This privacy policy (“Privacy Policy”) 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 Policy also sets out your rights in respect of our processing of your personal information. This Privacy Policy will inform you of the nature of the personal information about you that is processed by us and how you can request that we delete, update, transfer, and/or provide you with access to it. This Privacy Policy is intended to assist you in making informed decisions when using our website. Please take a moment to read and understand it. Please also note that this Privacy Policy only applies to the use of your personal information obtained by us, it does not apply to your personal information collected during your communications with third parties.

Snowball Impact Management Limited is a ‘controller’ for the purposes of the General Data Protection Regulation 2016/679 (“GDPR”). Snowball Impact Management Limited (registered in England with registered office address at 20 Little Britain, London, EC1A 7DH and company no. 12487802) is authorised and regulated by the Financial Conduct Authority (FRN948779). If you have any questions or concerns about this privacy policy then please contact hello@snowball.im

The Types of Information We Collect. Through our website, we may collect the following personal data: Contact information, including but not limited to name, email address and postcode; Information about your business role; Your country of residence; Technical details of your visits to our website and your computer and browser settings; and Any other personal data provided to us. In particular, we use your personal information for the following purposes: Enquiries via our Site. Our Site features a “Invest” page which invites you to submit general enquiries. We collect the personal data you submit to us when making your enquiry. Where you are a prospective client, we may use personal information that you voluntarily submit to us to prepare proposals for your purchase of our Services, to contact you, or otherwise to manage or administer our relationship with you. Who do we share your personal information with for this purpose? We do not actively share your personal information with any third parties, but we do store your data using secure third party servers based in the cloud. 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 the very best client service we can to you. We may analyse your activity and interactions with the Site. We do this to help us to improve our own Site (as a controller), or as part of the services we provide to our clients (as a processor). Where we process your user data as part of the services we provide to clients, this allows us to advise them on key analytics relating to their websites and apps. This helps our clients tailor projects for your benefit. Where you have given your consent (where lawfully required), we may use cookies, log files and other technologies to collect personal information in this way. This may include the following: An IP address to monitor traffic and volume on the Site; A session ID to track usage statistics on the Site; or Our Site and emails may contain cookies, web beacons and pixel tags (“Tags”). Tags allow us to track receipt of an email to you, to count users that have visited a web page or opened an email and collect other types of aggregate information. Once you click on an email that contains a Tag, your contact information may subsequently be cross-referenced to the source e-mail and the relevant Tag. In some of our email messages, we use a “click-through URL” linked to certain websites administered by us, or on our behalf. We may track click-through data to assist in determining interest in particular topics and measure the effectiveness of these communications. By using this information, we are able to measure the effectiveness of content and how visitors use our Site and Services. This allows us to learn what pages of the Site are most attractive to visitors, which parts are the most interesting. User insight and analysis. We may analyse your activity and interactions with the Site. We do this to help us to improve our own Site (as a controller), or as part of the services we provide to our clients (as a processor). Where we process your user data as part of the services we provide to clients, this allows us to advise them on key analytics relating to their websites and apps. This helps our clients tailor projects for your benefit. Where you have given your consent (where lawfully required), we may use cookies, log files and other technologies to collect personal information in this way. This may include the following: An IP address to monitor traffic and volume on the Site; A session ID to track usage statistics on the Site; or Our Site and emails may contain cookies, web beacons and pixel tags (“Tags”). Tags allow us to track receipt of an email to you, to count users that have visited a web page or opened an email and collect other types of aggregate information. Once you click on an email that contains a Tag, your contact information may subsequently be cross-referenced to the source e-mail and the relevant Tag. In some of our email messages, we use a “click-through URL” linked to certain websites administered by us, or on our behalf. We may track click-through data to assist in determining interest in particular topics and measure the effectiveness of these communications. By using this information, we are able to measure the effectiveness of content and how visitors use our Site and Services. This allows us to learn what pages of the Site are most attractive to visitors, which parts are the most interesting. What are cookies? Cookies are text files placed on your computer to collect standard Internet log information and visitor behaviour information. When you visit our websites, we may collect information from you automatically through cookies or similar technology. For further information, visit allaboutcookies.org. How do we use cookies? Our Company uses cookies in a range of ways to improve your experience on our website, including: Understanding how you use our website. What type of cookies do we use? There are a number of different types of cookies, however, our website uses: Functionality – Our Company uses these cookies so that we recognise you on our website and remember your previously selected preferences. These could include what language you prefer, and location you are in, or simply whether you have accepted terms on a website. Advertising – Our Company uses these cookies to collect information about your visit to our website, the content you viewed, the links you followed and information about your browser, device, and your IP address. How to manage cookies? You can set your browser not to accept cookies, and the allaboutcookies.org website tells you how to remove cookies from your browser. However, in a few cases, some of our website features may not function as a result. Who do we share your personal information with for these purposes? We share your personal information with a variety of third party service providers to assist us with user insight analytics. What is our legal basis? Where your personal information is completely anonymised, we do not require a legal basis to use it as the information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymised personal information may be subject to other laws where your consent is required. Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information in such a way to ensure that we provide the very best services to you and our other customers. We will only use your location data for user insight purposes where we have your consent to do so. Marketing communications. We carry out the following marketing activities using your personal information: Email marketing. We may use your personal information to send you marketing communications by email, where you have consented to receive such marketing communications, or where we have another lawful basis to do so. Please let us know if you would like to be added or removed from our mailing list by emailing us on: hello@snowbal.im Sometimes, as part of the services we are engaged to provide to clients, we advise them on (a) how to capture and store user data from their websites and apps, and (b) how to use this user data to inform their email marketing strategy. We process your personal information in these circumstances as a processor (not a controller). Who do we share your personal information with for these purposes? We share your personal information with a selection of third party email marketing providers who assist us in delivering our email marketing campaigns to you. What is our legal basis? Where your personal information is completely anonymised, we do not require a legal basis to use it as the personal information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymised personal information may be subject to other laws where your consent is required. Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information for marketing purposes. We will only send you marketing communications via email where you have consented to receive such marketing communications, or where we have a lawful right to do so. Recruitment. We use your personal information for recruitment purposes, in particular, to assess your suitability for any position for which you may apply for with us, whether such application has been received by us online, by email or by hard copy and whether submitted directly by you or by a third party recruitment agency on your behalf. We also use your personal information to communicate with you about the recruitment process, to keep records about our recruitment process and to comply with our legal and regulatory obligations in relation to recruitment. We may process any personal information about you that you volunteer when you apply for a job with us. We may also process your personal information obtained from any third parties we work with in relation to our recruitment activities, including without limitation, recruitment agencies, background check providers, credit reference agencies, your referees and the Disclosure and Barring Service (if applicable). The personal information we process may include your name and contact information (e.g. email address, postal address, telephone number), personal information concerning your education, qualifications and employment history, and any other personal information which appears in your curriculum vitae and cover letter, which you volunteer in an application form or during an interview or which is contained in any reference we receive about you. Such information may also include special categories of personal information (such as information about your health, any medical conditions and your health and sickness records), and information relating to criminal convictions and offences if that information is relevant to the role you are applying for. We also use your personal information for the purposes of reviewing our equal opportunity profile in accordance with applicable legislation. We do not discriminate on the grounds of gender, race, ethnic origin, age, religion, sexual orientation, disability or any other basis covered by local legislation. All employment-related decisions are made entirely on merit. Who do we share your personal information with for these purposes? We may share your personal information with external recruiters or third parties who provide background checks. We may also share your personal information with third parties who assist us with the recruitment process. What is our legal basis? Where we use your personal information in connection with recruitment, it will be in connection with us taking steps at your request to enter into a contract we may have with you or it is in our legitimate interest to use personal information in such a way to ensure that we can make appropriate and informed recruitment decisions. 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. 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; protect rights of third parties; Who do we share your personal information with for these purposes? We may share your personal information with professional advisers such as lawyers and accountants and/or governmental or regulatory authorities. What is our legal basis? Where we use your personal information in connection with a business transition, 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. How do 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; or by informing us by email, post or phone using the Contact Details set out in this Privacy Policy. Third Party Links and Services. Our Site may contain links to third party websites and services. Please remember that when you use a link to go from our Site to another website or you request a service from a third party, this Privacy Policy no longer applies. Where you have given your consent (where lawfully required), we may use cookies, log files and other technologies to collect personal information in this way. This may include the following: Your 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 linked to our Site. 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 policies and practices. This Privacy Policy applies solely to personal information collected by us through our Service and does not apply to these third party websites and third party service providers. How long do we keep your personal information for? We keep your personal information indefinitely so that we have a record of requests you have made in the past e.g. requests for information in relation to our Services. It is also important for us to maintain a record of your personal information in the event that you have asked us to no longer contact you. If your information is only useful for a short period e.g. for hiring periods, we may delete it. 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 of 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 Services.

