THE VAILLANT GROUP PENSION SCHEME: DATA PRIVACY & COOKIE NOTICE V2.2026

The following are definitions used throughout this Privacy and Cookie Notice:

“Controller” means the organisation that decides how the uses of your personal data and is required to issue this notice to all members;

"Personal Information" refers to the data which we collect about you and your nominated beneficiaries, dependants or next of kin, we explain this in more detail in Section 2;

“Plan” means the Vaillant Group Pension Scheme;

“Processor” means the organisation instructed to process your personal information for the provision of the Website or Plan;

“Vaillant Group” means any of these entities; Vaillant Group UK Limited, Vaillant Limited, Vaillant Industrial Limited, Vaillant Holdings Limited who employed members or do employ members of the Plan;

“Website” means the Member website at here;

“we”, “our” “us” refers to the the Trustees of the Plan;

1. Controller of your Personal Information

We are the Controller of your Personal Information used for the provision of the Plan and this Website and are committed to protecting all member Personal Information in accordance with UK data protection law. Capita Pension Solutions Limited act as our processor for certain services we provide to you under the Plan.

This privacy and cookie notice relates to all members of the Plan and their contact with us whether that be via phone, email, in person, or on our Website or Apps and contains all information that the law requires us to provide to you about your Personal Information, namely:

• (a) what Personal Information we collect;
• (b) what we do with it;
• (c) the lawful basis on which it is processed (used) by us;
• (d) who we may share it with;
• (e) transfers outside the UK/EU;
• (f) how long we retain it; and
• (g) what rights you have and how to exercise them.

2. Collection of your information

We collect and process the following Personal Information about you either from yourself or other sources:

• (a) your name, gender, date of birth, home address (including postcode), telephone number, e-mail address, national insurance number, bank account details and country of residence;
• (b) information relating to your benefits such as your member identifying number (which is assigned to you by us), the date you joined or left the Plan, your earnings and pensionable earnings, the category and value of benefits that you have built up or receive and relevant matters impacting your benefits such as voluntary contributions, pension sharing orders (including information in divorce or dissolution certificates), tax protections or other adjustments;
• (c) records of communications with you (including any complaints);
• (d) In some cases, special categories of Personal Information such as your marital status or information concerning your health (e.g. in the case of ill-health early retirement and ill-health reviews, and where incapacity or similar reasons determine the benefits paid to you); and
• (e) where applicable, we also collect information about your nominated beneficiaries, dependants or next of kin (for example, when you submit an expression of wish form). Before providing us with any such information, we suggest that you provide a copy of this privacy and cookie notice to those individuals. We will assume that you have their authority to share any personal information you provide to us about them.

In some cases, we may need to collect Personal Information about you from the Vaillant Group entity which is (or was) your employer under the Plan, from HM Revenue & Customs where this relates to the contracted-out benefits payable from the Plan, and from our service providers (e.g. our administrators (currently this is Vaillant Holdings Limited, Aviva Life and Pensions UK Limited, and Capita Pension Solutions Limited).

In some cases, it may be necessary to obtain additional information from you, such as in order to carry out your request for a transfer or allocation of benefits. Such information would only be used as part of our due diligence checks on the approval status of pension scheme you are transferring to and to check the qualified status of any Independent Financial Adviser whom may have advised you. This is in an effort to reduce risk of pension scams having an adverse impact on you. We will notify you when your information is required for this purpose.

3. How we use your Personal Information

We use your Personal Information for the following purposes:

• (a) communicating with you in relation to your benefits and contributions, handling requests for transfers and allocation of death benefits, dealing with complaints, and making disclosures at your request such as in relation to transfers to other pension arrangements;
• (b) for general administration of the Plan, which can include: to record and pay benefits; for making a determination in connection with eligibility for, or the amount of benefits payable under, the Plan; for actuarial valuations; for selecting member nominated trustee directors; for providing you with news about the Plan;
• (c) for reviews which we or our administrators conduct from time to time for statistical and reference purposes; and for other checks or administrative activities that may become necessary from time to time (like member tracing) should we happen to lose contact with you and to prevent fraud;
• (d) for meeting our on-going regulatory, legal, and compliance obligations, and investigating or preventing crime;
• (e) to improve our processes and our use of technology, including testing and upgrading of systems, and to learn about other processes we can use to improve the administration of the Plan; and
• (f) when we undertake activities from time to time to help us manage the liabilities of the Plan, such as obtaining life insurance, longevity hedging, insuring Plan liabilities with an insurer, Plan mergers, bulk transfers, pension increase exchanges and enhanced transfer value exercises, including (where relevant) disclosures to administrators for calculating offers made to you in relation to these activities and disclosures to advice providers to allow you to obtain financial advice.

