Impact Healthcare REIT plc (“we”, “our” or “Impact”) is committed to protecting the privacy of third parties (including its investors and all visitors to the website www.impactreit.uk (the “Website”)). Please read the following Privacy and Cookies Policy which explains how we use and protect your information.

We will only use information from which you can be identified (“Personal Information”) provided to us, or otherwise obtained by us, as set out in this Policy. We endeavour to ensure that your Personal Information is handled in accordance with “Data Protection Legislation”. References to “Data Protection Legislation” in this Policy mean any law applicable from time to time relating to the processing of personal data and/or privacy, as in force at the date of this Agreement or as re-enacted, applied, amended, superseded, repealed or consolidated, including without limitation, the UK Data Protection Act 1998, the General Data Protection Regulation (EU) 2016/679, and the Privacy and Electronic Communications (EC Directive) Regulations 2003, in each case including any legally binding regulations, direction and orders issued from time to time under or in connection with any such law.

By visiting and/or contacting us through the Website (or otherwise engaging with us), you acknowledge that we may collect, use and transfer your Personal Information as set out in this Policy. Impact reserves the right to change this Policy from time to time and you should therefore check this page frequently to ensure that you are happy with any changes.

In this Policy, “Impact”, “we”, “us” and “our”, refer to Impact Healthcare REIT plc, registered in England and Wales with registered office 7th Floor, 9 Berkeley Street, London W1J 8DW. Our company registration number is 10464966.

For the purposes of Data Protection Legislation, we are deemed to be the “data controller” in respect of any Personal Information that you provide to us or we otherwise obtain about you.

This Privacy and Cookie Policy covers:

When you engage with us (e.g. by visiting or making an enquiry through the Website), you may provide Personal Information about yourself including your name and contact details (e.g. your address, email address and telephone number). Where you make use of our Website we may also collect information about your use of the Website (e.g. your IP address and choice of web browser).

Some of this Personal Information is collected and processed so we can answer your enquiry, some for the purpose of legal compliance and some for the purposes of our legitimate business interests (namely to carry out and improve our business, analyse the use of our Website and services and support visitors to the Website).

We may receive information from third parties who collect Personal Information from you and pass it on to us. Where this is the case the third party is responsible for obtaining the relevant consents from you to ensure you are happy with the ways in which your Personal Information will be used.

We will only use your Personal Information in order to:

(a) supply the investment services or information you have requested and correspond with you,

(b) provide support to you in respect of these services,

(c) improve our Website and services, and

(d) for our internal business processes.

Where it is necessary to answer your enquiry or for our internal business processes, we may share your Personal Information with certain third parties such as our registrar, administrator, investment manager or investment adviser. By submitting your Personal Information to us, you agree to such third parties processing your information. Impact asks all third parties to treat your data securely and in accordance with this Privacy Policy, and will take reasonable steps to enforce this.

In addition, it may be necessary to disclose your Personal Information if we are under a duty to disclose your Personal Information in order to comply with any legal obligation (such as AML obligations), or protect the rights of Impact, Impact’s directors, employees or other personnel. This includes exchanging information with other companies and organisations for the purposes of fraud protection and prevention.

The Personal Information you provide to us will be transferred to and stored on our servers in [insert country where such servers will be hosted. Nb please contact Aaron Stocks if the servers are located outside the EEA] and we take steps to protect your Personal Information from unauthorised access and against unlawful processing, accidental loss, destruction and damage.

We will only keep your Personal Information for as long as we reasonably require and, in any event, only for as long as Data Protection Legislation allows.

Unfortunately, the transmission of information via the internet is not completely secure and, although we will take steps to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted via the Website; any transmission is therefore at your own risk.

In processing your Personal Information, it may be necessary for us to transfer your Personal Information outside the European Economic Area (“EEA”). It may also be accessed by staff operating outside the EEA who work for us or for one of our suppliers. This includes staff engaged in, among other things, the provision of support services to the Fund or the Website. We will take all steps reasonably necessary to ensure that your Personal Information is treated securely and in accordance with this Policy and Data Protection Legislation when it is processed in, or otherwise accessed from, a location outside the EEA. This means that we will only transfer your Personal Information to third parties outside the EEA if that third party (a) is situated in a country that has been confirmed by the European Commission to provide adequate protection to Personal Information, or (b) has agreed (by way of written contract) to provide all protections to your Personal Information as required by Data Protection Legislation. For the avoidance of doubt, in the event that the UK is no longer a part of the EEA, references in this paragraph to the EEA shall mean the EEA and/or the UK.

