Privacy Policy

Scully Royalty Ltd. and its subsidiaries and affiliates (“Scully”, “we”, “our”, or “us”) respect your right to privacy. This Privacy Notice explains who we are, how we collect, share and use personal information about you, and how you can exercise your privacy rights. This Privacy Notice only applies to personal information that we collect through our websites and the websites of our affiliates and subsidiaries (“Website”).

If you have any questions or concerns about our use of your personal information, then please contact us using the contact details provided at the bottom of this Privacy Notice.

For more information about Scully, please see the “About Us” section of our Website at https://www.scullyroyalty.com/about-us.

We recommend that you read this Privacy Notice in full to ensure you are fully informed. However, if you only want to access a particular section of this Privacy Notice, then you can click on the relevant link below to jump to that section.

What personal information does Scully collect and why?

The personal information that we may collect about you broadly falls into the following categories:

• Information that you provide voluntarily
  
  Certain parts of our Website may ask you to provide personal information voluntarily: for example, we may ask you to provide your name, address, e-mail address, company affiliation, telephone number, and other similar information. From time to time our Website may request additional information from users via surveys or contests. Participation in these surveys or contests is completely voluntary and you therefore have a choice whether or not to disclose additional information that may be requested. Information requested via surveys and contests may include additional demographic information.
  
  We use personal information for purposes of administering our business activities and providing customer service. The Personal Information you provide to us when filling out and submitting an online form or requesting us to contact you will be used for the purpose for which it was provided – such as contacting you or processing a request.
  
  Occasionally, we may also use the personal information we collect to notify you about important changes to our Website, new services and special offers we think you will find valuable. Any lists used to send you product and service offers are developed and managed under our traditional company standards designed to safeguard the security and privacy of our customers' personal information. As a customer, you will be given the opportunity, after registration, to notify us of your desire not to receive any further e-mails from us.
• Information that we collect automatically
  
  When you visit our Website, we may collect certain information automatically from your device. In some countries, including countries in the European Economic Area, this information may be considered personal information under applicable data protection laws.
  
  Specifically, the information we collect automatically may include information like your IP addresses, Internet domain names, the web browser and operating system used to access the Website, the files or pages visited, the time spent in each file or page, and the time and date of each visit. We use this information to improve our Website, for example by enhancing pages or features that are visited frequently, and on occasion we may share this information with our affiliates or other third party companies to provide them with an indication of the amount of interest in our Website for advertising purposes and to help us plan for technical improvements.
  
  Some of this information may be collected using cookies and similar tracking technology, as explained further under the heading “Cookie Consent Policy”.
• Information that we obtain from third party sources
  
  From time to time, we may receive personal information about you from third party sources, but we will only retain or process such information only where we have checked that these third parties either have your consent or are otherwise legally permitted or required to disclose your personal information to us, or where we have your consent or other legal grounds exist to allow us to retain or process such information.
  
  The types of information we collect from third parties may include marketing information provided by trade shows and professional and other relevant information available to us on social networks about employment candidates. We use the information we receive from these third parties to allow us to make more informed decisions, improve the accuracy of records we hold, and occasionally to reach out to you regarding items or issues we believe interest you.

In general, we will use the personal information we collect from you only for the purposes described in this Privacy Notice or for purposes that we explain to you at the time we collect your personal information. However, we may also use your personal information for other purposes that are not incompatible with the purposes we have disclosed to you (such as archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes) if and where this is permitted by applicable data protection laws.

Who does Scully share my personal information with?

We may disclose your personal information to the following categories of recipients:

• to our group companies, third party services providers and partners who provide data processing services to us (for example, to support the delivery of, provide functionality on, or help to enhance the security of our Website), or who otherwise process personal information for purposes that are described in this Privacy Notice or notified to you when we collect your personal information. A list of our current group companies is available in Scully’s most recent annual report on Form 20F, filed with the United States Securities and Exchange Commission and available at http://www.scullyroyalty.com/investors.
• to any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person;
• to a potential buyer (and its agents and advisers) in connection with any proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal information only for the purposes disclosed in this Privacy Notice;
• to any other person with your consent to the disclosure.

Linked Sites

It is important to note that our Website contains links to other websites and that those other websites will not follow the same privacy notice. This includes links from advertisers, content providers and trade partners who may use our logo and/or style as part of a co-branding agreement. These other websites may collect data from you that we would not and may use that data in ways that we would not.

Legal basis for processing personal information

Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.

However, we will normally collect personal information from you only where we have your consent to do so, where we need the personal information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person.

If we ask you to provide personal information to comply with a legal requirement or to perform a contact with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).

If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under the “How to contact us” heading below.

Cookies and similar tracking technology

We use cookies and similar tracking technology (collectively, “Cookies”) to collect and use personal information about you, including to serve interest-based advertising. For further information about the types of Cookies we use, why, and how you can control Cookies, please see our Cookie Notice at https://www.scullyroyalty.com/legal/cookies.

How do we keep your personal information secure

We use appropriate technical and organizational measures to protect the personal information that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information.

International data transfers

Your personal information may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country.

Specifically, certain Website assets and our offices located in Ireland, and our group companies and third party service providers and partners operate around the world. This means that when we collect your personal information we may process it in any of these countries.

However, we have taken appropriate safeguards to require that your personal information will remain protected in accordance with this Privacy Notice.

Data retention

We retain personal information we collect from you when we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

Automated decision-making

In some instances, our use of your personal information may result in automated decisions being taken that legally affect you or similarly significantly affect you.

Automated decisions mean that a decision concerning you is made automatically on the basis of a computer determination (using software algorithms), without human review. For example, we may use automated decisions to screen résumés. If such automated decision making procedures are implemented, we will take appropriate measures to safeguard the rights and interests of individuals whose personal information is subject to automated decision-making.

When we make an automated decision about you, you have the right to contest the decision, to express your point of view, and to require a human review of the decision. You can exercise this right by contacting us using the contact details provided under the “How to contact us” heading below.

Children and privacy

We do not knowingly collect information from or about children age 13 and under.

Your data protection rights and data subject access rights

Users residing in Europe have the following data protection rights:

• If you wish to access, correct, update or request deletion of your personal information, you can do so at any time by contacting us in a manner consistent with our Data Subject Access Rights policy (“DSAR Policy”).
• In addition, you can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. Again, you can exercise these rights in a manner consistent with our DSAR Policy
• You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe,” “opt-out,” or similar link in the marketing e-mails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), please contact us in a manner consistent with our DSAR Policy
• Similarly, if we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
• You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with our Data Subject Access Rights Policy and applicable data protection laws.

Our Data Subject Access Rights Policy and more detailed information on how to submit a request may be found at http://www.scullyroyalty.com/legal/privacy.

Modifications to Our Privacy Policies

Scully reserves the right to change our Privacy Notice at any time, except as may be prohibited by law. We will post revisions online. Use of our Website after the Privacy Notice has changed means that you consent to the Privacy Notice as changed.

How to Contact Us

If you have any questions or would like additional information about our privacy practices, please do not hesitate to contact us as provided below:
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Scully Royalty Ltd
Room 2103 Shanghai Mart Tower
2299 Yan An Road West
Changning District
Shanghai China 200336
Email: info@scullyroyalty.com
www.scullyroyalty.com

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