4. Cookies

A cookie is a tiny text file that a website or App can store on your device when you visit. The cookie can recall settings you select on earlier visits or track your activity, provide statistics and many other functions. This allows websites to identify you and for example, remember to log you in the next time you visit.

There are 2 different permission levels for cookies some are ‘necessary’ to be able to fully use the website and can be used without your consent as it is in the Plan provider’s legitimate interests to use them to allow the website to function properly. However, other cookies are ‘optional’ to allow the website owner to obtain helpful statistics, or to track your activity on the website or other websites, and target relevant advertising to your interests, but these optional cookies will require your explicit consent before being used.

Necessary Cookies

We currently only use necessary cookies that are directly required to fulfil an action requested by you, such as logging in or adding an item to a shopping basket. We do not need your consent to use strictly necessary cookies as the Website would not work without them and we therefore rely on our legitimate interests as our lawful basis.

Optional Cookies

5. Lawfulness of the use of your Personal Information

Our use of your Personal Information as described above is permitted by applicable data protection law if it is for one of the following reasons:

• (a) it is necessary for the fulfilment of our obligations under the pension contract between us, or actions prior to entering into a contract with you, to allow us to provide the pension service and pursuing the purposes set out in Section 3 above;
• (b) it is necessary for our legitimate interests that we make disclosures to the Vaillant Group (for the audit and corporate transaction purposes referred to below), and in the interests of prudential management and meeting our regulatory requirements, subject to those interests not affecting your privacy rights except where the law requires it;
• (c) it is necessary to meet our legal or regulatory responsibilities, such as disclosures to certain authorities, regulators or government bodies including:
  • a. HM Revenue & Customs
  • b. Department for Works & Pensions
  • c. Pensions Regulator
  • d. Pension Auditors
• (d) it is necessary for the prevention or detection of crime, fraud or other unlawful acts;
• (e) we have obtained your consent where our use requires consent to be in place by law e.g. optional cookies, further details in Section 4
• (f) In relation to special categories of personal information such as health and marital information, as well as having a lawful basis (a) – (e) above, we must also meet a condition under Article 9 of the UK GDPR for use of special category information, and in this case our condition is that it is necessary for the purposes of meeting our obligations under employment, social security and social protection law.

6. Disclosures of your Personal Information

We typically share your Personal Information with the following recipients:

• (a) our suppliers and other providers of services who use the information on our instructions; we use service providers to administer the Plan on our behalf (currently Vaillant Holdings Limited, Aviva Life and Pensions UK Limited (who hold your invested additional voluntary contributions), Capita Pension Solutions Limited), financial advisers (to provide you with financial advice), , medical advisers (to advise in relation to ill-health retirement cases), providers of printing and communication services (currently Capita PLC), tracing services (currently Capita PLC)), IT and hosting (currently Capita Pension Solutions Limited).
• (b) our professional advisers to obtain actuarial advice (currently Marsh), legal advice (currently Eversheds Sutherland), investment advice (currently SEI Investments Europe Limited) and audit and covenant monitoring services (currently PricewaterhouseCoopers). We may also share your personal information with other professional advisers from time-to-time in order to take advice on matters such as de-risking and insurance buy-in and ultimately fully securing benefits with an insurer through a scheme “buy-out”.
• (c) the Vaillant Group, who will use the information for audit purposes, in relation to corporate transactions initiated by the Vaillant Group from time to time (although personal information is not normally disclosed as it would be anonymised);
• (d) any new pension provider you select, if requested to do so by you;
• (e) insurance and reinsurance companies, when we carry out the activities referred to in paragraph 3 above;
• (f) public authorities, regulators or government bodies, including when required by law or regulation, under a code of practice or conduct, or when these authorities or bodies require us to do so. This may include the Pensions Regulator, HM Revenue & Customs and the Department for Work and Pensions; and
• (g) other persons from time to time when the disclosure is needed to exercise or protect our legal rights, including the rights of other stakeholders, or in response to requests from individuals or their representatives who seek to protect their legal rights or such rights of others. This may include the police or by order of the court if, for example, there is suspected or actual criminal activity involving the Plan.

