) collects and uses information about its suppliers, before, during and after the contractual relationship, to the extent such information is personal data in accordance with the EU Regulation 2016/679 General Data Protection Regulation (GDPR). This document also satisfies our obligations under Article 30 of the GDPR. It applies to all suppliers (whether of goods and/or services) to the Breedon Group (You).

Data Controller Details

The Company is a data controller for the purposes of the GDPR and every supplier on behalf of itself and any of its directors, shareholders, members, employees, servants and agents (“associates”) acknowledges the use and processing of personal data described in this privacy notice.
Company means the member of the Breedon Group buying goods and/or associated services from the relevant supplier. Breedon Group means any of the companies within the Breedon group of companies, including, without limitation, Breedon Trading Limited, Breedon Cement Limited, Breedon Holdings Limited, Breedon Group Services Limited, Lagan Materials Limited, Lagan Asphalt Limited, Whitemountain Quarries Ltd, Alpha Resource Management Ltd, Breedon Cement Ireland Limited, Breedon Employee Services Ireland Limited and/or Breedon Brick Limited further details of which can be found at www.breedongroup.com

Categories of Data Subjects

Whilst the majority of our suppliers are “corporates”, some may be sole traders or partnerships. We may therefore collect personal data from those types of suppliers and any employees or individuals working for that supplier (collectively “suppliers”).

Categories of Personal Data

We may collect the following categories of personal data about suppliers:

• Personal details including name, address, email, telephone number including mobile phone or other contact information;

• Date of birth and/or age;

• Banking, taxation and financial information including VAT details:

• Credit information (through an external third party);

• Electronic identification data including IP address collected through our websites;

• Contractual details including the goods and services provided, trading history with the Company, insurance details and buying status;

• The details of the supplier’s customers;

• Audio recordings of all telephone orders, enquiries and supplier communications (Audio Data);

• Images (still or video) from the closed circuit television (CCTV) on the Company’s sites or from onboard vehicle monitoring (CCTV Data); and/or

• Telemetry data from onboard tracking systems (Telemetry Data).

Due to the Coronavirus pandemic, in addition to the collection of personal data as mentioned above, Breedon may also be required to collect the following information from suppliers when attending at one of our Breedon sites in order to comply with the Government’s legislation/guidelines in respect of any track and trace system:

• information to determine whether a supplier has experienced or are maybe experiencing Covid-19 symptoms (which may include temperature checks) or are in any of the high-risk categories which are most vulnerable to become infected and seriously ill (Health Information); and/or

• a positive result for Covid-19; details of anyone a supplier may have been in contact with who has tested positive for Covid-19 or presented with symptoms; whether a supplier has been asked to self-quarantine within the preceding 14 days; and/or where a supplier has travelled to in the preceding 14 days (Contact History).

Source of personal data

Most of the information we obtain comes directly from the supplier or in the case of Audio Data and CCTV Data from our IT systems and Telemetry Data from our vehicle tracking systems. Some information may come from external third-party credit reference agencies or credit insurers. If you don’t provide us with this data we may be unable to enter into or
conclude a contract with you.

Purposes of Data Processing

The Company collects and processes data about suppliers, some of which may be personal data as defined under GDPR, for purposes which include:

• As necessary to perform a contract with a supplier including:

o To take steps at the supplier’s request prior to entering into a contract;
o To decide whether to enter into a contract;
o To make credit decisions about the supplier or its associates regarding the
contract or the entering into of a new contract with us;
o To manage, perform and operate the contract and the supplier’s account;
o To update our records;
o To resolve any complaints in relation to the contract.

• As necessary for our own legitimate interests or those of other persons and organisation, for example:

o For good governance, accounting and managing and auditing our business operations;
o To search credit reference agencies;
o To protect the health and safety of workers and others;
o Maintaining, monitoring, improving and enhancing our goods and services;
o To monitor Audio Data, CCTV Data and Telemetry Data for quality control
and training or for the detection and prevention of crime or unauthorised use of our systems.

• As necessary to comply with our legal obligations for example:

o Where disclosure is necessary for or in connection with any legal
proceedings (including prospective legal proceedings), for obtaining legal
advice or for establishing, exercising or defending legal rights;
o For tax collection purposes;
o To comply with any regulatory obligations to which we are subject;3
o Where we are required to do so by law (including under any legislation, or by a court or tribunal in any jurisdiction);
o All Health Information and Contact History will be obtained in order that we can keep you and others safe and/or where we are required to comply with Government legislation/guidelines in respect of any track and trace system as part of a response to Covid-19;
o For fraud prevention and money laundering purposes in compliance with our statutory obligations.

