ACCO UK Privacy Policy

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1 ACCO UK Privacy Policy Updated on May 25, 2018 ACCO UK is committed to managing your privacy. We have developed this Privacy Policy to guide our organization and to inform you how we may collect, manage, and use information gathered from you, electronically and otherwise. It also covers how you may be able to manage this information. You can always reach us at with any questions about this policy, or about your information. What does this policy cover? This policy describes how ACCO UK Limited ( ACCO UK ) and other companies in ACCO UK s company group (also referred to as "ACCO Brands", "we" or "us") collect, use and share data you provide to us, when you interact with our business, employees or otherwise. It also describes your data protection rights, including a right to object to some of the processing that ACCO Brands carries out. More information about your rights, and how to exercise them, is provided in the What rights do I have? section. Please note that this policy does not apply to websites or other digital platforms on which a different privacy policy is posted. What information do we collect? We collect and process personal data about you when you communicate with our sales and customer service representatives, when you purchase goods and services from us or otherwise interact with our business or employees. The data we may collect or process includes: Full name; Business address, telephone number, and address; Job title, role, and department; Signature; Nationality; Credit limit information; Names of the shareholders or ultimate beneficial owners of your business; Names of the management of your business; Financial account details of your business; Tax identification or national ID number; Order details; or chat communications;

2 Copy of identification documents, such as a vehicle operating license or passport; Photographs from events; Areas of operation of your business; Industry of your business; Your marketing preferences, including any consents you have given us; and Any personal details you volunteer. What information do we receive from third parties? Sometimes, we receive information about you from third parties. In particular, sometimes our wholesalers may collect data from you and share it with us to ensure we are providing you with great customer service and support. How do we use this information, and what is the legal basis for this use? We process this personal data for the following purposes: To fulfil a contract, or take steps linked to a contract, in particular: o executing and performing a contract between you, or your company, and ACCO Brands; o verifying your identity; o taking or making payments; o processing orders; o communicating with you; o providing customer services and arranging the delivery or other provision of products, prizes or services; and o providing after-sales service and warranty coverage. As required by ACCO Brands to conduct our business and pursue our legitimate interests, in particular: o we use data to provide products and services you have requested and respond to any comments or complaints you may send us; o if you provide a credit or debit card as payment, we use third parties to check the validity of the sort code, account number and card number you submit in order to prevent fraud (see data sharing below);

3 o we monitor accounts to prevent, investigate and/or report fraud, terrorism, misrepresentation, security incidents or crime, in accordance with applicable law; o we use data you provide to investigate any complaints received from you or from others, about our company, products or services and to ensure the safety of our products; o we use data to pursue our intellectual property rights; o we use data to conduct our internal financial processes, such as internal accounting and payment of relevant taxes; o we use data to conduct credit risk assessments; o we use data in connection with legal claims, compliance, regulatory and investigative purposes as necessary (including disclosure of such information in connection with legal process or litigation); and o we use data of some individuals to invite them to take part in marketing or promotional programs. Where you give us consent: o we will send you direct marketing in relation to our relevant products and services, or other products and services provided by us, our affiliates and carefully selected partners; and o on other occasions where we ask you for consent, we will use the data for the purpose which we explain at that time. For purposes which are required by law: o responding to requests for a copy of your information, to correct it, erase or restrict its processing, or to ask us to transfer some of this information to other organisations; o in connection with legal claims, compliance, regulatory and investigative purposes as necessary (including disclosure of such information in connection with legal process or litigation); and o in response to requests by government or law enforcement authorities conducting an investigation under applicable laws.

