Last updated: July 2026

1. Important Notice
Siege FX understands that your privacy is important to you and that you care about how your personal data is
used. We take our data protection responsibilities seriously and respect the privacy of everyone who visits this
website, www.siegefx.com (“Our Site”), or engages with Siege through other means, including participants and
vendors interacting with Siege technology services (“Siege Platform”).

We collect and use your personal data only as described in this Privacy Policy and as permitted by Data
Protection Legislation. Please read this Privacy Policy carefully to ensure that you understand it.

2. Information About Us
Our Site is owned and operated by Siege FX Limited, a limited company registered in England & Wales under
company number 10569910, registered address: 8th Floor 71 Queen Victoria Street, London, England, EC4V
4AY.

3. What Does This Policy Cover?
This Privacy Policy applies to users of Our Site and the Siege Platform, so participants, prospective participants,
suppliers, business contacts, contractors, employees and website visitors. It explains how we process personal
data that we collect from you or a third party, or that you provide to us.

Our Site may contain links to other websites. Please note that We have no control over how your data is
collected, stored, or used by other websites and We advise you to check the privacy policies of any such
websites before providing any data to them.

4. What Is Personal Data?
Personal data is any information about you that enables you to be identified. Personal data covers obvious
information such as your name and contact details, but it also covers less obvious information such as
identification numbers, electronic location data, and other online identifiers. It does not include data where
the identity has been removed (anonymous data).

For the purposes of this Privacy Policy, “Data Protection Legislation” means the UK General Data Protection
Regulation (“UK GDPR”), the Data Protection Act 2018 (“DPA”), the Protection of Personal Information Act
(“POPIA”) and any other data protection legislation that may apply to our processing of personal data,
including the EU General Data Protection Regulation 2016/679 (the “EU GDPR”) (which We are also subject to
in relation to services we offer in the European Economic Area (EEA)).

5. What Are My Rights?
Under the Data Protection Legislation, you have the following rights, which We will always work to uphold:

● The right to be informed about our collection and use of your personal data. This Privacy Policy should
tell you everything you need to know, but you can always contact us to find out more or to ask any
questions using the details in Part 10.
● The right to access the personal data We hold about you. Part 9 will tell you how to do this.
● The right to have your personal data rectified if any of your personal data held by us is inaccurate or
incomplete. Please contact us using the details in Part 10 to find out more.
● The right to be forgotten, i.e., the right to ask us to delete or otherwise dispose of any of your
personal data that We process or control. Please contact us using the details in Part 10 to find out
more.
● The right to restrict (i.e., prevent) the processing of your personal data.
● The right to object to us using your personal data for a particular purpose or purposes.
The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for
using your personal data, you are free to withdraw that consent at any time.
● The right to data portability. This means that, if you have provided personal data to us directly, we are
using it with your consent or for the performance of a contract, and that data is processed using
automated means, you can ask us for a copy of that personal data to re-use with another service or
business in many cases.
● Rights relating to automated decision-making and profiling. We do not use your personal data in this
way.

For more information about our use of your personal data or exercising your rights as outlined above, please
contact us using the details provided in Part 10.

It is important that your personal data is kept accurate and up to date. If any of the personal data We hold
about you changes, please keep us informed as long as We have that data.
Further information about your rights can also be obtained from the Information Commissioner’s Office or
your local Citizens Advice Bureau.

If you have any cause for complaint about our use of your personal data, you have the right to lodge a
complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your
concerns ourselves, however, so please contact us first, using the details in Part 10.

6. What Personal Data Do You Collect and How?
Subject to the following, we collect limited personal data from you via our website and in the provision of
services to you (if applicable), and we may collect the following personal data about you:

● personal data you provide to us in person, via our website or by telephone, including the personal and
contact details you supply when requesting that we contact you in relation to a query. For example:
your first and last name; demographic data such as your gender, title, country and preferred
language; and log-in and account information for authentication purposes and account access.
● personal data gathered using cookies, server logs and other similar technologies, including: details of
your visits to our website including but not limited to traffic data, location data, weblogs and other
communication data. For more details on the specific cookies we use on our site, please visit our
Cookie Policy.
● information about your computer, including where available your IP address, operating system and
browser type, for system administration. This is statistical data about our users’ browsing actions and
patterns, and does not identify any individual;
● personal data you provide when:
   ○ you purchase our services, or we process orders and payment transactions;
   ○ you provide feedback about our services;
   ○ we conduct our administrative and business functions;
   ○ you request our marketing material or communication; and
   ○ there are communications between you and our representatives, or when you submit a
      query to us or which is collected via social media, or.
   ○ when we receive it from third parties such as analytics providers or publicly available sources
      such as LinkedIn.

