The Company respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

This privacy policy is provided in a layered format so you can click through to the specific areas set out below.

This privacy policy aims to give you information on how the Company collects and processes your personal data through your use of this website, including any data you may provide through this website.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

The Company is made up of different legal entities, details of which can be found in our website. This privacy policy is issued on behalf of the Company so when we mention “we”, “us” or “our” in this privacy policy, we are referring to the relevant company in the Company responsible for processing your data. Galkynysh Gas Field is the controller and responsible for this website.

We have appointed a data protection office that is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, please contact the data protection manager using the details set out below.

If you have any questions about this privacy policy or our privacy practices, please contact our data protection office in the following ways:

Full name of legal entity: Galkynysh Gas Field

Email address: dp@galkynysh-gasfield.com

Postal address: 8925+GCV, Ýolöten, Turkmenistan.

You may also have the right to file a complaint with the local data protection authority. We would, however, appreciate the chance to deal with your concerns before you approach the office so please contact us in the first instance.

We keep our privacy policy under regular review.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name and last name.
• Contact Data includes email address and telephone numbers.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
• Profile Data includes your interests, preferences and feedback.
• Usage Data includes information about how you use our website.
• Communications Data includes your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
• sign up for updates and correspondence on our website;
• subscribe to our publications;
• request investor relations material to be sent to you; or
• give us feedback or contact us.
• Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.
• Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
• Technical Data from the following parties:
  • analytics providers such as Google based in Poland;
  • advertising networks based in Turkmenistan; and
  • search information providers based in Turkmenistan.
• Identity and Contact Data from data brokers or aggregators based in Turkmenistan;
• Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based in Turkmenistan; and

Identity and Contact Data from our registrar.

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform a contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation.

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

We strive to provide you with choices regarding certain personal data uses, particularly around communications.

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which communications may be relevant for you.

You will receive communications from us if you have requested investor relations material from us and you have not opted out of receiving those communications.

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

A “cookie” is a bite-sized piece of data that is stored on your computer’s hard drive. They are used by nearly all websites and do not harm your system.

We use them to track your activity to help ensure you get the smoothest possible experience when visiting our website but the information does not usually identify you directly. We can use the information from cookies to ensure we present you with options tailored to your preferences on your next visit. We can also use cookies to analyse traffic and for advertising purposes.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information generally on cookies, including how to disable them, please refer to aboutcookies.org. You will also find details on how to delete cookies from your computer.

Below we describe the cookies which are installed upon this website.

You can change your cookie preferences at any time by clicking on the icon at the bottom left of this webpage.  You can then adjust the available sliders to “On” or “Off” and then click “Save and close”. You may need to refresh your page for your settings to take effect.

Alternatively, most web browsers allow some control of most cookies through the browser settings. Find out how to manage cookies on popular browsers:

• Google Chrome
• Microsoft Edge
• Mozilla Firefox
• Microsoft Internet Explorer
• Opera
• Apple Safari

If you use a smart phone, you can usually prevent cross-site tracking and block cookies in the settings section on your device. You may also be able to visit websites without leaving a history by turning private browsing on.   You should visit the support section of the website of your device for more information on how to do this.

Strictly necessary cookies

These cookies are always active and are necessary for this website to function. They cannot be switched off. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences.

You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personally identifiable information.

Performance cookies

These cookies allow us to count visits and traffic so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular, and see how visitors move around the site.

All information that is collected by these cookies is aggregated, and therefore anonymous. If you do not allow these cookies we will not know when you have visited our site, and will not be able to monitor its performance.

These cookies are set by the Google Analytics service, but hosted by galkynysh-gasfield.com.

Targeting cookies

We do not currently use targeting cookies.

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

We may share personal data we hold with third party providers of business, legal and professional services, judicial and other authorities.

If in the future we reorganize or transfer all or part of our business, we may need to transfer your personal data to third parties.

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Under certain circumstances, you have rights under data protection laws in relation to your personal data as follows:

• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact info@galkynysh-gasfield.com.