Categories of Personal Data Recipients

We disclose personal data to a number of recipients which includes the following categories of persons:

• Other companies within the Breedon Group;

• Auditors and professional advisors, such as our bankers, lawyers and consultants;

• Law enforcement officials and statutory or regulatory authorities and courts;

• Third-party service providers, such as providers of CCTV management; Audio Data management; IT system management; credit checks; hauliers, contractors or subcontractors or associated services necessary to perform the contract.

Data Protection Principles

We will comply with data protection law which includes the GDPR (Data Protection Laws) applicable in the country in which the Company operates. This says that the personal information we hold must be:
1. Used lawfully, fairly and in a transparent way.
2. Collected only for valid purposes that have been clearly explained and not used in any way that is incompatible with those purposes.
3. Relevant to the purposes we have told you about and limited only to those purposes.
4. Accurate and kept up to date.
5. Kept only as long as necessary for the purposes we have told you about.
6. Kept securely. .

Personal Data Retention Periods

Except as otherwise permitted or required by applicable law or regulation, we only retain personal data for as long as necessary to fulfil the purposes we collected it for, as required to satisfy any legal, accounting, or reporting obligations, or as necessary to resolve disputes. We typically retain personal data obtained from suppliers for 6 years after the completion or termination of the contract, save for Audio Data which is retained for 6 months and Telemetry Data or CCTV Data which is retained for 30 days.

Technical and Organisational Security Measures

We have implemented technical and organisational security measures to protect personal data.

Duty to inform us of changes

It is important that the personal information we hold about suppliers is accurate and current. We ask all our suppliers to keep us informed if personal information changes during your contractual relationship with us.

Suppliers’ rights in connection with personal information

Under certain circumstances, by law suppliers have the right to:

• Request access to personal information.

• Request correction of the personal information that we hold.

• Request erasure of personal information.

• Request the restriction of processing of personal information.

• Request the transfer of personal information to another party.

Data Processors

For the purposes of the contract and GDPR, we are of the view that it is the Company which is the data controller. However, if the Company is deemed to be acting as data processor for the purposes of the contract (or the supplier is held to be a data processor in relation to any of the Company’s personal data they receive during the contract) then the relevant processor shall:

• act only on the written instructions of the controller (unless required by law to act without such instructions);

• ensure that people processing the data are subject to a duty of confidence;
• take appropriate measures to ensure the security of processing;

• only engage a sub-processor with the prior consent of the data controller and a written contract;

• assist the data controller in providing subject access and allowing data subjects to exercise their rights under the GDPR;

• assist the data controller in meeting its GDPR obligations in relation to the security of processing, the notification of personal data breaches and data protection impact assessments;

• delete or return all personal data to the controller as requested at the end of the contract;

Each of the parties, shall, comply with its obligations under the GDPR, shall co-operate with the relevant supervisory authorities and upon request provide the other with reasonable assistance, information and cooperation, at its own expense, to ensure the other party’s compliance with their respective obligations.

Changes to this Record of Processing Activities

We reserve the right to amend this Privacy Notice from time to time consistent with the GDPR and other applicable data protection requirements. You can contact us at Compliance.Officer@breedongroup.com.

Breedon Group plc 1 April 2021

GDPR PRIVACY NOTICE FOR ALL BREEDON GROUP WORKERS

What is the purpose of this document?

Breedon Group plc and its subsidiaries, are committed to protecting the privacy and security of your personal information. Breedon Group plc has the following wholly owned trading subsidiaries: Breedon Trading Limited,
Breedon Cement Limited, Breedon Holdings Limited, Breedon Group Services Limited, Lagan Materials Limited, Lagan Asphalt Limited, Whitemountain Quarries Ltd, Alpha Resource Management
Ltd, Breedon Cement Ireland Limited, Breedon Employee Services Ireland Limited, Breedon Brick Limited (together Breedon and each a Breedon Company). This privacy notice describes how we collect and use personal information about you during and after your working relationship with us, in accordance with the General Data Protection Regulation
(GDPR).

It applies to all Breedon workers, “worker” means all of Breedon’s permanent and temporary employees, work experience candidates, agency workers, consultants, company officers, directors, job applicants, contractors and workers. Each Breedon Company is a “data controller”, which means a party who (either alone or jointly) determines the purposes for which and the manner in which any personal data is, or will be,
processed. 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.

This notice applies to current and former workers. This notice does not form part of any contract of employment or other contract to provide services. We may update this notice at any time. 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.

Data protection principles

We will comply with data protection law. This says that the personal information we hold about you must be:

1. Used lawfully, fairly and in a transparent way.
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.
3. Relevant to the purposes we have told you about and limited only to those purposes.
4. Accurate and kept up to date.3
5. Kept only as long as necessary for the purposes we have told you about.
6. Kept securely.

