Privacy and cookie policy

Last updated 28 January 2025

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ISLAND GREEN POWER UK LIMITED- Privacy Notice

This privacy notice describes how Island Green Power UK Limited’sgroup companies which includes Island Green Power Group Limited and IslandGreen Power UK Limited (also referred toas “IGP”, "we" or "us") will make useof your personal data.

This privacy notice explains how andwhy we collect, use and process personal data relating to individuals. This mayinclude, without limitation, visitors to our website; stakeholders orindividuals interested in our projects (including landowners or occupiers, landagents, statutory consultees and members of the community); business partners; suppliers;contractors; consultants; politicians and civil servants (also referred to as “you).

It also describes your data protectionrights, including a right to object to some of the processing which IGP carriesout. More information about your rights, and how to exercise them, is set outin Section 13 (“What rights you have?”).

IGP uses your personal data to send you: (i) informationabout working with us which you register to receive; (ii) to enable you togrant a lease of your land to one of our project companies (and ancillaryrights and obligations thereto) and/or to enable us to agree with you otherland related rights in connection with land in your ownership or occupation(collectively, the “Rights”) in relation to the development of a solarand/or battery storage project(s) (the “Projects”); (iii) manage ourrelationship with you where you act as, or on behalf of, a supplier,contractor, consultant or a customer, investor or business partner, which mayinclude but is not limited to procurement, due dligence and regulatory compliancecontract and purchase order management, making payments, , and communicationsrelating to services or orders; and (iv)to provide you with access to our website.

At IGP we take your privacy veryseriously and this privacy notice outlines how we will collect, hold andprocess your personal data under UK data protection laws, including the DataProtection Act 2018 and the UK General Data Protection Regulation (“DataProtection Legislation”).

1. Who weare

1.1 The legal entity responsible for the processingof your personal data is Island Green Power UK Limited, Unit 25.7 Coda Studios, 189 Munster Road, LondonSW6 6AW, company number 08615657 ICOregistration number ZB245796.

2. The data we collect about you and how wecollect it

2.1 We may collect, use, store and transferdifferent kinds of personal data about you when you interact with us and/or ourwebsite. The category of data we collect, hold and process will depend on ourrelationship with you, so not all categories included in the below table willapply to all individuals. Sometimes we may also receive personal data about youfrom third parties, including in connection with the development and operationof our Projects. For example, we engage land referencing agents in order toobtain the Rights required in order to deliver the Projects. They will contactyou on our behalf about a Project and enquire about any Rights or obligationsyou may have. They will then put you incontact with us to discuss the Project and share your details with us.

2.2 See further below:

Category of data

Examples may include

How do we collect this data

Identity Data

Information identifying who you are including:

· Name

· Date of birth

· Occupation

· Nationality

· Information relating to your family, solicitors and other related parties

· Information in relation to the entity through which you are engaging with us.

· Directly from you when you interact with us or our website

· From any of our communications consultants, environmental consultants, land agents, land referencers and/or from legal advisors, local councils, vetting providers, business partners, other statutory undertakers and public bodies across the United Kingdom [AG1]

Contact Data

Information we may use to contact you or for identity verification as part of anti-money laundering checks (including address, registered company address, telephone number and e-mail address).

· Directly from you when you interact with us or our website

Property Data

Information about property, property ownership, property occupation and/or other property interests (such as a mortgage) in connection with the development and operation of a Project.

· - Directly from you when you interact with us or our website

Business Data

Information about your businesses and business operations.

· Directly from you when you interact with us or our website

Consent Data

Your marketing preferences, including any consents you have given us.

· Directly from you when you interact with us or our website

· From any of our communications or marketing consultants

Device Data

Information related to the browser or device you use to access our website.

· Directly from you when you interact with us or our website.