You have the right to see the Personal Information we hold about you and to ask us to:

(a) make any changes to ensure that any Personal Information we hold about you is accurate and up to date;

(b) erase or stop processing any Personal Information we hold about you where there is no longer a legal ground for us to hold it; or

(c) transfer any information we hold about you to a specified third party. If you wish to do this, please contact us using the contact details set out at section 10 below.

Should you have any queries or complaints in relation to how we use your Personal Information, please contact us using the details set out at section 10 below. Should you wish to take any complaints or queries further, you have the right to contact the Information Commissioner’s Office regarding such issues.

Our Website may, from time to time, contain links to and from third party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these websites or their related policies. Please check these policies before you submit any Personal Information via these websites.

A cookie is a small file that, if you consent to it, is sent to your browser from our web server and is stored on your computer. Cookies help us to analyse web traffic and identify which pages of our Website are being used. Our Website also uses cookies to respond to you as an individual so that it can tailor its operations to your needs by gathering and remembering information about your preferences. We only use this information for statistical analysis purposes and then the data is removed from our systems.

A cookie in no way gives us access to your computer or any information about you, other than information about how you use the Website and the data you choose to share with us (including data you automatically share with us by way of your browser settings).
In particular, we use the following cookies:

(a) Strictly necessary cookies. These are cookies that are required for the operation of our Website.

(b) Analytical/performance cookies. These cookies collect information about how visitors use our Website, for instance which pages visitors go to most often, and if they get error messages from web pages. Information collected by these cookies is aggregated and therefore anonymous. It is only used to improve how the Website works.

(c) Functionality cookies. These cookies are set by 3rd party services such as Investis Limited. Investis provide the share price and RNS feed.

You will normally see a message on our Website before we store a cookie on your computer which describes the types of cookies we use and what information they might collect. We may also use banners and pop-ups from time to time to give you options around cookies use.

You can also manage cookie use via your browser settings (this will allow you to refuse the setting of all or some cookies). Note, however, that if you block all cookies (including essential cookies) via your browser settings you may not be able to access all or parts of our Website.

You can find more information about the specific cookies we use and the purposes for which we use them in the table attached to this Policy. You can also find more information about cookies generally here: www.allaboutcookies.org.

Please note that third party providers may also use cookies to assess the ways in which you make use of their websites and we have no control over these.

The cookies we use on our website

Cookie nameDescription/purposeDuration

Performance cookies

We use Google Analytics on our website to collect information about visitor behaviour. We use this information to review the performance of the website and inform any decisions we make on future developments.

Google Analytics stores information about what pages you visit, how long you are on the site, how you got here and what you click on. This Analytics data is collected via a JavaScript tag in the pages of our site and is not tied to personally identifiable information. We therefore do not collect or store your personal information (eg your name or address). You may opt out of this tracking by disabling cookies within your browser.

_ga

Used to distinguish userstwo years

_gid

Used to distinguish users24 hours

_gat

Used to throttle request rate 1 minute

_dc_gtm_

If Google Analytics is deployed via Google Tag Manager1 minute

Functionality cookies

AWSELB

AWS Classic Load Balance Cookie used to map the session to the instance. Cookie set by 'ir.tools.investis.com’Removed after session with server closes

incap_ses_*

Incapsula DDoS Protectiona and Web Application Firewall:
The cookie on which HTTP requests are related to a certain session (AKA visit)
Re-opening the browser and accessing the same site is supposed to be considered as different visits. In order to maintain existing sessions. Cookie set by 'ir.tools.investis.com’
Removed after browser closes

nlbi_*

Incapsula DDoS Protectiona and Web Application Firewall:
Load balancing cookie to ensure requests by a client are sent to the same origin server. Cookie set by 'ir.tools.investis.com’
Removed after browser closes

visid_incap_*

Incapsula DDoS Protectiona and Web Application Firewall:
The cookie on which sessions are related to a specific visitor (visitor representing a specific computer) in order to identify clients which have already visited Incapsula. The only cookie that is persistent, for the duration of 12 months. Cookie set by 'ir.tools.investis.com’
12 months

Impact may amend this Policy at any time without notice. By continuing to use the Website and making use of our services you agree to the updated Policy. If you do not agree to any changes that we make, you should not use or access (or continue to use or access) the Website and/or our services. Any changes to this Policy will be posted on the Website.

If you have any questions (including relating to transfers of your Personal Information outside the EEA), please feel free to contact us by email at: info@impactreit.uk

Alternatively, you may call our team on +44 (0) 203 146 7100, Monday to Friday: 9am to 5pm.