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

Identity Data:

• Personal contact details such as name (surname and forenames), title, addresses, telephone numbers, and personal email addresses; date of birth; gender; nationality; marital status and dependants (including your potential beneficiary details in relation to life assurance, death in
service or personal pension (if any)); next of kin and emergency contact information; copy of passport including photograph; copy of driving licence, insurance certificates, recruitment information (including copies of right to work documentation, references and other information
included in a CV or cover letter or as part of the application process; interview notes, internal notes, results of any written or online selection tests); photographs; automated voice recording from our telephone systems.

Financial Data:

• Bank account details, payroll records and tax status information; salary; annual leave; pension details and rates; benefits information; National Insurance number or Irish equivalent; tax code; cumulative taxable pay and tax; cumulative NIable pay and NI; breakdown of NI; payroll
number; bank sort code and account number; bank account name; building society roll number; student loan information; court order information; share scheme or share save details; compensation history.

Worker Data:

• Start date; reason for leaving and date; annual leave; FTE and contract hours; full or part time; working pattern; location of employment or workplace; employment records (including job titles, work history, training records and professional memberships); performance information; disciplinary and grievance information; mobile phone records; information about your use of business equipment, technology and systems including our computers, telephones, mobile phones, software applications, social media, door entry systems, clocking 4 in and out systems and/or time recording; vehicle registration numbers or mileage records; CCTV footage and other information obtained through electronic means such as swipecard records, route mapping data; information about your use of our information and communications systems; information obtained from onboard CCTV or vehicle tracking systems.

We may also collect, store and use the following “special categories” of more sensitive personal
information:

Special Category Data:

• Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions; Trade union membership; Information about your health, including any medical condition, health and sickness records including breakdown of SSP, SMP and SPP; medical
screening information; and/or Information about criminal convictions and offences.

Technical Data:

• Internet protocol (IP) address; your login data; browser type and version; time zone setting and location; browser plug-in types and versions; operating system and platform; and other technology on the devices you use to access this website.

Usage Date:

• Information about how you use the internet; username; passwords; and browser history, from any devices belonging to the Breedon Group.

How is your personal information collected?

We collect personal information about workers through the application and recruitment process, either directly from candidates or sometimes from an employment agency or background check provider. We may sometimes collect additional information from third parties including former employers, credit reference agencies or other background check agencies.
We will collect additional personal information in the course of job-related activities throughout the period of you working for us.

How we will use information about you

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:

1. Where we need to perform the contract we have entered into with you.5
2. Where we need to comply with a legal obligation.
3. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

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

1. Where we need to protect your interests (or someone else’s interests).
2. Where it is needed in the public interest.
Situations in which we will use your personal information

We need all the categories of information in the list above (see “The kind of information we hold about you”) primarily to allow us to perform our contract with you and to enable us to comply with legal obligations. In some cases we may use your personal information to pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights do not override those interests.

The situations in which we will normally process your personal information are listed below.

• Making a decision about your recruitment or appointment.

• Determining the terms on which you work for us.

• Checking you are legally entitled to work in the UK or Ireland and obtaining references.

• Paying you correctly and determining overtime and, if you are an employee, deducting tax and National Insurance contributions (or equivalent under Irish tax laws) and keeping appropriate records.

• Providing the following benefits to you, such as but not restricted to: company vehicles, private healthcare, death in service, mobile phone.

• Liaising with your pension provider.

• Ensuring you are appropriately qualified and trained for current or potential roles.

• Administering, managing and enforcing the contract we have entered into with you.

• Providing access to the Breedon Sharesave Scheme or other share scheme and administering this or appointing third parties to administer this on our behalf.

• Business management and planning, including accounting and auditing, business efficiencies and improvements.

• Conducting performance reviews, managing performance and determining performance requirements.

• Making decisions about salary reviews and compensation.

• Assessing qualifications for a particular job or task, including decisions about promotions and career progression.

• Gathering evidence for possible grievance conduct or disciplinary hearings or breaches of contractual obligations related to you or otherwise involving you.

• Making decisions about your continued employment or engagement.

• Making arrangements for the termination of our working relationship.

• Education, training and development requirements.

• Dealing with legal disputes involving you, or other workers, including but not limited to verification of information provided and accidents at work.

• Conducting risk assessments, establishing safety measures to mitigate identified risks; providing a safe working environment and keeping required records.

• Ascertaining your fitness to work.

• Managing sickness absence, statutory and non statutory holiday and other leave.
• Complying with health and safety obligations.

• To prevent fraud.

• To monitor your use of our information and communication systems and social media presence to ensure compliance with our IT policies and expected standards.

• Recording communications with customers for quality control and training purposes.

• To ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution; preventing excessive personal use.

• To conduct data analytics studies to review and better understand employee retention and attrition rates.

• Equal opportunities monitoring.

Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.
If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you (such as paying you or providing a benefit), or we may be prevented from complying with our legal obligations (such as to ensure the health and safety of our workers).

Change of purpose

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.
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.

