1. Introduction

Drayton Trust ("we," "our," or "us") is committed to protecting the privacy and confidentiality of the personal information entrusted to us by our family members and website visitors. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website or use our services.

By accessing or using our services, you acknowledge that you have read and understood this Privacy Policy.

2. Information We Collect

We may collect the following types of personal information:

• Identity Information: Names, dates of birth, and family relationship details.
• Contact Information: Email addresses, postal addresses, and telephone numbers.
• Account Information: Login credentials for Microsoft 365, OneDrive, and OneNote services accessed through our portal.
• Financial Information: Asset details, trust-related financial records, and estate planning documents, where applicable.
• Usage Data: Information about how you interact with our website, including IP addresses, browser type, pages visited, and access times.

3. How We Use Your Information

We use the information we collect for the following purposes:

• To provide and manage trust and family services on your behalf.
• To facilitate access to Microsoft 365, OneDrive, and OneNote services.
• To communicate with you regarding your account, services, or important updates.
• To comply with our legal and regulatory obligations.
• To maintain the security and integrity of our systems and services.
• To improve and personalise your experience with our services.

4. Information Sharing and Disclosure

We do not sell, trade, or rent your personal information to third parties. We may share your information only in the following limited circumstances:

• Service Providers: With trusted third-party service providers (such as Microsoft for Office 365 services) who assist us in operating our services, under strict confidentiality obligations.
• Legal Requirements: When required to do so by law, court order, or governmental authority.
• Protection of Rights: Where necessary to protect the rights, property, or safety of Drayton Trust, our members, or others.
• Family Trust Administration: With other authorised family members or trustees as required in the course of legitimate trust administration.

5. Data Security

We take the security of your personal information seriously. We implement appropriate technical and organisational measures to protect your data against unauthorised access, alteration, disclosure, or destruction. These measures include:

• Secure access to all Microsoft 365 services through authenticated accounts.
• Encrypted transmission of data where applicable.
• Restricted access to personal information on a need-to-know basis.
• Regular review of our security practices and procedures.

However, no method of transmission over the internet or electronic storage is completely secure. While we strive to use commercially acceptable means to protect your information, we cannot guarantee absolute security.

6. Third-Party Services

Our website and services include links to and integrations with third-party platforms, including Microsoft Office 365, OneDrive, and OneNote. These services are governed by their own privacy policies. We encourage you to review Microsoft's Privacy Statement for details on how they handle your data. Drayton Trust is not responsible for the privacy practices of third-party services.

7. Cookies and Tracking

Our website may use cookies and similar tracking technologies to enhance your browsing experience. Cookies are small files stored on your device that help us understand how you use our site. You may choose to disable cookies through your browser settings; however, some features of the site may not function correctly as a result.

8. Data Retention

We retain your personal information for as long as necessary to fulfil the purposes for which it was collected, including legal, accounting, and trust administration requirements. When data is no longer required, it is securely deleted or anonymised in accordance with applicable regulations.

9. Your Rights

Depending on your jurisdiction, you may have the following rights regarding your personal information:

• The right to access the personal information we hold about you.
• The right to request correction of inaccurate or incomplete data.
• The right to request deletion of your personal information, subject to legal obligations.
• The right to object to or restrict certain processing of your data.
• The right to data portability where applicable.

To exercise any of these rights, please contact us using the details below.

10. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. We will notify you of any significant changes by updating the "Last Updated" date at the top of this page. We encourage you to review this policy periodically.