Last Updated: 16 March 2018

We are committed to protecting and respecting your privacy.

This policy and any other documents referred to in it explains how we collect, use and protect your personal data when you use our website (www.transformingtim.com) (the “site”) or if you otherwise interact with us.

Please read this policy carefully so that you understand your rights in relation to your personal data and how we will collect, use and process it. The data controller of any personal data collected through the website is Elliott Advisors (UK) Limited of Park House, a company registered at 116 Park Street, London W1K 6AF and with contact email address privacy@elliottadvisors.co.uk.

By continuing to use our Website, you acknowledge that you have read, understood and accepted the information described in this Privacy Policy. If you do not agree with this Privacy Policy in general or any part of it, you should not access our Website. 

1. INFORMATION WE COLLECT FROM YOU

1.1 We will collect and process the following data about you as it is in our legitimate interests to identify users that are interested in our site and/or campaign, to improve the site and ensure it functions properly and if you consent to send you email updates:

    • Information that you provide by filling in forms on the site. This includes information such as your first name, last name and email address provided at the time of registering to use our site.
    • Information, such as your name and email address, when you sign up to receive email updates about our campaign. You can withdraw you consent at any time. Providing your data [in relation to surveys] or to receive email updates is optional and your data will only be collected subject to your consent. Not providing your data for these purposes will not have any negative consequences for you.
    • If you report a problem with our site or communicate with us by email or through other channels, we will also process information such as your name and contact information and keep a record of any correspondence.
    • Technical information we collect when you visit our site including  your IP address, operating system and browser type as well as traffic data, weblogs and other communication data, and the resources that you access, without identifying your identity or profiling your activities.

1.2 If you do not wish us to process your data for such purposes, we may not be able to provide access to certain parts of our site.

2. COOKIES

2.1 Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. You can accept, disable and reject cookies easily by adjusting your browser settings. You can find more information about cookies and how to manage them at http://www.allaboutcookies.org/. Please be aware that total or partial disabling of technical cookies may affect the proper functioning of features reserved to registered users, whereas disabling third-party cookies will not affect your browsing experience in any way. For more information about cookies, please refer to our Cookies Policy.

2.2 We use Google Analytics, which is a web analytics tool that helps us understand how users engage with our Website. Like many services, Google Analytics tracks your movement through our site (i.e. the pages you have seen and the links you have clicked on) and helps us measure how you interact with the content we provide. . This information is used to compile reports and to help us improve our Website. The reports disclose website trends without identifying individual visitors. You can opt out of Google Analytics without affecting your use of our site. For more information on opting out of Google Analytics across all websites you use, visit this Google page: https://tools.google.com/dlpage/gaoptout.

3. DISCLOSURE AND TRANSFER OF YOUR PERSONAL DATA

3.1 The data that we collect from you will generally be held only within the European Economic Area (EEA). However, we are part of a group of global companies with our parent company, Elliott Management LLC, in the United States and affiliates in Hong Kong and Japan. On this basis, we will disclose your data within our group for the purposes of effective business management. To the extent this involves transferring your data outside the EEA, we will do so under the Commission’s model contracts for the transfer of personal data to third countries (i.e., the standard contractual clauses), pursuant to Decision 2004/915/EC and 2010/87/EU.

3.2 We also disclose your personal information to selected third parties, including:

    • Webreality, based in Jersey, who store the contact details of our users on AWS servers in Ireland. If we are under a duty to disclose or share your personal data in order to comply with any legal obligation or if we believe, in good faith, that such use is reasonably necessary to (i) comply with a legal obligation; (ii) enforce our terms and conditions and other agreements, including investigation of any potential violation thereof; (iii) detect, prevent or otherwise address security, fraud or technical issues; or (iv) to protect our rights, property, or safety of us, our users, a third party, our customers or others.

3.3 All information you provide to us is stored on secure servers. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access, by adopting all the minimum security measures necessary according to the kind of processing.

4. DATA RETENTION

4.1 Your personal data will be retained for as long as necessary for the legitimate purposes of the processing.

5. YOUR RIGHTS

5.1 In certain circumstances you have rights in relation to the personal data we hold about you. We have set out below an outline of those rights and how to exercise those rights. To exercise any of your rights, please contact us at privacy@elliottadvisors.co.uk. [Please note that we will require you to verify your identity before responding to any requests to exercise your rights.  Please note that for each of the rights below we may have valid legal reasons to refuse your request, in such instances we will let you know if that is the case.