How we use particularly sensitive personal information

“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:
1. In limited circumstances, with your explicit written consent.
2. Where we need to carry out our legal obligations and in line with our data protection policy.
3. Where it is needed in the public interest, such as for equal opportunities monitoring or in relation to our occupational pension scheme, and in line with our data protection policy.
4. Where it is needed to assess your working capacity on health grounds, subject to appropriate confidentiality safeguards.

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 members or former members in the course of legitimate business activities with the appropriate safeguards.

Our obligations in relation to special categories of data

We will use your particularly sensitive personal information in the following ways:

• We will use information relating to leaves of absence, which may include sickness absence or family related leaves, to comply with employment and other laws.

• We will use information about your physical or mental health, or disability status, to ensure your health and safety in the workplace and to assess your fitness to work, to provide appropriate workplace adjustments, to monitor and manage sickness absence and to administer benefits.

• We will use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting.

• We will use trade union membership information to pay trade union premiums, register the status of a protected employee and to comply with employment law obligations.

• We will use information relating to leaves of absence, which may include sickness absence or family related leave in gathering evidence for possible grievance or disciplinary hearings or making decisions about your continuing employment or engagement.

• We may collect limited information from you which can be in the form of an “expression of wishes” which sets out how and to whom you would like us to distribute the proceeds of any company benefits we administer (Beneficiary). This could include life assurance or death in
service benefit. We obtain the details (name and relationship to you) of the Beneficiary from you under an obligation of confidence and will only be processed, when we need to administer the relevant benefits. We are prevented from notifying a Beneficiary of the details of the personal data we hold about them as the information was obtained under an obligation
of confidence.

You may provide personal data of a Beneficiary directly to a third party benefits provider as part of your employment which will be processed in line with that third party’s privacy policy and notices.

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 in the field of employment law. 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.

Information about criminal convictions

We may only use information relating to criminal convictions where the law allows us to do so. This will usually be where such processing is necessary to carry out our obligations and provided we do so
in line with our data protection policy. Less commonly, we may use information relating to criminal convictions where it is necessary in
relation to legal claims, where it is necessary 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 members or former members in the course of legitimate business activities with the appropriate safeguards. We envisage that we will hold information about criminal convictions. Where appropriate, we will collect information about criminal convictions as part of the recruitment or appointment process or we may be notified of such information directly by you in the course of you
working for us.

We will use information about criminal convictions and offences in the following ways:

• Making a decision about your recruitment or appointment.

• Making decisions about your confirmed employment or engagement
• Making arrangements for the termination of our working relationship.

We are allowed to use your personal information in this way to carry out our legal obligations and in our legitimate interests to determine any impact of those criminal convictions within a particular role.

Automated decision-making

Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. We are allowed to use automated decision-making in the following circumstances:

1. Where we have notified you of the decision and given you 21 days to request a reconsideration.
2. Where it is necessary to perform the contract with you and appropriate measures are in place to safeguard your rights.
3. In limited circumstances, with your explicit written consent and where appropriate measures are in place to safeguard your rights.

If we make an automated decision on the basis of any particularly sensitive personal information, we must have either your explicit written consent or it must be justified in the public interest, and we must also put in place appropriate measures to safeguard your rights.

You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you. We do not envisage that any decisions will be taken about you using automated means, however we
will notify you in writing if this position changes.

Data sharing

We may have to share your data with third parties, including third-party service providers and other entities in the group. We require third parties to respect the security of your data and to treat it in accordance with the law. We may transfer your personal information outside the EU.
If we do, you can expect a similar degree of protection in respect of your personal information.

Why might you share my personal information with third parties?

We will 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 in doing
so.

Which third-party service providers process my personal information?

“Third parties” includes third-party service providers (including contractors and designated agents) and other entities within our group. The following activities are carried out by third-party service providers: payroll, making payments to you, pension administration, benefits provision and
administration, IT services, Sharesave or share scheme provision and administration, mileage logs, vehicle tracking, CCTV monitoring, phone recordings.

This includes but is not limited to the following
third-party service providers who may process personal information about you for the following purposes:

• Midland HR iTrent (payroll); Sage (accounts & payroll packages); Pams (HR software); CORVID PayGate and Experian (Bacs payment software); Concur Solutions (expenses software); Link Asset Services and Orient Capital (shareholder registry); Aon Hewitt (management consultancy); Aviva (pension provider, private medical insurance, life assurance and digital GP); Willis Towers Watson (benefits broker and insurance broker); AXA
(motor insurance); HDI Global (to deal with employer’s liability claims); Peoples Pension (pension provider); Legal and General (life assurance provider); Yorkshire Building Society (Sharesave scheme); TomTom (route tracker); Barclays (our bankers); Danske (banking); Zenith (company cars); HMRC (to deal with taxation); Inform Direct (statutory records); SAP
(computer system); JDE (computer system); Quiet Storm Ltd (communications distributor); SunSign Communications, MED Ltd, Quiet Storm Ltd and Radley Yeldar (photographs from publications); Investis Limited (website host via the systems of Bladonmore (Europe) Ltd);
Evolve, Kevin Bradly Ltd (courier); Parcelforce (courier); Postal Sort (postal services); Fisher German (tenant agency); Occupational Health practitioner; Simply Health, Westfield Health (health insurance providers); Kerr Henderson (life assurance broker); GMB, Unite Union
(Union fees); Welfare Hope (Hope social club contribution); Curie Care, Charitable Giving, 11 Barnado’s (charitable donations); Court Orders (payments by employees re judgments); Student Loans (payments by employees for historical loans); professional trustees; the Company’s brokers; Insight (despatch software); SHE (HSE software); ZAP (Business Intelligence Tool); Therefore (Canon Document Management); and/or Advance Systems (Time & Attendance System).

We also share data with our legal and other professional advisers appointed from time to time to obtain professional advice about matters relating to you or in the course of dealing with disputes with you and other workers or in compliance with our legal obligations.

How secure is my information with third-party service providers and other entities in our group?

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.

When might you share my personal information with other entities in the group?

We will share your personal information with other entities in our group as part of our regular reporting activities on company performance where we need to perform our contract with you, in the context of a business reorganisation or group restructuring exercise, for system maintenance support and hosting of data, for business improvements, to protect health and safety, for learning and development.

What about other third parties?

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. We may also share your data with potential new service providers or other corporate transactions. We will share your data with customers, potential customers, shareholder and interested parties for inclusion in corporate reports for use in business communications and/or security clearance to work on customer’s premises.

Transferring information outside the EEA

We will transfer the personal information we collect about you to countries outside the EEA in order to perform our contract with you. We will only do this if there is an adequacy decision by the European Commission in respect of that country or we will ensure that the recipient of the information enters into a contract with us confirming that your personal information does receive an adequate level of protection as it were in the EEA. If you require further information about these protective measures,
you can request it from the Compliance Team.

Data security

We have put in place measures to protect the security of your information.
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. 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. 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.

Data retention
How long will you use my information for?

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 intranet (if relevant) or the Compliance Team. 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. 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 an employee, worker or contractor of the company we will retain and securely destroy your personal information in accordance with our data retention policy or any applicable laws and regulations.

Rights of access, correction, erasure, and restriction
Your duty to inform us of changes

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 working relationship with us.

Your rights in connection with personal information

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

• 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.

• 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.

• 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 youhave exercised your right to object to processing (see below).

• 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.

• 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.

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

No fee usually required

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.

What we may need from you

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). This is another appropriate security measure to ensure that personal information is not disclosed to any person who
has no right to receive it.

Right to withdraw consent
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 a member of the Compliance Team. 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. Please note we are not necessarily obliged to accept your withdrawal request. There may be other legal reasons why we can refuse.

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.

Make a Complaint

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority or the Irish data commissioner’s office for data protection issues.

Compliance Team

The Compliance Team oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact any one of the
following:

Ross McDonald
Group Services Director
Pinnacle House,
Breedon Quarry,
Breedon on the Hill,
Derby, DE73 8AP
D: 01332 694404
M: 07717 336401
ross.mcdonald@breedongroup.com

Lorna Coxon
Company Solicitor
Hope Works,
Hope Valley,
Derbyshire,
S33 6RP
D: 01433 622323
M: 07802 873723
lorna.coxon@breedongroup.com

Privacy Notice: Website Use and Marketing

Introduction

Welcome to the Breedon Group’s (Breedon) website use and marketing privacy notice.

Breedon respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and in relation to marketing and tell you about your privacy rights and how the law protects you.

Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.

1. Important information and who we are

Purpose of this privacy notice

Welcome to the Breedon Group’s (Breedon) website use and marketing privacy notice. Breedon respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and in relation to marketing and tell you about your privacy rights and how the law protects you.

Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.

1. Important information and who we are
Purpose of this privacy notice

This privacy notice aims to give you information on how Breedon collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our mailing list newsletter or take part in a competition.

This website is not intended for children and we do not knowingly collect data relating to children. It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are
using your data. This privacy notice supplements the other notices and is not intended to override them.

Controller

The Breedon Group is made up of different legal entities, details of which can be found at www.breedongroup.com. This privacy notice is issued on behalf of the Breedon Group so when we mention “Breedon”, “we”, “us” or “our” in this privacy notice, we are referring to Breedon Group plc and its subsidiary and associated companies, including, Breedon Cement Limited, Breedon Trading Limited, Breedon Group Services Limited, Breedon
Holdings Limited, Lagan Materials Limited, Lagan Asphalt Limited, Whitemountain Quarries Ltd, Alpha Resource Management Ltd, Breedon Cement Ireland Limited, Breedon Employee Services Ireland Limited and/or Breedon Brick Limited (together “Breedon” and each a “member of Breedon”) the relevant company in the Breedon Group responsible for
processing your data.

