YOUR
PRIVACY MATTERS

We value your privacy very highly. Please read this Privacy Policy carefully before using the enspirittech.co.uk website (the “Website”) operated by EnSpirit Technologies, a Company registered in England and Wales (“us, we, our”) as this Privacy Policy contains important information regarding your privacy and how we may use the information we collect about you.

Your access to or use of the Website is conditional upon your acceptance of and compliance with this Privacy Policy. This Privacy Policy applies to everyone, including but not limited to visitors, users and others, who wish to access or use the Website.

By accessing or using the Website, you agree to be bound by this Privacy Policy. If you disagree with any part of this Privacy Policy, you do not have our permission to access or use the Website.

We collect and store any and all information that you enter on this Website. We collect and store the following information about you:

• Identifying information - Name: Collected from information submitted by the consumer. Legal basis: Consent, Contract. Used for: Enforcing Terms, Marketing, Surveys, Services, Orders, Payments, Support, Recording calls, Disputes, Verification. Failure to provide: These services will not be possible.

• Postal / Shipping address: Collected from information submitted by the consumer. Legal basis: Consent, Contract. Used for: Enforcing Terms, Marketing, Surveys, Services, Orders, Payments, Support, Recording calls, Disputes, Verification. Failure to provide: These services will not be possible.

• Billing address: Collected from information submitted by the consumer. Legal basis: Consent, Contract. Used for: Enforcing Terms, Marketing, Surveys, Services, Orders, Payments, Support, Recording calls, Disputes, Verification. Failure to provide: These services will not be possible.

• Phone number: Collected from information submitted by the consumer. Legal basis: Consent, Contract. Used for: Enforcing Terms, Marketing, Surveys, Services, Orders, Payments, Support, Recording calls, Disputes, Verification. Failure to provide: These services will not be possible.

• IP address: Collected via Tracking pixels and Cookies. Legal basis: Consent. Used for: Analytics, Ad impressions, Enforcing Terms, Marketing, Security, Support, Disputes, Targeted ads, Verification. Failure to provide: These services will not be possible.

• Email address: Collected from information submitted by the consumer. Legal basis: Consent, Contract. Used for: Enforcing Terms, Marketing, Surveys, Services, Orders, Payments, Support, Recording calls, Disputes, Verification. Failure to provide: These services will not be possible.

• Device identifier: Collected via Tracking pixels and Cookies. Legal basis: Consent. Used for: Analytics, Ad impressions, Enforcing Terms, Marketing, Security, Support, Disputes, Targeted ads, Verification. Failure to provide: These services will not be possible.

• Financial information - Credit card or debit card number: Collected from information submitted by the consumer. Legal basis: Consent, Contract. Used for: Enforcing Terms, Services, Orders, Payments, Support, Recording calls, Disputes, Verification. Failure to provide: These services will not be possible.

• Financial information - Card expiration date & CVV: Collected from information submitted by the consumer for payment processing.

• Internet or other electronic activity: Information regarding your interaction with our website, application, and advertisements.

We are not required to collect this information by a law, court order, nor by a tribunal order. We combine or link the personal information that we hold about you.

We share the personal information below with the following categories of third parties for the following reasons:

• Identifying information (Name, Address, Billing, Phone, Email): Shared with Content management systems, Customer management systems, Data linking platforms, Email marketing vendors, Email service providers, Financial transactions processors, Fraud prevention services vendors, Hosting providers, Voice recording vendors.

Reasons: To manage our interactions with you, market to you via email, process transactions, prevent fraud, and record voice calls.

• IP address & Device identifier: Shared with Advertising networks, Content management systems, Customer management systems, Data analytics providers, Data linking platforms, Email marketing vendors, Financial processors, Hosting providers, Social networks, and more.

Reasons: To provide advertisements, analyze interactions, market via email, process transactions, prevent fraud.

• Financial information (Card number, Expiration, CVV): Shared with Content management systems, Customer management systems, Data linking platforms, Email marketing vendors, Financial processors, Fraud prevention, Hosting providers, Voice recording vendors.

Reasons: To manage interactions, process transactions, prevent fraud, record voice calls.

• Internet activity: Shared with Advertising networks, Analytics providers, Social networks, and robust service ecosystems to provide advertisements and analyze interactions.

Please note that these third parties will store your personal information that has been provided to them.

We protect and safeguard your personal information by using ssl encryption or other secure technologies when receiving or sending personal information beyond internal networks.

We do not sell your personal information.

Please see the “Your Rights” section below for more information about exercising your privacy rights regarding sales of your personal information.

A cookie is a small piece of data sent from a website and stored on your device by your browser. This Website sets cookies. Please visit our Cookie Policy to learn more about what cookies we set, why we set them, and how to change your cookie settings.

This Website is intended for use by a general audience and does not offer services to children. Should a child whom we know to be under 18 send personal information to us, we will use that information only to respond to that child to inform them that they cannot use this Website.