Meeting Data

Information captured during meetings or interactions recorded by us including:

· Audio recordings

· Video recordings (including images)

· Transcriptions

· Artificial intelligence (“AI”) generated summaries

· Contributions via the chat function

· Content shared via screen and/or document sharing activity.

· Directly from you when you interact with us or attend a meeting with us either online or in person

· From a third-party who is hosting the meeting, in cooperation with us or on our behalf, or a meeting which we are also attending and where information may be shared with attendees.

Special Category Data [AG2]

· Directly from you when you interact with us or our website

· From legal advisors or external vetting provides or other third parties (see 2.4 below) who have your explicit consent to process such data.

· In general, we do not actively seek to collect or process Special Category Data (as defined under UK data protection laws) and we do not expect most interactions with you to involve such information. However, there may be limited circumstances where Special Category Data is provided to us or where its processing is necessary in connection with our Projects, legal obligations or our relationship with you. For example, individuals may voluntarily disclose information relating to health conditions, disabilities or other personal circumstances when responding to consultations or engaging with us in relation to a Project.

· Where we process Special Category Data, we will do so only where a valid condition for processing applies under applicable data protection legislation. Depending on the circumstances, this may include where:

§ you have provided your explicit consent;

§ processing is necessary to comply with our legal or regulatory obligations;

§ processing is necessary for reasons of substantial public interest;

§ processing is necessary for the establishment, exercise or defence of legal claims; or

§ another lawful condition under applicable data protection legislation applies.

· We will ensure that any Special Category Data is processed only where necessary, proportionately and subject to appropriate safeguards.

2.3 If you provide information to us about anyperson other than yourself, you must ensure that they understand how theirinformation will be used, and that they have given their permission for you todisclose it to us and to allow us, and our outsourced service providers, to useit.

2.4 We may also collect some of your informationfrom other third parties, including providers supporting supplier onboarding,verification and compliance checks, public records such as the Land Registry,Companies House, the electoral roll, Experian 192, the Charity Commission, theFinancial Conduct Authority, TraceIQ and the BT Directory, other similaraforementioned registries relevant in Scotland and Wales, online registries,websites of organisation and information which may be obtained from a generalinternet search or from other persons with a legal or beneficial interest inthe land. Please note that we may combine personal data we receive from othersources with personal data you give us and personal data we collect about you.

3. How do we use this information and what isthe legal basis for this use?

3.1 We process this personal data for the followingpurposes and relying on the legal bases identified:

Purpose

Categories of data

Lawful basis for processing

To verify your identity and communicate with you, including in relation to the Projects or a service or goods you are providing to us.

· Identity Data

· Contact Data

· Meeting Data

· Business Data

· Consent Data

· Property Data

· Special Category Data

In order to comply with our legal obligations, including to the extent applicable under the Planning Act 2008, the Town and Country Planning Act 1990, the Town and Country Planning (Scotland) Act 1997 (amended by the Planning (Scotland) Act 2019), Infrastructure (Wales) Act 2024, the Planning (Wales) Act 2015 and the Well-being of Future Generations (Wales) Act 2015 and associated and updated laws and regulations applicable to the United Kingdom.

We have a legitimate interest to use the personal data we collect to further engage with you in connection with the Projects.

To fulfil a contract or take steps linked to a contract: where you make an enquiry about leasing, selling or agreeing any other rights and/or obligations with respect to land that you own or occupy, such rights being in relation to one of our Projects, or where you wish to become an investor.

Consent where you subscribe to our communications: such as marketing emails, online feedback forms, newsletters and event notifications.

Where Special Category Data is processed, an appropriate condition under Article 9 UK GDPR and Schedule 1 Data Protection Act 2018 will apply.

To arrange and manage a lease, including payment and access to the land.

· Identity Data

· Contact Data

· Meeting Data

· Business Data

· Property Data

We have a legitimate interest to use the personal data we collect to further engage with you in connection with the Projects.

To facilitate our suppliers, consultants contractors, and business partners’ ability to carry out work for us, including but not limited to undertake due diligence and provide them with access to sites for surveys and other works.