The following legal entities are the controller and operator of the following websites:

www.breedongroup.com Breedon Trading Limited
www.breedon-special-aggregates.co.uk Breedon Trading Limited
www.1stmix.co.uk Breedon Trading Limited
www.welshslate.com Breedon Trading Limited
www.breedoncement.com Breedon Cement Limited
www.mobileconcretesolutions.co.uk Breedon Trading Limited
www.breedonbowhighways.com Breedon Trading Limited
www.kingscourtbrick.com Breedon Brick Limited
www.breedonrooftiles.co.uk Breedon Trading Limited
www.hopecementworks.co.uk Breedon Cement Limited
www.holmehallquarry.co.uk Breedon Trading Limited

Changes to the privacy notice and your duty to inform us of changes
This version was updated on 1 April 2021.

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

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their
privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

The data we collect about you

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).We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.

• Contact Data includes billing address, delivery address, email address and
telephone numbers.

• Financial Data includes bank account and payment card details.

• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.

• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.

• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback, consultation and survey responses.

• Usage Data includes information about how you use our website, products and services.

• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does 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 notice.

We do not collect 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). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with
goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

How is your personal data collected?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email, via a Breedon website or otherwise.

This includes personal data you provide when you:

• apply for our products or services;

• create an account on our website;

• subscribe to our service or publications;

• request marketing to be sent to you;

• enter a competition, promotion or survey;

• provide comments or views on any form of public consultation via the website or generally; or

• give us some feedback.

• Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.

• Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:

• Technical Data from the following parties:
(a) analytics providers;
(b) advertising networks; and
(c) search information providers.
• Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
• Identity and Contact Data from data brokers or aggregators.
• Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.

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

• Where we need to perform the contract we are about to enter into or have entered into with you.

• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

• Where we need to comply with a legal or regulatory obligation.

• Where we need to respond to your feedback.

See below to find out more about the types of lawful basis that we will rely on to process your personal data. Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via
email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity Type of data Lawful basis for processing
including basis of legitimate interest
To register you as a new customer (a) Identity
(b) Contact
Performance of a
contract with you
To process and deliver your order
including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to
us
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and
Communications
(a) Performance
of a contract with
you
(b) Necessary for
our legitimate
interests (to
recover debts due
to us)
To manage our relationship with you
which will include:
(a) Notifying you about changes to our
terms or privacy policy
(b) Asking you to leave a review or take
a survey
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and
Communications
(a) Performance
of a contract with
you
(b) Necessary to
comply with a
legal obligation
(c) Necessary for 6
(c) Responding to your feedback either
to any of our public consultations or
generally
our legitimate
interests (to keep
our records
updated and to
study how
customers use
our
products/services)
To enable you to partake in a prize
draw, competition or complete a survey
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and
Communications
(a) Performance
of a contract with
you
(b) Necessary for
our legitimate
interests (to study
how customers
use our
products/services,
to develop them
and grow our
business)
To administer and protect our business
and this website (including
troubleshooting, data analysis, testing,
system maintenance, support, reporting
and hosting of data)
(a) Identity
(b) Contact
(c) Technical
(a) Necessary for
our legitimate
interests (for
running our
business,
provision of
administration and
IT services,
network security,
to prevent fraud
and in the context
of a business
reorganisation or
group
restructuring
exercise)
(b) Necessary to
comply with a
legal obligation
To deliver relevant website content and
advertisements to you and measure or
understand the effectiveness of the
(a) Identity
(b) Contact
Necessary for our
legitimate
interests (to study 7
advertising we serve to you (c) Profile
(d) Usage
(e) Marketing and
Communications
(f) Technical
how customers
use our
products/services,
to develop them,
to grow our
business and to
inform our
marketing
strategy)
To use data analytics to improve our
website, products/services, marketing,
customer relationships and experiences
(a) Technical
(b) Usage
Necessary for our
legitimate
interests (to
define types of
customers for our
products and
services, to keep
our website
updated and
relevant, to
develop our
business and to
inform our
marketing
strategy)
To make suggestions and
recommendations to you about goods or
services that may be of interest to you
(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
Necessary for our
legitimate
interests (to
develop our
products/services
and grow our
business)
To collect your contact details in order to
comply with Government
legislation/guidelines or any track and
trace system as part of a response to
Covid-19
(a) Identity
(b) Contact
(a) Public Interest:
to ensure the
health and safety
of the public and
our employees
(b) Necessary to
comply with legal
obligation

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any company outside the Breedon group of companies for marketing purposes.

Opting out
You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing references or by following the opt-out links on any marketing message sent to you or by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see Breedon’s cookie policy at www.breedongroup.com.

