Privacy Notice

PENSIONS WEBSITE PRIVACY NOTICE

We respect the privacy of every person who visits or registers with or submits personal information through our website at howdenjoineryaescheme.co.uk (the "Website") and who uses the information that we provide on the Website ("Services"), and we are committed to ensuring a safe online experience.

1 Purpose of this privacy notice

This Privacy Notice ("Privacy Notice") explains our approach to any personal information that we might collect from you or which we have obtained about you from a third party and the purposes for which we process your personal information. This Privacy Notice also sets out your rights in respect of our processing of your personal information.

2 About Us

The Website is made available by Howden Joinery Limited ("Howdens"). Howdens is the data controller responsible for your personal information. Howdens Joinery Limited is a private limited company registered in England under registration number 00526923 with registered offices at 105 Wigmore Street, London, England, W1U 1QY

Howdens is registered as a data controller with the UK's Information Commissioner's Office under registration number Z6174295.

3 How to contact us about data protection

If you have any questions about this Privacy Notice or if you want to exercise your rights set out in this Privacy Notice, please email pensions@howdens.com or contact Shromi Jeyakumar Nilam Gardiner.

Alternatively you may write to Nilam or Shromi at Howden Joinery Pensions, 105 Wigmore Street, London, W1U 1QY.

4 Personal information we collect and how we use it

Our primary reasons for collecting personal information from you is to: (i) provide our Services to you; (ii) verify your identity (where applicable); (iii) help us improve our Website and our Services; (iv) carry out requests made by you on the Website; (v) investigate or settle enquiries or disputes; (vi) comply with applicable law, court order, other judicial process and the requirements of regulators; (vii) protect the rights, property and safety of us or third parties, including our other investors and users of the Website; (viii) provide support for the provision of our products and services; and (ix) use as otherwise required or permitted by law.

In particular, we use your personal information for the following purposes:

  • General enquiries. Our Website uses various user interfaces to allow you to request information about our Website and Services. Our enquiry services are accessible by email, post and telephone. When making an enquiry, the enquirer's name and contact information (including email address, postal address, telephone number) may be requested, together with details of other personal information that is relevant to the enquiry. This information is used to enable us to manage and respond to your enquiries and requests.

Who do we share your personal information with for this purpose?

We do not share your personal information for this purpose.

What is our legal basis?

It is in our legitimate interest to use your personal information in such a way to ensure that we provide good customer service to you.

  • Business administration and legal compliance. We use your personal information for the following business administration and legal compliance purposes:
    • to comply with our legal obligations;
    • to enforce our legal rights;
    • to protect the rights of third parties; and
    • in connection with a business transition such as a merger, reorganisation, acquisition by another company, or sale of all or a portion of our assets.

Who do we share your personal information with for these purposes?

We will share your personal information with professional advisers such as lawyers, accountants, registrars and/or governmental or regulatory authorities.

We may also share personal information with other entities within the Howdens group of companies for these purposes.

What is our legal basis?

Where we use your personal information in connection with a business transition, to enforce our legal rights or to protect the rights of third parties, it is in our legitimate interest to do so. For all other purposes described in this section, it is our legal obligation to use your personal information to comply with any legal obligations imposed upon us such as a court order.

We will not process any special (or sensitive) categories of personal information or personal information relating to criminal convictions or offences except where we are able to do so under applicable legislation or with your explicit consent.

  • Any other purposes for which we wish to use your personal information that are not listed above, or any other changes we propose to make to the existing purposes, will be notified to you using your contact details.

5 How we obtain your consent

Where our use of your personal information requires your consent, you can provide such consent:

  • at the time we collect your personal information following the instructions provided; or
  • by informing us by email, post or telephone using the contact details set out in the "How to contact us about data protection" section above.

6 Our use of cookies and similar technologies

Our Website may use certain cookies, web beacons, pixel tags, log files and other technologies. Please see our insert link to cookie policy to find out more about the cookies and other technologies we use, the purposes for which we use them and how to manage, block or delete them.

7 Third party links and services

Our Website may contain links to third party websites and services. When you use a link to go from our Website to another website or you request a service from a third party, this Privacy Notice no longer applies.

browsing and interaction on any other websites, or your dealings with any other third party service provider, is subject to that website's or third party service provider's own rules and policies.

We do not monitor, control or endorse the privacy practices of any third parties.