· Identity Data

· Contact Data

· Meeting Data

· Business Data

· Special Category Data

To fulfil a contract entered into with our suppliers and contractors to complete works.

Where Special Category Data is processed, an appropriate condition under Article 9 UK GDPR and Schedule 1 Data Protection Act 2018 will apply.

To discuss funding for the Projects with you or discuss your interest in buying one of our Projects.

· Identity Data

· Contact Data

· Meeting Data

· Business Data

· Special Category Data

To pursue our legitimate interests of obtaining funding for Projects and communicating with potential buyers.

Where Special Category Data is processed, an appropriate condition under Article 9 UK GDPR and Schedule 1 Data Protection Act 2018 will apply.

To deliver the Projects and investor relations programme including: to carry out enquiries into land ownership and occupation, and land values / compensation; to survey land that may be affected by the Projects; to consult on the Projects; for the future development and implementation of the Projects; and respond to any comments or complaints you may send us.

· Identity Data

· Contact Data

· Meeting Data

· Business Data

· Property Data

· Special Category Data

To pursue our legitimate interest of managing our Projects and investor relations programme effectively and to further engage with you in connection with the Projects which includes: considering project related information obtained through land interest questionnaires, feedback and enquiries, including in-person at consultation events; responding to comments or complaints in a timely manner.

During consultation and stakeholder engagement activities, individuals may choose to provide information relating to health conditions, disabilities or other personal circumstances that are relevant to the Projects or to the assessment of potential impacts. Where Special Category Data is provided, we will process it only where a valid condition under applicable data protection legislation applies. This may include compliance with legal obligations arising from the planning process, reasons of substantial public interest, the assessment of equality impacts, the establishment or defence of legal claims, or where explicit consent has been obtained.

To monitor the use of our websites in order to improve and protect our Projects, investor relations programme and websites both online and offline. This includes the placing of cookies and use of similar technologies, see section 5 (“Information about our use of cookies”).

· Identity Data

· Device Data

· Consent Data

To pursue our legitimate interest of ensuring our website and programmes are running efficiently, to help provide you with the most convenient browsing experience we can and to improve these based on current use.

Consent.

To provide a personalised website for you.

· Identity Data

· Device Data

· Consent Data

To pursue our legitimate interest of providing a tailored experience on our website to enhance your visit.

To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceedings in which personal data is held by us in connection with such assets.

· Identity Data

· Contact Data

· Meeting Data

· Business Data

· Special Category Data

To pursue our legitimate interest of ensuring a seamless business transfer or evaluation of a potential business transfer.

Where Special Category Data is processed, an appropriate condition under Article 9 UK GDPR and Schedule 1 Data Protection Act 2018 will apply.

For the purpose of offering to obtain Rights, legal claims, compliance, regulatory and investigative purposes as necessary (including disclosure of such information in connection with legal process or litigation) including supplier due diligence, verification and governance requirement such as anti-money laundering (AML) and persons with significant control (PSC) checks.

· Identity Data

· Contact Data

· Meeting Data

· Business Data

· Special Category Data

To pursue our legitimate interest, including to conduct our business, or if required for the legal protection of our legitimate interests and compliance with our legal obligations, such as anti-money laundering regulations.

In limited circumstances, we may process personal data contained within identity documents for identity verification, anti-money laundering, sanctions screening, fraud prevention and other legal and regulatory compliance purposes. Such processing will only be undertaken where permitted by applicable law and subject to appropriate safeguards.

Where Special Category Data is processed, an appropriate condition under Article 9 UK GDPR and Schedule 1 Data Protection Act 2018 will apply.

To record, summarise and analyse meetings or interactions using AI systems such as Fathom AI.