Change of purpose

We will only use your personal data 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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we
will explain the legal basis which allows us to do so.

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

Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
• Internal Third Parties as set out in paragraph 10.
• External Third Parties as set out in paragraph 10.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets.

Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice. 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 specified purposes and in accordance with our instructions.

International transfers
We share your personal data within the Breedon Group.
Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
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:

• 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.

• 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.

• 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.10

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

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

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.

Data retention

How long will you use my personal data for?

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, accounting, or reporting requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see below for further information. In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These are set out below.

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required

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

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation
to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Glossary
LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are
overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

THIRD PARTIES
Internal Third Parties

Other companies in the Breedon Group acting as joint controllers or processors and who are based in the UK and Ireland and provide IT and system administration services and undertake leadership reporting.

External Third Parties

• Service providers acting as processors who provide IT and system administration services.
• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, planning, lands and minerals, banking, legal, insurance and accounting services.12
• HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

YOUR LEGAL RIGHTS
You have the right to:

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

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data 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 data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data 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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our
use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Public Consultations: Covid-19

What personal data do we collect?

Due to the Coronavirus pandemic, Breedon is required to collect information from you when you attend a public consultation held at one of our Breedon sites (Site). The information we collect from you regarding this processing activity includes:

• Identity Data: Name and postcode;
• Contact Data: Telephone number.

How do we collect personal data?

We collect your personal data when you arrive as a “walk-in” in order for us to log any visitors as required by Government guidelines/legislation. This information may be needed as part of any track & trace system which is operating in the jurisdiction by the relevant public health authority in which the Site is based (Track & Trace).

The data we collect comes directly from you when attending a Site. Failing to provide the required personal data may mean we are unable to grant you access to our Site.

Our lawful basis for processing

Breedon only process your personal data when we have a lawful basis to do so. The lawful basis for us collecting your personal data for the purposes of Track & Trace is:

• Public Interest: To ensure the health and safety of the public due to Coronavirus for Track & Trace.

Make a complaint

You have the right to make a complaint at any time to the Information Commissioner’s Office, the UK supervisory authority for data protection issues (www.ico.org.uk) or the Irish Data Commissioner’s Office (www.dataprotection.ie). We would, however, appreciate the chance to deal with your concerns before you approach them so please contact us in the
first instance.

Compliance Team

We have appointed a Compliance Team who are responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice please contact the Compliance Team using the details set out below.

Contact details

Name	Office	Telephone and e-mail
Ross McDonald Group Services Director	Pinnacle House, Breedon Quarry, Breedon on the Hill, Derby, DE73 8AP	D: 01332 694404 M: 07717 336401 ross.mcdonald@breedongroup.com
Lorna Bennett Company Solicitor	Hope Works, Hope Valley, Derbyshire, S33 6RP	D: 01433 622323 M: 07802 873723 lorna.bennett@breedongroup.com

Breedon Group: Cookie Policy

This website www.breedonbowhighways.com (“Our Site”) uses Cookies and similar technologies in order to distinguish you from other users. By using Cookies, We are able to provide you with a better experience and to improve Our Site by better understanding how you use it.

Please read this Cookie Policy carefully and ensure that you understand it. Your acceptance of Our Cookie Policy is deemed to occur if you continue using Our Site. If you do not agree to Our Cookie Policy, please stop using Our Site immediately.

Definitions and Interpretation
1.1 In this Cookie Policy, unless the context otherwise requires, the following expressions have the following meanings:

“Cookie” means a small file placed on your computer or device
by Our Site when you visit certain parts of Our Site
and/or when you use certain features of Our Site;

“Cookie Law” means the relevant parts of the Privacy and Electronic
Communications (EC Directive) Regulations 2003 and
of EU Regulation 2016/679 General Data Protection
Regulation (“GDPR”);

“personal data” means any and all data that relates to an identifiable
person who can be directly or indirectly identified from
that data, as defined by GDPR; and “We/Us/Our” means Breedon Group plc and all our subsidiary and associated companies.
Information About Us
2.1 Our Site is owned and operated by Breedon Trading Limited, a limited company registered in England and Wales under company number 00156531, whose registered address is Pinnacle House, Breedon Quarry, Breedon on the Hill, Derby, DE73 8AP.
How Does Our Site Use Cookies?
3.1 Our Site may place and access certain first party Cookies on your computer or device. First party Cookies are those placed directly by Us and are used only by Us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve Our products and/or services. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.

3.2 By using Our Site, you may also receive certain third party Cookies on your computer or device. Third party Cookies are those placed by websites, services, and/or parties other than Us. Third party Cookies are used on Our Site as detailed in section 4 below.