  • Access: You have the right to know whether we process personal data about you, and if we do, to access data we hold about you and certain information about how we use it and who we share it with.

  • Correction: You have the right to require us to correct any personal data held about you that is inaccurate and have incomplete data completed.

  • Erasure: You may request that we erase the personal data we hold about you in the following circumstances:  (i) where you believe it is no longer necessary for us to hold the personal data; (ii), where we are processing it on the basis of your consent and you wish to withdraw your consent; (iii) where we are processing your data on the basis of our legitimate interest and you object to such processing (provided that there is no overriding legitimate interest for retaining it); (iv) you no longer wish us to use your data to send you marketing; or (iv) you believe we are unlawfully processing your data.  Please provide as much detail as possible on your reasons for the request to assist us in determining whether you have a valid basis for erasure.

  • Restriction of Processing to Storage Only: You have a right to require us to stop processing the personal data we hold about you other than for storage purposes in certain circumstances including if you believe the personal data is not accurate for such period it takes for us to verify whether the data is accurate or whilst we consider your objection to the our processing of personal data.

5.2 Our site may, from time to time, contain links to and from the websites of third parties. If you follow a link to any of these websites, please note that these websites have their own privacy policies and we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

6. CHANGES TO OUR PRIVACY POLICY

6.1 Any changes we may make to our privacy policy in the future will be posted on this page. Please check back frequently for updates or changes to this policy.

7. COMPLAINTS

7.1 In the event that you wish to make a complaint about how we process your personal data, please contact us in the first instance at privacy@elliottadvisors.co.uk and we will endeavour to deal with your request. This is without prejudice to your right to launch a claim with the data protection supervisory authority in the EU country in which you live or work where you think we have infringed data protection laws.

8. CONTACT

8.1 Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to:

privacy@elliottadivsors.co.uk

to which you can also address your requests to exercise your rights.

Disclaimer

This website and the information contained within it (together referred to as "this website") is an information resource for shareholders in Telecom Italia SPA ("Shareholders"). Through this website Shareholders can access copies of the correspondence between Elliott Advisors (UK) Limited ("Elliott"), Elliott International LP, Liverpool Limited Partnership, Elliott Associates LP (“Elliott Funds”) and the management of Telecom Italia SPA (“TI”), the press releases issued by Elliott, and presentations relating to TI prepared by Elliott.

This website is not intended to be and is not an investment recommendation as defined by Regulation (EU) No 596/2014. No information on this website should be construed as recommending or suggesting an investment strategy or as representing any opinion as to the present or future value of any financial instrument.  The information on this website is not an offer to sell or a solicitation of an offer to buy any security, nor shall Elliott offer, sell or buy any security to or from any person through this site.  The information in this website is not intended to constitute nor should it be construed as advice of any kind, whether in relation to legal, compliance, accounting, regulatory matters or otherwise.  Elliott is expressing its opinions solely in its capacity as an investment advisor to the Elliott Funds.  Nothing in this material should be taken as any indication of Elliott’s or the Elliott Funds’ current or future trading or voting intentions in relation to TI or any other listed security.  As of 16th March 2018, Elliott Funds hold a position in the issued share capital of TI.  As a result of its arrangements with the Elliott Funds, Elliott has a financial interest in the profitability of the Elliott Funds' positions in TI.

Materials contained in this website do not relate to a board-control seeking resolution in TI. Elliott is not seeking to secure commitments or proxies from TI shareholders to vote their shares to support the resolutions that Elliott has requested to table at TI general meeting convened on April 24, 2018 other than within the context of any proxy solicitation that Elliott may elect to pursue in accordance with applicable law.

This website is published and maintained by Elliott which is authorised and regulated by the Financial Conduct Authority in the United Kingdom.   Elliott and its affiliates, officers and employees make no representations or warranties, express or implied, regarding the accuracy, reliability, completeness, suitability or other characteristics of the information and materials (which may include information and materials obtained from third party sources) contained on or presented through the site. The information on this website is provided “as is”, is subject to change at any time, and Elliott has no duty to provide notice of such changes, nor is it obliged to undertake such changes.  Neither Elliott, nor any of its affiliates or officers shall be liable for any direct, indirect, consequential, punitive or special losses or damages of any kind whatsoever arising from reliance on any of the content of this website.

Telecom Italia SPA has not approved nor does it have any responsibility for this website or its contents.  This website was last updated on 5th April 2018.  Elliott does not intend to update this website on a regular basis, but may from time to time add additional information as it becomes available.