This Website uses the following analytics program(s) to collect information about you and your behaviors: Google Analytics 4, Statcounter, Hotjar, Microsoft Clarity. To learn how to opt-out, please visit the website(s) of the analytics program(s) listed. You can also opt out of cookies by using our cookie consent banner.

We retain all of the information that we collect until we no longer need the information to contact you.

We use the information that we collect about you for direct marketing purposes. Direct marketing is the act of selling products or services directly to consumers rather than through retailers. You may, at any time, request that we cease to use your information for direct marketing purposes by emailing us at support@enspirittech.co.uk.

All visitors or users of this Website have the following rights with regard to their personal information:

• The right to access the personal information that we hold about you.

• The right to receive the personal information that we hold about you in a portable and, to the extent feasible, a readily usable format that allows you to transmit this information to another entity.

• The right to ask us to transmit your personal information that we have collected on you to another provider, where technically feasible.

• The right to request that we amend any of the information that we have collected about you.

• The right to withdraw your consent to the processing of your personal information.

• The right to request that we restrict the processing of your personal information.

• The right to request that we delete some or all of the personal information that we have collected about you.

• The right to lodge a complaint regarding our collection, sharing, and processing of your personal information with competent authorities in the proper jurisdiction.

• The right to opt out of the use of your personal information for purposes of direct marketing.

• The right to opt out of sales of your personal information.

• The right to not have to identify yourself, or of using a pseudonym in certain circumstances.

• The right to opt out of tracking of your location.

• The right to opt out of the use of your personal information for the purposes of profiling in furtherance of decisions that could produce legal or similarly significant effects concerning you.

• The right to opt out of the use of your personal information for automated decision making purposes.

You may exercise the rights specified above by submitting a consumer request to:

Data Protection Officer

EnSpirit Technologies

support@enspirittech.co.uk

+44 7968533918

85 Great Portland Street, First Floor, London, England, W1W 7LT

United Kingdom

https://www.enspirittech.co.uk/contact

We will need to verify your identity prior to effectuating your request. To verify your identity, you will need to provide us with the following information with your request: Email address.

Please note that we may be unable to process your request if you do not provide us with the above information.

We will respond to most consumer requests within 30 days of receipt. However, some requests may take longer. We will notify you in writing if we need more time to respond. We have the ability to deny your request(s) if certain exceptions in the law apply. If we do deny your request, we will provide you with the reasons for such denial.

You have the right to lodge a complaint regarding our collection, use and sharing of your personal information by contacting us at the following contact information:

Data Protection Officer

EnSpirit Technologies

+44 7968533918

support@enspirittech.co.uk

85 Great Portland Street, First Floor, London, England, W1W 7LT

United Kingdom

Any such complaints must first be addressed to us in writing as required by Australia Privacy Act 1988 S 40(1A). We will respond to all complaints within a reasonable time (usually 30 days). If you are not satisfied with our response to your complaint, you may then lodge a complaint with the Office of the Australian Information Commissioner by following the steps on this Lodge a Privacy Complaint (Australia) page.

The following person is accountable and responsible for our privacy practices and procedures:

Data Protection Officer

EnSpirit Technologies

+44 7968533918

support@enspirittech.co.uk

85 Great Portland Street, First Floor, London, England, W1W 7LT

United Kingdom

You may lodge a complaint with us by contacting the person accountable and responsible for our privacy practices and procedures at the contact information above. Residents of Canada may also lodge a complaint with the Office of the Privacy Commissioner of Canada by visiting this File a Privacy Complaint (Canada) page or calling 1-800-282-1376. Residents of Quebec may also lodge a complaint with the Office of the Privacy Commissioner of Quebec by filling out this Quebec Privacy Commission page or calling 1-888-528-7741.

All data processing activities undertaken by us take place in the United Kingdom.

This Website may contain hyperlinks to websites operated by parties other than us. We provide such hyperlinks for your reference only. We do not control such websites and are not responsible for their contents or the privacy or other practices of such websites. It is up to you to read and fully understand their Privacy Policies. Our inclusion of hyperlinks to such websites does not imply any endorsement of the material on such websites or any association with their operators.

Do Not Track (“DNT”) is a preference you can set on your browser to inform websites that you do not want to be tracked. We do not support DNT. You can either enable or disable Do Not Track by visiting the Preferences or Settings page of your browser.

We may transfer your personal information for processing to the United Kingdom. This means that your information may be processed outside of your country of residence and it may be accessible to law enforcement and national security authorities of that country and jurisdiction. Please note that we use standard contractual clauses, additional safeguards, and adequacy decisions to transfer data.

If you have any questions about this Privacy Policy, please contact us at support@enspirittech.co.uk.

We reserve the right to amend this Privacy Policy at any time. We will notify you of any changes to this Privacy Policy by posting the updated Privacy Policy to this website or application.

No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. All OPT-IN requests include text messaging originator opt-in data and consent; this information will not be shared with third parties.