We do not collect any Special Categories of personal data about you (this includes details about 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.

For the purposes of the Data Protection Legislation, we are the data controller responsible for the personal
data described above. As a controller we use (or “process”) the personal data we hold on you in accordance
with this Privacy Policy.

7. How Do You Use My Personal Data?
We may use your personal data for the purposes set out below, and for each use we have included the legal
basis for processing (what the law allows):

● To perform our contracts with you, including providing our services. This is necessary for the
performance of the contract, or before entering a contract.
● To comply with our own legal obligations e.g., health and safety legislation. This is necessary for
compliance with a legal obligation.
● To operate our business, other than performing our contractual obligations to you. These are our
‘legitimate interests’ for the purposes of Data Protection Legislation and include: dealing with your
enquiries, and sending requested information; dealing with job applications; developing, delivering
and improving our services; developing our website to be more useful to users, and to deal with any
misuse of our website; for internal research, analysis, testing and monitoring; risk management and
administrative purpose; assisting investigation of suspected illegal or wrongful activity (including
exchanging information with third parties for fraud protection and credit risk reduction); enforcing
our website terms, contract terms and other agreements with third parties. This is necessary for the
purposes of the legitimate interests pursued by us or by a third party.

Where we collect any personal data, it will be processed and stored securely, for no longer than is necessary in
light of the reason(s) for which it was first collected. We will comply with our obligations and safeguard your
rights under the Data Protection Legislation at all times. For more details on security see below.

We will keep your personal data while we are providing services to you. Thereafter, we will keep your personal
data for as long as is necessary: to respond to any questions, complaints or claims made by you or on your
behalf; to show that we treated you fairly; to keep records required by law.

Personal data is retained in accordance with Siege FX’s Record Retention Schedule. In certain circumstances,
retention periods may be extended where required for legal, regulatory, audit, litigation or contractual
purposes.

8. How and Where Do You Store My Data?
Your personal data may be transferred to other countries when it is shared with our group entities, it may also
be transferred, stored and/or processed outside the UK by our data processors. This is because the
organisations we use to provide some of our services to you are located in other countries.

We have taken appropriate steps to ensure that where personal data processed outside the UK, it has an
essentially equivalent level of protection as it has within the UK. We do this by ensuring that:

● your personal data is only processed in a country which the Secretary of State has confirmed has an
adequate level of protection (an ‘adequacy regulation’); or
● We enter into International Data Transfers Agreements (IDTAs) or Standard Contractual Clauses
(SCCs) or equivalent terms with the receiving organisations and ensure that supplementary measures
are also applied, where necessary.

9. Data Security
Siege FX maintains an information security management system and applies technical and organisational
measures including access controls, authentication controls, encryption and information classification
procedures designed to protect personal data.

Protecting personal data is essential to us. We take measures designed to prevent personal data from being
accidentally lost, used, accessed, altered or disclosed without authorisation, including:

● restricting access to personal data to employees, agents, contractors and other third parties who
need it for business purposes, and ensuring they process it only on our instructions and are subject to
confidentiality obligations; and
● maintaining procedures for responding to personal data breaches, including notifying you and/or the
Information Commissioner’s Office where required by law.

10. Do You Share My Personal Data?
We will not share any of your personal data with any third parties for any purposes, subject to the following
exceptions:

● selected third-party service providers to support our business operations, including providers of cloud
hosting, collaboration platforms, customer support systems, electronic signature services, identity
verification services and business administration systems;
● external professional advisers such as accountants, bankers, insurers, auditors and lawyers;
● our group companies and affiliates or other third-party data processors who process data on our
behalf.

If any of your personal data is transferred to a third party, as described above, 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.

If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third
party. Any new owner of our business may continue to use your personal data in the same way(s) that We
have used it, as specified in this Privacy Policy (i.e. to communicate with you).

In some limited circumstances, we may be legally required to share certain personal data, which might include
yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the
instructions of a government authority (including HMRC and our regulators).

11. How Can I Access My Personal Data?
You may request details of the personal data we hold about you and, where applicable, a copy of that data.
This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email or postal addresses shown below.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or
excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative
costs in responding.

We will respond to your subject access request within one month of receipt. We usually aim to provide a
complete response, including a copy of your personal data, within that period. If your request is complex, we
may need more time, up to a maximum of three months from the date we receive it, and we will keep you
informed of our progress.

12. How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject
access request, please put the request in writing to: support@siegefx.com

13. Changes to this Privacy Policy
We may change this Privacy Policy from time to time. This may be necessary, for example, if the law changes,
or if we change our business in a way that affects personal data protection.

Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the
Privacy Policy on your first use of Our Site or the Siege Platform following the alterations. We recommend that
you check this page regularly to keep up-to-date.