Privacy policy

1. Privacy Policy

1.1 BBGI Management HoldCo S. à r.l., together with other members of its group, ( BBGI Group, we/us/our) are committed to safeguarding the privacy of our shareholders and users (you/your) of this website.  This Privacy Policy sets out our personal data collection and sharing practices for both offline (e.g. via phone, conferences and other correspondence) and online (e.g. via our website www.bb-gi.com (Site) and mobile apps (as applicable) collection of your personal data) and is intended to inform you of the ways in which we collect your personal data, the uses of that personal data and the ways in which we will share any personal data you choose to provide to us.

1.2 Further notices highlighting certain uses we wish to make of your personal data together with the ability to opt in or out of selected uses may also be provided when we collect personal data from you.

1.3 Our Site may contain links to other third party websites.  If you follow a link to any of those third party websites, please note that they have their own privacy policies and that we do not accept any responsibility or liability for their policies or processing of your personal data.  Please check these policies before you submit any personal information to such third party websites.

1.4 This Privacy Policy is intended to explain our privacy practices and covers the following areas:

(a) Personal data we may collect about you;

(b) Uses made of your personal data;

(c) Transmission, storage and security of your personal data;

(d) Your rights;

(e) Contacting us;

(f) Cookies policy;

(g) Changes to our Privacy Policy and/or Cookies Policy.

2. Personal data we may collect about you

2.1 The following list shows the categories of personal data that we may collect or receive.

a) Contact details: such as your full name, e-mail address, or telephone number. We may receive this information from (i) you, when you visit our Site or apply for a position with the BBGI Group, (ii) from an employee of the BBGI Group, or (iii)from your employer if you provide services to the BBGI Group or enter into business with the BBGI Group;

b) Correspondence: if you contact us we will typically keep a record of that correspondence;

c) Survey information: we may also ask you to complete surveys that we use for research purposes.  In such circumstances we shall collect the information provided in the completed survey;

d) Marketing preference information:details of your marketing preferences (e.g. communication preferences);

e) Website and communication usage:details of your visits to the websites and information collected through cookies and other tracking technologies including, but not limited to, your IP address and domain name, your browser version and operating system, traffic data, location data, web logs and other communication data, and the resources that you access.

f) Recruitment information: this information may include (i) CVs, application forms, evidence of qualifications and other requirements; (ii) interview annotations; (iii) information to your right to work in certain jurisdictions; (iii) information related to reasonable work adjustments, inter alia. Recruitment information may be obtained directly from you or from third parties including employment agencies or other referees.

2.2 When we obtain your personal data from third parties, the third party is responsible for informing you about the sharing of you personal data. Once we receive you personal data, it will only be handled in accordance with this Privacy Policy.

3. Uses made of your personal information

In this section, we set out the purposes for which we use personal data that we collect.

3.1 Our use of personal data must be based on one of a number of lawful bases and we are required to set out the grounds in respect of each use. In the list below, we have set out the relevant grounds that apply to each purpose. You can find an explanation of each of the grounds relied on at Appendix 1.

3.2 Please note that in addition to the disclosures we have identified below, we may disclose personal data for the purposes we explain in this notice to service providers, contractors, agents, advisors (e.g.  legal, financial, business or other advisors) and affiliates of BBGI Group that perform activities on our behalf, as well as other members of the BBGI Group.

Examples of our use of personal data:

  • To provide and manage products and services you have requested: to administer our services, including to carry out our obligations arising from any agreements entered into between you and us, or to notify you about changes to our services and products.
  • To communicate effectively with you and conduct our business: to conduct our business, including to enable you to use our service, to respond to your queries, to otherwise communicate with you, or to carry out our obligations arising from any agreements entered into between you and us.
  • We may access and use certain information to prevent fraud, money laundering and terrorism as may be required by applicable law and regulation and best practice at any given time, including checking against sanctions, politically exposed persons (PEP) and other fraud or crime screening databases. If false or inaccurate information is provided and fraud is identified or suspected, details may be passed to fraud prevention agencies and may be recorded by us or by them.
  • To monitor certain activities such as queries, complaints and transactions to ensure service quality, compliance with procedures and to combat fraud.
  • To ensure that content from our websites is presented in the most effective manner for you and for your device, which may include passing your data to business partners, suppliers and/or service providers.
  • To provide you with marketing materials and updates where you have chosen to receive these. Where required by law, we will ask for your consent at the time we collect your data to conduct any types of marketing. We will provide an option to unsubscribe or opt-out of further communication on any electronic marketing communication sent to you or you may opt out by contacting us as set out in the “Contacting Us” section below.
  • To reorganise or make changes to our business: in the event that we: (i) are subject to negotiations for the sale of our business or part thereof to a third party; (ii) are sold to a third party; or (iii) undergo a re-organisation, we may need to transfer some or all of your personal information to the relevant third party (or its advisors) as part of any due diligence process for the purpose of analysing any proposed sale or re-organisation. We may also need to transfer your personal information to that re-organised entity or third party after the sale or reorganisation for them to use for the same purposes as set out in this policy.
  • In connection with legal or regulatory obligations: We may process your personal information to comply with our regulatory requirements or dialogue with regulators as applicable which may include disclosing your personal information to third parties, the court service and/or regulators or law enforcement agencies in connection  with  enquiries, proceedings or investigations by such parties anywhere in the world or where compelled to do so.  Where permitted, we will direct any such request to you or notify you before responding unless to do so would prejudice the prevention or detection of a crime.

3.3 We may use and share irreversibly de-identified data for any other legitimate purposes, including product and service development and improvement activities. We base this de-identification on the ground that it is within our legitimate interests.

4. Lawful basis

We will process your personal data for the purposes set out in this Privacy Policy based in our legitimate interests or the legitimate interests of a third party, when these interests are not outweighed by the rights of an individual under applicable legislation.

The legitimate interest and legal basis may include:

  • Operating and improving our respective lines of business and analysing the user of our Website;
  • Your consent to the processing of personal data,
  • To comply with legal obligations;
  • Processing personal data is necessary for contractual purposes;
  • Processing personal data is necessary to protect the rights of another data subject;
  • Processing personal data is necessary for a task carried out in the public interest.

5. Data storage and retention

We will only process your personal data for as long as necessary. The criteria used to determine the retention period is based on (i) the period of time required under applicable legal obligations, (ii) the period we have a relation with you, (iii) the period necessary for us to establish, exercise and defend legal claims, and (iv) the period for which we need your personal data for justified business purposes.

6. Security of personal data

6.1 No data transmission over the Internet or website can be guaranteed to be secure from intrusion. However, we maintain commercially reasonable physical, electronic and procedural safeguards to protect your personal information in accordance with data protection legislative requirements.

6.2 All information you provide to us is stored on our or our subcontractors’ secure servers and accessed and used subject to our security policies and standards. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our websites, you are responsible for keeping this password confidential and for complying with any other security procedures that we notify you of. We ask you not to share a password with anyone.

6.3 The Site may contain links to and from third party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these websites or their related policies. Please check these policies before you submit any Personal Data via these websites.

6. Transmission of personal data

Transfers outside of the European Economic Area (EEA)

7.1 Your personal information may be accessed by staff or suppliers in, transferred to, and/or stored at, a destination outside the country in which you are located, whose data protection laws may be of a lower standard than in the EEA. We will, in all circumstances, safeguard personal information as set out in this Privacy Policy.

7.2 Where we transfer personal information from inside the EEA to outside the EEA, we may be required to take specific additional measures to safeguard the relevant personal information. Certain countries outside the EEA have been approved by the European Commission as providing essentially equivalent protections to EEA data protection laws and therefore no additional safeguards are required to export personal information to these jurisdictions. In countries which have not had these approvals (see the full list here http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm), we will establish legal grounds justifying such transfer, such as EU Commission-approved model contractual clauses, or other legal grounds permitted by applicable legal requirements.

7.3 Where the EU GDPR or UK GDPR applies, we will only transfer personal data an affiliate or third party outside the UK or EEA if: (i) that third party is situated in a country that has been confirmed by the European Commission or UK Government (as relevant) to provide adequate protection to personal data, (ii) that third party has agreed (by way of written contract or by some other form of data transfer mechanism approved by the European Commission or UK Government) to provide all protections to personal data as required by the data protection legislation and we have undertaken a transfer risk assessment in respect of the transfer (as required), or (iii) we have your explicit consent to do so (such as where you have requested us to make the transfer).