3.3 All Cookies used by and on Our Site are used in accordance with current Cookie Law. We may use some or all of the following types of Cookie:

3.3.1 Strictly Necessary Cookies

A Cookie falls into this category if it is essential to the operation of Our
Site, supporting functions such as logging in, your shopping basket,
and payment transactions.

3.3.2 Analytics Cookies

It is important for Us to understand how you use Our Site, for example,
how efficiently you are able to navigate around it, and what features
you use. Analytics Cookies enable us to gather this information,
helping Us to improve Our Site and your experience of it.

3.3.3 Functionality Cookies

Functionality Cookies enable Us to provide additional functions to you
on Our Site such as personalisation and remembering your saved
preferences. Some functionality Cookies may also be strictly
necessary Cookies, but not all necessarily fall into that category.

3.3.4 Targeting Cookies

It is important for Us to know when and how often you visit Our Site,
and which parts of it you have used (including which pages you have
visited and which links you have visited). As with analytics Cookies,
this information helps us to better understand you and, in turn, to make
Our Site and advertising more relevant to your interests.

3.3.5 Third Party Cookies

Third party Cookies are not placed by Us; instead, they are placed by
third parties that provide services to Us and/or to you. Third party
Cookies may be used by advertising services to serve up tailored
advertising to you on Our Site, or by third parties providing analytics
services to Us (these Cookies will work in the same way as analytics
Cookies described above).

3.3.6 Persistent Cookies

Any of the above types of Cookie may be a persistent Cookie.
Persistent Cookies are those which remain on your computer or device
for a predetermined period and are activated each time you visit Our
Site.

3.3.7 Session Cookies

Any of the above types of Cookie may be a session Cookie. Session
Cookies are temporary and only remain on your computer or device 3
from the point at which you visit Our Site until you close your browser.
Session Cookies are deleted when you close your browser.

3.4 Cookies on Our Site are not permanent and will expire as indicated in the table below.

3.5 For more details of the personal data that We collect and use, the measure we have in place to protect personal data, your legal rights, and our legal obligations, please refer to our Privacy Policy
https://breedonbowhighways.com/privacy-policy/.

3.6 For more specific details of the Cookies that We use, please refer to the table below.
What Cookies Does Our Site Use?

4.1 The following Cookies may be placed on your computer or device:

Name of Cookie Purpose & Type Expiry Date
CONSENT Cookie consent setting 20 years
NID Advertising cookie by Google 5 months
_ga Google Universal Analytics sets a unique ID used to 2 years calculate data for analytics reports for how users interact with content
_gid Used to distinguish users from one another. 1 year

4.2 Our Site uses analytics services. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling Us to better understand how Our Site is used. This, in turn, enables Us to improve Our Site and the products offered through it. You do not have to allow Us to use these Cookies, however whilst Our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable Us to continually improve Our Site, making it a better and more useful experience for you.

4.3 The analytics service(s) used by Our Site use(s) analytics Cookies to gather the required information.
Consent and Control

5.1 Before Cookies are placed on your computer or device, you will be shown a pop up requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling Us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies unless those Cookies are strictly necessary; however certain features of Our Site may not function fully or as intended. You can return to your Cookie preferences to review and/or change them at any time.

5.2 In addition to the controls that We provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third party Cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.

5.3 The links below provide instructions on how to control Cookies in all
mainstream browsers:

5.3.1 Google Chrome:
https://support.google.com/chrome/answer/95647?hl=en-GB

5.3.2 Microsoft Internet Explorer: https://support.microsoft.com/enus/kb/278835

5.3.3 Microsoft Edge: https://support.microsoft.com/engb/products/microsoft-edge (Please note that there are no specific
instructions at this time, but Microsoft support will be able to assist)

5.3.4 Safari (macOS):
https://support.apple.com/kb/PH21411?viewlocale=en_GB&locale=en_
GB

5.3.5 Safari (iOS): https://support.apple.com/en-gb/HT201265

5.3.6 Mozilla Firefox: https://support.mozilla.org/en-US/kb/enable-anddisable-Cookies-website-preferences

5.3.7 Android:
https://support.google.com/chrome/answer/95647?co=GENIE.Platform
%3DAndroid&hl=en (Please refer to your device’s documentation for
manufacturers’ own browsers)
Changes to this Cookie Policy

6.1 We may alter this Cookie Policy at any time. Any such changes will become binding on you on your first use of Our Site after the changes have been made. You are therefore advised to check this page from time to time.

6.2 In the event of any conflict between the current version of this Cookie Policy and any previous version(s), the provisions current and in effect shall prevail unless it is expressly stated otherwise.
Further Information

7.1 If you would like to know more about how We use Cookies, please contact Us at Compliance.Officer@breedongroup.com, by telephone on 01332 694400, or by post at Pinnacle House, Breedon on the Hill, Derby DE73 8AP.

7.2 For more information about privacy, data protection and our terms and conditions, please visit our privacy policy on the website.