4 Withdrawing consent or otherwise objecting to processing Wherever we rely on your consent, you will always be able to withdraw that consent, although we may have other legal grounds for processing your data for other purposes, such as those set out above. In some cases, we are able to send you direct marketing without your consent, where we rely on our legitimate interests. You have an absolute right to opt-out of direct marketing or profiling we carry out for direct marketing, at any time. You can do this by following the instructions in the communication where this is an electronic message, or by contacting us using the details set out below. In some cases, we use information you provide to conduct screening to ensure compliance with relevant laws. In these processes, names are screened against publicly available data to identify potential compliance risks, and where such a risk is identified, we may contact you to confirm that any such information is accurate or to provide additional information. Additionally, we use information you provide to conduct credit reference checks and other financial due diligence. To do so, we send basic information to a third party credit reference agency that collects a variety of metrics, such as registered capital, financial accounts, and payment history to determine relevant credit risks. Who will we share this data with, where and when? We may share your personal data with ACCO Brands group companies: to prevent, investigate and/or report fraud, terrorism, misrepresentation, security incidents or crime, in accordance with applicable law; to manage our accounts receivable function; to manager our customer loyalty program; to allow them market products that may be of interest to you; to investigate any complaints received from you or from others, about our company, products or services; and in connection with legal claims, compliance, regulatory and investigative purposes as necessary (including disclosure of such information in connection with legal process or litigation). We may share your data with the following third parties: third party service providers, who will process it on behalf of ACCO Brands for the purposes identified above, including:

5 o payment services providers, o compliance vendors, o suppliers, o couriers, o repair service providers, o sales agents, o warehousing, shipping, and other logistics companies, and o IT service providers; accountants, auditors, actuaries, lawyers, or other professional service providers, subject to the appropriate contractual safeguards, if mandated by law or if required for the legal protection of our legitimate interests in compliance with applicable laws; banks for payment processing as well as legal and regulatory compliance; credit reference agencies for credit reference checks; government authorities, parties, claimants, complainants, enquirers or law enforcement officials if required for the purposes above, if mandated by law or if required for the legal protection of our legitimate interests in compliance with applicable laws; and our advisers, prospective purchasers, and any prospective purchasers advisers, in the event that our business or assets are sold or integrated with another business. In such cases, your data may be passed onto the new entity. Because of the nature of our business, we may need to transfer data you provide to us to members of the ACCO Brands group or third parties located in countries that may have different laws and data protection compliance requirements, including countries whose privacy and data protection laws may be less comprehensive than those in your country. Where information is transferred outside the European Economic Area, and where this is to a country that is not subject to an adequacy decision by the European Union Commission, data will be adequately protected by EU Commission approved standard contractual clauses, an appropriate Privacy Shield certification or a vendor's Processor Binding Corporate Rules. A copy of the relevant mechanism can be provided for your review on request to DataPrivacy@acco.com.

6 What rights do I have? You have the right to ask us for a copy of your personal data; to correct, delete or restrict (stop any active) processing of your personal data; and to obtain the personal data you provide to us for a contract or with your consent in a structured, machine readable format, and to ask us to share (port) this data to another controller. In addition, you can object to the processing of your personal data in some circumstances (in particular, where we don t have to process the data to meet a contractual or other legal requirement, or where we are using the data for direct marketing). These rights may be limited, for example if fulfilling your request would reveal personal data about another person, or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. To exercise any of these rights, you can get in touch with us using the details set out below. If you have unresolved concerns, you have the right to complain to an EU data protection authority where you live, work or where you believe a breach may have occurred. With the exception of marketing preferences and personal details your volunteer, the provision of information identified above is necessary if relevant data is not provided, then we will not be able to provide you with the relevant products, services, payments or prizes. Marketing preferences and any other details you volunteer are voluntary. However, failure to provide that information may mean that we are unable to show you relevant products or promotions that may be of interest to you. How do I get in touch with you? We hope that we can satisfy queries you may have about the way we process your data. If you have any concerns about how we process your data, or would like to opt out of direct marketing, you can contact us at DataPrivacy@acco.com or by writing to the physical address of the controller listed below. Which ACCO Brands entity is my data controller, and which affiliates might my data be shared with? The data controller for your information is ACCO UK Limited Oxford House, Oxford Road, Aylesbury, Buckinghamshire, HP21 8SZ

7 Phone Number: A list of ACCO Brands group entities and their contact details can be found here. How long will you retain my data? We maintain and protect data for as long as necessary in connection with the purposes for which it was collected or otherwise lawfully processed, including as required by applicable laws and limitation periods. Where we process personal data for marketing purposes or with your consent, we process the data until you ask us to stop and for a short period after this (to allow us to implement your requests). We also keep a record of the fact that you have asked us not to send you direct marketing or to process your data indefinitely so that we can respect your request in future.

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