7.4 Please contact us as set out in the “Contacting Us” section below if you would like to see a copy of the specific safeguards applied to the export of your personal information.

8.    Your rights

8.1 Data protection legislation provides data subject with certain rights depending on your jurisdiction.

  • Right to request and obtain information regarding our processing of your personal data and access to the personal data which we hold about you.
  • Right to withdraw your consent to our processing of your personal data at any time. Please note that we may still be entitled to processing your personal data if we have any legitimate grounds to so (e.g. compliance with legal obligations).
  • Right to request us that we rectify your personal data if its inaccurate, outdated, erroneous, or incomplete.
  • Right to request the deletion of your personal data in certain circumstances. The BBGI Group may have, in certain circumstances, the legal obligation to keep your data.
  • The right to object to, and the right to request that we restrict, our processing of your Personal Data in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your Personal Data but we are legally entitled or required to continue processing your Personal Data and/or to refuse that request.
  • The right to object to, and the right to request that we restrict, our processing of your Personal Data in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your Personal Data but we are legally entitled or required to continue processing your Personal Data and/or to refuse that request.
  • The right to restrict how we use your personal data whilst a complaint is being investigated

Marketing

8.2 You have the right to ask us not to process your personal data for marketing purposes. We will inform you if we intend to use your information for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by not checking certain boxes on the forms we use to collect your personal information.  You can also exercise the right at any time by contacting us as set out in the “Contacting Us” section below.

Exercise of your rights

8.3 You can exercise your rights by contacting us using the details set out in the “Contacting Us” section.

8.4 Your exercise of these rights is subject to certain exemptions to safeguard the public interest (e.g. the prevention or detection of crime) and our interests (e.g. the maintenance of legal privilege). If you exercise any of these rights we will check your entitlement and respond in most cases within a month.

8.5 If you are not satisfied with our use of your personal information or our response to any exercise of these rights you have the right to complain to the Commission Nationale pour la Protection des Données, who can be contacted at:

Commission Nationale pour la Protection des Données
1, avenue du Rock’n’Roll
L-4361 Esch-sur-Alzette
Tel. : (+352) 26 10 60 – 1
Fax: (+352) 26 10 60 – 29
https://cnpd.public.lu/fr.html

9. Cookies Policy

We use cookies on the websites. To find out more about how we use cookies, please see our Cookies Policy.

10. Changes to our Privacy Policy and/or Cookies Policy

10.1 If we change this Privacy Policy or our Cookies Policy, we will update the date it was last changed below. If these changes are material, we will indicate this clearly on our Site.

10.2 This Privacy Policy was last updated on 29 May 2026.

11.    Contacting us

The data controller of your personal information processed by us under this Privacy Policy is BBGI Management HoldCo S. à r.l.

BBGI Management HoldCo S. à r.l.
EBBC, 6 E route de Trèves
L-2633 Senningerberg
Grand Duchy of Luxembourg

If you have any questions in relation to this policy, please contact our Investor services team at [email protected]

 

Appendix 1

Legal bases for Personal Data:

  • Contract performance: where your information is necessary to enter into or perform our contract with you.
  • Legal obligations: where BBGI is required to process your Personal Data to comply with a legal requirement; and
  • Legitimate interests: where BBGI collect and use personal information in reliance on its legitimate interests (or those of any third party) and these outweigh any prejudices to your data protection rights.

Legal claims

  • Legal claims: where we are required to process your personal information for the BBGI Group to establish, defend, prosecute or make a claim against you, BBGI Group or a third party;
  • In the substantial public interest: the processing is necessary for reasons of substantial public interest, on the basis of EU or local law; and
  • Explicit consent: where you have given explicit consent to the processing of those personal data for one or more specified purposes (this will rarely be relied on). You are free to withdraw your consent by contacting us using the details set out in the “Contacting us” section above. If you do so, we may be unable to provide a benefit or service that requires the use of such data.