Data Protection Policy

Important information

You must read the following information before proceeding. It explains certain legal and regulatory restrictions which apply to the information contained on this website. By accessing this website, you agree to be bound by the terms and conditions below. If you do not agree to the notices and disclaimers below, do not access this website.

This website provides general information about LXi REIT plc (the "Company") only and does not constitute investment, tax, legal or other advice. The information contained on this website is intended only for professional and retail investors (as those terms are used in the Alternative Investment Fund Managers Directive 2011/61/EU) who are resident in the United Kingdom and may not be accessed by persons who are located in the United States, Canada, Australia, the Republic of South Africa or Japan. Viewing the materials you are seeking to access may not be lawful in jurisdictions other than the United Kingdom. In some jurisdictions, only certain categories of person may be allowed to view such materials. Any person who wishes to view these materials must first satisfy themselves that they are not subject to any local requirements that prohibit or restrict them from doing so.

If you are not permitted to view this website or are in any doubt as to whether you are permitted to view this website, please exit this website immediately by clicking on the "I do not accept" button below.

You may download or print copies of the reports or information contained within this website for your own private use only; all other copying, reproducing, transmitting, distributing or displaying of material on this website (by any means and in whole or in part) is prohibited. The contents of this website must not be released or otherwise forwarded, distributed or sent, directly or indirectly, in whole or in part, outside the United Kingdom and in particular in or into any other Member State of the EEA, the United States, Canada, Australia the Republic of South Africa or Japan or any other jurisdiction where the distribution of such materials would or may breach any applicable law or regulation or would require any registration or licensing within such jurisdiction. Persons receiving any such materials (including, without limitation, custodians, nominees and trustees) should observe these restrictions and must not, directly or indirectly, in whole or in part, forward, distribute or send them in, into or from any jurisdiction outside the United Kingdom. None of the Company, LXI REIT Advisors Limited, Alvarium Fund Managers (UK) Limited nor any of their respective representatives accepts any responsibility for any violation by any person of any of these restrictions.

The information on this website may be subject to amendment and updating without notice. None of the Company, LXI REIT Advisors Limited, Alvarium Fund Managers (UK) Limited nor any other person guarantees the accuracy or completeness of any information on this website and each such person disclaims all representations and warranties, whether express or implied, to the greatest extent permitted by applicable law and regulation. By continuing to use this website, you agree to the exclusion by such persons, to the greatest extent permitted by applicable law and regulation, of any and all liability for any direct, indirect, punitive, consequential, incidental, special or other damages, including, without limitation, loss of profits, revenue or data arising out of or relating to the provision of and your use of this website and its content.

This website may contain or link to content which is generated by third parties. None of the Company, LXI REIT Advisors Limited, Alvarium Fund Managers (UK) Limited nor any other person accepts any responsibility in respect of any information contained on any other website which may be linked to or from this website.

The information on this website is for information purposes only and does not constitute or form a part of any offer or invitation to sell or issue, or the solicitation of any offer to purchase or subscribe for, securities in any jurisdiction. If you are considering any investment in the Company's shares and are unsure as to whether the investments described on this website are suitable for you, we strongly recommend that you seek professional advice from a financial adviser before making any investment or financial decisions. All investment is subject to risk. The value of the shares in the Company may go down as well as up. Past performance is no guarantee of future returns and there is no guarantee that the market price of the Company's shares will fully reflect their underlying net asset value. There is also no guarantee that the Company's investment objective or return objectives will be achieved.

This website is governed by the laws of England.

By clicking the "I accept" button below, you warrant that you are located in the United Kingdom, you are not a resident of, or physically present in, the United States, Canada, Australia, the Republic of South Africa or Japan or any other territory where to do so would breach applicable laws, rules or regulations, and you agree that you will not transmit or otherwise send any of the information on this website to persons outside the United Kingdom.

LXi REIT plc (the ‘Company’)

Data Protection Policy

Status
‍
‍This document is authorised by the Board of the Company and is reviewed by the Board at least annually.