Please note that when we share your Personal Information with our suppliers and service providers, the police, courts and regulators etc., we take steps to ensure they meet appropriate security standards, so that your Personal Information remains secure and only used in compliance with UK data protection law.

7. Transfers of your Personal Information abroad

We do not currently transfer any data outside of the UK, although in the future if this were to be the case, we would ensure that the transferred information is protected in compliance with applicable UK data protection law. To ensure an appropriate level of protection, we typically use either i) a UK data transfer agreement in the appropriate standard form approved for this purpose by the UK or ii) the European Commission approved Standard Contract Clauses with the UK Addendum.

8. Retention of your Personal Information

In general, we will keep your Personal Information for seven (7) years after the last member of the Plan and their nominated beneficiaries have stopped being entitled to any benefits from the Plan. This retention period enables us to properly manage the Plan’s operational and legal requirements, such as: facilitating the payment of benefits to you or your nominated beneficiaries; calculating and managing the liabilities of the Plan; and responding to legal claims or regulatory requests.

9. Security of your Personal Information

We have implemented and regularly review the technical and organisational security measures we use to protect the Personal Information we process against destruction, loss, alteration, unauthorised disclosure or access.

All Personal Information provided by you when contacting us via our Website will be transmitted to us in encrypted form. Your Personal Information is password protected in the pension management systems in which it is stored. The persons who have access to it are prohibited by strict security regulations from disclosing your data to third parties unless we have set out where a third party is used as part of the provision of any of our services in this privacy and cookie notice. We also ensure that any third party we use also implements appropriate technical and organisational measures to comply with data protection law.

10. Your rights

You have rights under data protection law to do the following:

• (a) access your Personal Information held by us;
• (b) correct errors in your Personal Information;
• (c) object to certain of the processing of your Personal Information;
• (d) Restrict certain of the processing of your Personal Information
• (e) to require us to provide certain of your Personal Information in a portable medium such that you can move it to an alternative pension provider; and
• (f) complaint to us about how we use your Personal Information (see Complaints below); and
• (g) If we rely on your consent to use any of your Personal Information you also have the right to withdraw your consent to the use of your Personal Information for that purpose at any time.

You can exercise any of these rights by contacting us, details are set out in Section 13 below.

11. Complaints

You can lodge a complaint about our processing of your Personal Information. By law, this must first be sent to us to resolve for you but if you remain dissatisfied with our response you are then entitled to take your complaint to the supervisory authority for the country where you habitually reside or work, or where a breach has taken place.

Details for the UK supervisory authority are as follows:

Information Commissioner’s Office (changing to the Information Commission) Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF this address will change in Autumn 2026 please review this page or visit the ICO website to check the latest address if your correspondence is likely to be sent during Autumn 2026. website: www.ico.org.uk.

12. Amendments to this privacy notice

This privacy notice may be subject to amendments from time to time and the latest version will always display on our Website. For any material future changes or additions to our processing of Personal Information (as described in this privacy and cookie notice), will be brought to your attention in an appropriate way.

This is Version 2.2026 privacy notice was issued on 28 September 2026

PREVIOUS: Version 1.2018 was issued on 8 May 2018 and was valid until Version 2.2026 was issued.

13. Contact Us

To contact us about the Personal Information matters set out in this privacy and cookie notice, please contact the Pensions Manager at:

Vaillant Group Pension Scheme

Nottingham Road

Belper

Derbyshire, DE56 1JT

telephone the Pensions Helpline on 01773 596 048

or email us at vaillant.pensions@vaillant-group.com

or click HERE to go to our Website Contact Us form.