We encourage you to become familiar with the privacy practices of every website you visit or third party service provider that you deal with and to contact them if you have any questions about their respective privacy notices and practices.

This Privacy Notice applies solely to personal information collected by us through our Site and/or the supply of our products and services and does not apply to these third party websites and third party service providers.

8 Transfers outside the EEA

We do not transfer your personal data outside the European Economic Area.

9 How long we keep your personal information

We will keep your personal data for as long as we need it for the purpose it is being processed for. For example, where you sign up to our Investor Alert emails, will keep your contact details for as long as you wish to receive such alerts and after that, we will keep the information for a period which enables us to handle or respond to any complaints, queries or concerns relating to either the Investor Alerts and/or any other provision of the Services. We may then destroy such files without further notice or liability.

If you have opted out of receiving marketing communications from us, we will need to retain certain personal information indefinitely so we do not send you marketing communications again.

10 Confidentiality and security of your personal information

We are committed to keeping the personal information you provide to us secure and we will take reasonable precautions to protect your personal information from loss, misuse or alteration.

We have implemented information security policies, rules and technical measures to protect the personal information that we have under our control from:

  • unauthorised access;
  • improper use or disclosure;
  • unauthorised modification; and
  • unlawful destruction or accidental loss.

All our employees and data processors (i.e. those who process your personal information on our behalf, for the purposes listed above) who have access to and are associated with the processing of personal information are obliged to respect the confidentiality of the personal information of all users of our Website and our Services.

11 How to access your information and your other rights

You have the following rights in relation to the personal information we hold about you:

  • Your right of access. If you ask us, we will confirm whether we are processing your personal information and, if so, provide you with a copy of that personal information (along with certain other details). If you require additional copies, we may charge a reasonable fee for producing those additional copies.
  • Your right to rectification. If the personal information we hold about you is inaccurate or incomplete, you are entitled to have it rectified. If we have shared your personal information with others, we'll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we will also tell you who we've shared your personal information with so that you can contact them directly.
  • Your right to erasure. You can ask us to delete or remove your personal information in some circumstances, such as where we no longer need it or where you withdraw your consent (where applicable). If we have shared your personal information with others, we will let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we will also tell you who we have shared your personal information with so that you can contact them directly.
  • Your right to restrict processing. You can ask us to block or suppress the processing of your personal information in certain circumstances, such as where you contest the accuracy of that personal information or you object to us processing it. It won't stop us from storing your personal information, though. We will tell you before we lift any restriction. If we have shared your personal information with others, we will let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we will also tell you who we have shared your personal information with so that you can contact them directly.
  • Your right to data portability. You have the right, in certain circumstances, to obtain personal information you have provided to us (in a structured, commonly used and machine readable format) and to reuse it elsewhere or to ask us to transfer it to a third party of your choice.
  • Your right to object. You can ask us to stop processing your personal information, and we will do so, if we are:
    • relying on our own or someone else's legitimate interest to process your personal information, except if we can demonstrate compelling legal grounds for the processing; or
    • processing your personal information for the purposes of direct marketing.
  • Your rights in relation to automated decision-making and profiling. You have the right not to be subject to a decision when it is based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for the entering into, or the performance of, a contract between you and us.
  • Your right to withdraw consent. If we rely on your consent (or explicit consent) as our legal basis for processing your personal information, you have the right to withdraw that consent at any time. You can exercise your right of withdrawal by contacting us using our contact details in the “How to contact us about data protection” section above or by using any other opt-out mechanism we may provide, such as an unsubscribe link in an email.
  • Your right to lodge a complaint with the supervisory authority. If you have a concern about any aspect of our privacy practices, including the way we have handled your personal data, you can complain directly to us. Please contact us using the contact details provided in the “How to contact us about data protection” section. You can also report any issues or concerns to a national supervisory authority in the Member State of your residence or the place of the alleged infringement.

12 Changes to this Privacy Notice

We may make changes to this Privacy Notice from time to time. To ensure that you are always aware of how we use your personal information we will update this Privacy Notice from time to time to reflect any changes to our use of your personal information. We may also make changes as required to comply with changes in applicable law or regulatory requirements. We will notify you by email of any significant changes. However, we encourage you to review this Privacy Notice periodically to be informed of how we use your personal information.

Version: 1
Last Updated: 16 June 2026