This Policy also applies to any subsidiaries held directly and indirectly by the Company, which operate and are incorporated in the UK.

In this Policy, the terms:

"Data Protection Laws" mean all applicable laws from time to time relating to the processing of personal data and/or privacy, including, when, and to the extent in force, (a) the General Data Protection Regulation (Regulation (EU) 2016/679) (the "GDPR"), (b) the Privacy and Electronic Communications Regulations 2003 and (c) any legislation that in respect of the United Kingdom, replaces the GDPR as a consequence of the United Kingdom leaving the European Union; and"controller", "processor", "data subject", "personal data" and "processing" shall have the meanings ascribed to them in the Data Protection Laws.The document sets out the Company’s obligations under the Data Protection Laws and explains how the Company meets these obligations.
‍

‍Data collected and processed lawfully, fairly and transparently
‍
‍Data must be collected and processed for a lawful purpose. In the case of the data held by the Company, that purpose will either be that there is a legal requirement to hold the data or that it is necessary for the purposes of a contract between the Company and the data subject. Normally, a company collecting personal data is obliged to tell the data subject that the data are being collected, the reasons for collecting them and the data subject’s rights in respect of those data. However, this does not apply where the data are collected for the purposes of a statutory register which the company is required to maintain and make available to the public.

As a result, in the case of data held on the registers of directors and shareholders, the Company is not obliged to provide information to the relevant data subjects. However, for other data this information must be provided. The Company places reliance upon its data processors to carry this out.

The Company maintains a record of the types of personal data held and the basis on which it is held.
‍

‍Specific purpose and minimum data
‍
‍The Company only collects and processes personal data that it is required to collect and process by law or that it needs in connection with its contracts with directors. The Company does not collect or process any other personal data. If the Company’s investment managers or other service providers use data relating to shareholders for other purposes (eg marketing), they become the data controllers for that data and are responsible for ensuring compliance with GDPR.
‍

‍Accuracy of data
‍
‍The Company aims to ensure that all personal data for which it is responsible is accurate and up to date. For this purpose, it obtains confirmations from its data processors that there are processes in place to ensure accuracy of the data held by them.
‍

‍Data retention
‍
‍All personal data held by the Company is subject to minimum retention periods laid down by law. Personal data is not retained beyond these statutory periods and the Company obtains confirmations from its data processors that this is the case.

‍Data security
‍
‍The Company places reliance upon its data processors to ensure security of personal data held by them on its behalf. It obtains confirmations from its data processors that data security arrangements are adequate.
‍

‍Breaches
‍
‍Under GDPR, any breaches of data security must be reported to the Information Commissioner’s Office within 72 hours and to the relevant data subjects if there is a high risk to their rights and freedoms. The Company places reliance upon its data processors to report any breaches of data security. It obtains confirmations from its data processors that their reporting procedures are adequate.
‍

‍Training
‍
‍Staff involved in the collection and processing of personal data needs training in their responsibilities under GDPR. Data processors are responsible for the training of their own staff.

‍Transfer outside the EU
‍
‍Under GDPR transfer of personal data outside the EU is illegal unless the European Commission has decided that the relevant jurisdiction provides equivalent protection or certain other conditions are met. Such transfers include the transfer of data by data processors to servers under their control but based outside the EU. The Company’s agreements with its data processors contain provisions restricting the transfer of personal data outside the EU, unless the Company has expressed its consent.
‍

‍Data processors
‍
‍The Company places reliance upon its data processors to ensure that data are processed in accordance with the principles established by GDPR. It also places reliance upon them to ensure that adequate records are kept and that systems exist for reporting data breaches and responding to data access requests.

The Company has entered into agreements with each of its data processors designed to ensure that the data held by them on behalf of the Company are dealt with correctly.
‍

‍Record keeping

‍The Company maintains records of all decisions made relating to data protection including all reports produced by data processors.