· Identity Data

· Contact Data

· Meeting Data

· Business Data

· Consent Data

· Special Category Data

· Property Data

To pursue our legitimate interests of improving service quality, recording-keeping, and team collaboration, including: making internal operational improvements; improving quality assurance; enhancing customer or partner interactions; and providing employees and stakeholders with detailed and accurate records of meetings for better decision-making and project management.

Participants should avoid sharing Special Category Data during meetings unless it is necessary for the purpose of the discussion. Where such information is disclosed, it will only be processed where a valid condition under applicable data protection legislation applies and will be subject to appropriate safeguards.

To send you direct marketing in relation to our Projects, including investor materials.

· Identity Data

· Contact Data

· Business Data

· Consent Data

· Device Data

Consent.

In order to respond to requests by government or law enforcement authorities conducting an investigation or a freedom of information request.

· Identity Data

· Contact Data

· Meeting Data

· Business Data

· Consent Data

· Special Category Data

· Property Data

In order to comply with our legal obligations.

3.2 We have carried out balancing tests for all thedata processing we carry out on the basis of our legitimate interests, which wehave described above. You can obtain information on any of our balancing testsby contacting us using the details set out at section 15 (“Contacting us”).

3.3 Wherever we rely on your consent, you willalways be able to withdraw that consent, although we may have other legalgrounds for processing your data for other purposes, such as those set outabove. In some cases, we are able to send you direct marketing without yourconsent, where we rely on our legitimate interests. You have an absolute right to opt-out ofdirect 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 isan electronic message, or by contacting us using the details set out at section15 (“Contacting us”)..

3.4 We will only use your personal data for thepurpose for which it is collected, unless we reasonably consider that we needto use it for another reason and that reason is compatible with the originalpurpose. If we need to use your personal data for an unrelated purpose, we willnotify you and explain the legal basis which allows us to do so.

4. Use of AI technology

4.1 From time to time, we may process your personaldata using AI and other similar technology. This could include generativeartificial intelligence (also known as “GenAI”) serviced by third partyproviders to better manage risks and improve the quality of efficiency of ourservices (e.g. Fathom AI).

4.2 Should you wish to object to the use of FathomAI, you can ask the meeting host not to enable recording or transcription.Objections will be considered by us but may not always be accepted, dependingon the circumstances of the meeting. We will provide details of the appropriatereasons for recording or transcription in response to any objections. You maychoose to keep/turn off your microphone or camera, or leave the meeting at anypoint, but this may result in you not being able to participate fully in ameeting or event.

4.3 Where we use any other AI systems, we willensure such uses are properly validated, and would be used fairly, ethnicallyand with appropriate human oversight of the decision-making process. If the relevantindividuals do not wish for personal data to be processed via BDAI (big data analyticsand artificial intelligence) tools, please contact us using the details set outat section 15 (“Contacting us”).

5. Who will we share your data with, where andwhen?

5.1 We may share your data with professional advisorsand external technical consultants (including communications consultants,environmental consultants, land agents and land referencers and our legaladvisors) in order to apply for planning permission and grid connection,conduct surveys and review the Rights, undertake vetting or audits. We may share your data with our joint venturecompanies and other companies in the IGP group.

5.2 Personal data may be shared with governmentand/or local authorities and/or law enforcement officials if required for thepurposes above, if mandated or permitted by law or if required for the legalprotection of our legitimate interests in compliance with applicable laws.

5.3 Personal data may also be shared with ouroutsourced third-party service providers, who will process it on behalf of IGPfor the purposes identified above. This may include third party providerssupporting procurement activities, supplier vetting and onboarding, paymentprocessing and compliance requirements.
In particular:

· Personal data, including information capturedduring recorded meetings or interactions, may be shared with Fathom AI, a thirdparty service provider, for the purpose of generating meeting summaries. We mayalso share personal data recorded in such meetings with other parties who mightreasonably require the data such as with other companies in the IGP groupFathom AI process this data on our behalf under appropriate data protectionagreements;

· Third party providers of website hosting/maintenance,IT services and support, data storage solutions, accounting and paymentsoftware such as Netsuites, and identity checking such as Ethixbase360 [PM3] .