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’ll confirm whether we’re 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 need to charge a reasonable fee. With effect from 25 May 2018, you have the right, in certain circumstances, to obtain personal information you’ve provided us with (in a structured, commonly used and machine readable format) and to reuse it elsewhere or to ask us to transfer this to a third party of your choice. Your right to rectification. If the personal information we hold about you is inaccurate or incomplete, you’re entitled to have it rectified. If we’ve 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’ll also tell you who we’ve shared your personal information with so that you can contact them directly. Your right to erasure, or your right to be forgotten You can ask us to delete or remove your personal information in some circumstances such as where we no longer need it or if you withdraw your consent (where applicable). If we’ve shared your personal information with others, we’ll let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve 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’ll tell you before we lift any restriction. If we’ve shared your personal information with others, we’ll 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’ll also tell you who we’ve shared your personal information with so that you can contact them directly. Your right to data portability You have the right to receive personal data that you have provided to us in a structured, commonly used and machine readable format. It also gives you the right to request that we transmit this data directly to another controller. 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 interests to process your personal information, except if we can demonstrate compelling legal grounds for the processing; or, processing your personal information for 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’s based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for 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. We will assess any deletion request on a case by case basis and will endeavour to respond as soon as possible, at most within 10 working days. 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’ve handled your personal information, you can report it to the UK Information Commissioner’s Office (ICO). You can find details about how to do this on the ICO website at ico.org.uk/concerns or by calling their helpline on 0303 123 1113.

Changes to this Privacy Policy We may make changes to this Privacy Policy from time to time. To ensure that you are always aware of how we use your personal information, we will update this Privacy Policy 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 make available to you here any significant changes to the policy, whether based on a change of law or otherwise. However, we encourage you to review this Privacy Policy periodically to be informed of how we use your personal information.