· In the event that the business is sold orintegrated with another business your details will be disclosed to our advisersand any prospective purchaser’s adviser and will be passed to the new owners ofthe business.

5.4 We will not rent or sell your information tothird parties without your consent.

6. How we store information andinternational transfers

6.1 In general, the personal data that we collectfrom you will be stored at a destination within the UK or European EconomicArea (“EEA”). However, we may also transfer your data outside the UK orEEA, if stored on external platforms.

6.2 Please note that some countries outside of theUK or EEA have a lower standard of protection for personal data, includinglower security requirements and fewer rights for individuals. Where yourpersonal data is transferred, stored and/or otherwise processed outside the UKor EEA, we will take all reasonable steps to ensure that your personal data istreated securely and in accordance with this notice. When personal data istransferred internationally to a country that is not deemed adequate by theEuropean Commission or the UK Secretary of State, we will rely on acceptableand defined legal mechanisms such as using standard contractual clauses whichhave been approved by the European Commission or the UK Government.

7. Data security

7.1 We take care to ensure the security of yourpersonal data in use, storage and transmission and that it is only accessed byverified persons who have the necessary authority. All of our personnel whohave access to personal data are legally and contractually obliged to respectthe confidentiality of this information and we deliver training to ensure thisis maintained.

7.2 We have in place appropriate policies, rules andtechnical and organisational measures to protect your personal data fromunauthorised or unlawful processing, and against accidental loss, destructionor damage.

8. Retention of personal data

8.1 We will retain your personal data only for aslong as we need it for the purposes set out in this notice, except incircumstances where we need to retain it for longer to comply with legalobligations or to progress legal claims. At the end of the retention period, wewill take steps to delete your personal data or hold it in a form that nolonger identifies you.

8.2 Where we process personal data for marketingpurposes or with your consent, we process the data until you ask us to stop andfor a short period after this (to allow us to implement your requests). We alsokeep a record of the fact that you have asked us not to send you directmarketing or to process your data so that we can respect your request infuture.

8.3 Where we process personal data in connectionwith supplier and contractor relationships, including onboarding, procurement,contract management, payments and compliance activities, we will retain suchdata for as long as necessary to manage the business relationship, comply withlegal and regulatory obligations and resolve disputes, typically for up to sixyears after the end of the relationship.

9. What rights you have

9.1 You have a number of rights under the DataProtection Legislation in relation to the way we process your personal data,which are set out below. You may contact us using the details at the end ofthis privacy notice to exercise any of these rights.

9.2 You have the following rights:

Right

Description

To be informed

A right to be informed about the personal data we hold about you.

Of access

A right to access the personal data we hold about you.

To rectification

A right to require us to rectify any inaccurate personal data we hold about you.

To erasure

A right to ask us to delete the personal data we hold about you. This right will only apply where (for example):

· we no longer need to use the personal information to achieve the purpose we collected it for;

· where you withdraw your consent if we are using your personal data based on your consent; or

where you object to the way we process your data.

To restrict processing

In certain circumstances, a right to restrict our processing of the personal data we hold about you. This right will only apply where (for example):

· you dispute the accuracy of the personal data held by us;

· where you would have the right to ask us to delete the personal data but would prefer that our processing is restricted instead; or

where we no longer need to use the personal data to achieve the purpose we collected it for, but you need the data for the purposes of establishing, exercising or defending legal claims.

To data portability

In certain circumstances, a right to receive the personal data you have given us, in a structured, commonly used and machine readable format. You also have the right to require us to transfer this personal data to another organisation, at your request.

In relation to automated decision making and profiling

A right for you not to be subject to a decision based solely on an automated process, including profiling, which produces legal effects concerning you or similarly significantly affect you. We do not carry out any automated processing or profiling.

To withdraw

A right to withdraw your consent, where we are relying on it to use your personal data (for example, to provide you with brochures and newsletters).

9.3 You also have the right to object to processingof your personal data as follows:

· If processing of your personal data is basedon it being necessary to comply with a legal obligation or for legitimateinterests, you have the right to object, on grounds relating to your particularsituation, at any time to the processing of your personal data.

· Where your personal data is processed fordirect marketing purposes, you have the right to object at any time to theprocessing of personal data about you for such marketing.

9.4 There may be conditions or limitations on theserights. It is therefore not certain for example that you have the right of dataportability in every case - this depends on the specific circumstances of theprocessing activity.

9.5 If you have any concerns regarding ourprocessing of your personal data or are not satisfied with our handing of anyrequest made by you, or would otherwise like to make a complaint, pleasecontact IGP in the first instance using the details set out at section 15(“Contacting us”), so that we can do our very best to sort out the problem.

9.6 You have the right to make a complaint at anytime to the Information Commissioner’s Office (ICO), the UK supervisoryauthority for data protection issues. The ICO can be contacted by telephone on0303 123 1113; by post as follows: Information Commissioner’s Office, WycliffeHouse, Water Lane, Wilmslow, Cheshire, SK9 5AF; or via email at casework@ico.org.uk.

Ifyou are based in the EU,[MM4] [AG5] this linkcontains a comprehensive list of all data protection regulators in the EU andtheir contact details. If you are based in the rest of the world, please referto the website of your local data protection regulator for their contactdetails.

10. Changes to this privacy notice

We will keep thisnotice under regular review. Any changes we make to this notice in the futurewill be posted on this page.

11. Contacting us[PM6]

If you have any queries, comments orrequests regarding this notice or you would like to exercise any of your rightsset out above, you can contact us as follows:

by post to Unit 25.7 Coda Studios,189 Munster Road, London SW6 6AW; or

by email to compliance@islandgp.com[AG7]

[AG1]addedbusiness partners and vetting providers - copy below

[AG2]Ingeneral, whilst we will not proactively process sensitive or special categorydata (as defined in Data Protection Legislation) about you, and we do notexpect that our interactions with you will include any Special Category Data,there may be very limited circumstances in which we process such data where itis strictly necessary. This includes, in specific cases involving sensitivetransactions, the processing of biometric data (such as biometric informationcontained in passports or other identity documents) solely for the purposes ofidentity verification and compliance with applicable anti-money laundering andcounter-terrorist financing obligations. We may also use any SpecialCategory Data you provide us with to develop our Projects, manageour relationship with you or for the purposes of undertaking any environmentalor equality impact assessments relating to the Projects.

If you voluntarily disclose such or any other SpecialCategory Data, we shall treat your disclosure as your explicit consent for usto process that data. Special Category Data is sensitive information relatingto you (such as your health and medical conditions) and is afforded greaterprotection under Data Protection Legislation given its sensitive nature. Exceptwhere required for identity verification and legal compliance as describedabove, it is completely optional for you to provide such information whenengaging with us. Where the processing is necessary for the purposes ofcarrying out our legal and regulatory obligations required byRegulation 5(2)(5) of the Infrastructure Planning (Applications: PrescribedForms and Procedure) Regulations 2009 we may rely on a legal basis to processSpecial Category Data.

[PM3]ForIGP: As per regulator guidance, this should be as specific as possible e.g.AWS, hubspot, paypal etc as suppliers.

[MM4]ForIGP: Given the references to the Spanish and Bermuda companies above anddepending on your intention as to whether this is intended to be a Group-levelor a UK focussed privacy notice, is there a need to include references to EUauthorities / rest of world?

[AG5]Yesas we may process personal data of EU nationals

[PM6]ForIGP: Please review these contact details to ensure they remain accurate.

[AG7]whoreceives this - should it not be compliance?