Privacy Policy

1. What information do we collect?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal information provided by you. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

• Email addresses
• Debit/credit card numbers
• Billing addresses

Sensitive information. We do not process sensitive information.

Payment data. We may collect data necessary to process your payment if you choose to make purchases, such as your payment instrument number and the security code associated with your payment instrument. All payment data is handled and stored by Stripe. You may review their privacy notice at stripe.com/privacy.

Payments are processed securely by Stripe. We do not store, see, or have access to your payment card details at any time — all transactions are encrypted and handled directly by Stripe's secure payment infrastructure.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

2. How do we process your information?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual's vital interest, such as to prevent harm.

3. What legal bases do we rely on to process your information?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason to do so under applicable law — like your consent, to comply with laws, to fulfil our contractual obligations, to protect your rights, or to fulfil our legitimate business interests.

If you are located in the EU or UK

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on to process your personal information. As such, we may rely on the following legal bases:

• Consent. We may process your information if you have given us permission to use it for a specific purpose. You can withdraw your consent at any time.
• Legal obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as cooperating with a law enforcement body or regulatory agency, or exercising or defending our legal rights.
• Vital interests. We may process your information where we believe it is necessary to protect your vital interests or those of a third party, such as situations involving potential threats to safety.

If you are located in Canada

We may process your information if you have given us specific permission (express consent) to use it for a specific purpose, or in situations where your permission can be inferred (implied consent). You can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

• If collection is clearly in your interests and consent cannot be obtained in a timely way
• For investigations and fraud detection and prevention
• For business transactions, provided certain conditions are met
• If contained in a witness statement necessary to assess, process, or settle an insurance claim
• For identifying injured, ill, or deceased persons and communicating with next of kin
• If we have reasonable grounds to believe an individual has been, is, or may be a victim of financial abuse
• If disclosure is required to comply with a subpoena, warrant, or court order
• If produced by an individual in the course of their employment, business, or profession, consistent with the purposes for which it was produced
• If the collection is solely for journalistic, artistic, or literary purposes
• If the information is publicly available and specified by the regulations

4. When and with whom do we share your personal information?

In Short: We may share information in specific situations described in this section and/or with the following third parties.

We may need to share your personal information in the following situations:

• Business transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.

5. What is our stance on third-party websites?

In Short: We are not responsible for the safety of any information that you share with third parties that we may link to, or who advertise on our Services, but are not affiliated with our Services.

The Services may link to third-party websites, online services, or mobile applications, and/or contain advertisements from third parties that are not affiliated with us. Accordingly, we do not make any guarantee regarding any such third parties, and we will not be liable for any loss or damage caused by the use of such third-party websites, services, or applications. A link to a third-party website does not imply an endorsement by us. We cannot guarantee the safety and privacy of data you provide to any third-party websites — any data collected by third parties is not covered by this Privacy Notice. We encourage you to review the policies of any third party you interact with and contact them directly with questions.

6. How long do we keep your information?

In Short: We keep your information for as long as necessary to fulfil the purposes outlined in this Privacy Notice, unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because it has been stored in backup archives), we will securely store it and isolate it from further processing until deletion is possible.

7. Do we collect information from minors?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly collect, solicit data from, or market to children under 18 years of age or the equivalent age as specified by law in your jurisdiction, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18, or the equivalent age as specified by law in your jurisdiction, or that you are the parent or guardian of such a minor and consent to their use of the Services. If we learn that personal information from users under 18 (or the equivalent age in your jurisdiction) has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under 18, please contact us at garbuttrhys130@tutamail.com.

8. What are your privacy rights?

In Short: Depending on your state of residence in the US, or in regions such as the EEA, UK, Switzerland, and Canada, you have rights that give you greater access to and control over your personal information.

In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right to (i) request access to and a copy of your personal information, (ii) request rectification or erasure, (iii) restrict the processing of your personal information, (iv) where applicable, data portability, and (v) not be subject to automated decision-making. If a decision that produces legal or similarly significant effects is made solely by automated means, we will inform you, explain the main factors, and offer a simple way to request human review. You can make such a request using the contact details in the "How can you contact us" section below, and we will consider and act on it in accordance with applicable data protection laws.

If you are located in the EEA or UK and believe we are unlawfully processing your personal information, you have the right to complain to your Member State or UK data protection authority. If you are in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Withdrawing your consent. If we are relying on your consent to process your personal information, you have the right to withdraw it at any time by contacting us. This will not affect the lawfulness of processing before its withdrawal, nor will it affect processing conducted in reliance on lawful grounds other than consent.

If you have questions or comments about your privacy rights, you may email us at garbuttrhys130@tutamail.com.

9. Controls for Do-Not-Track features

Most web browsers and some mobile operating systems and applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized, so we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in future, we will inform you in a revised version of this Privacy Notice.

California law requires us to let you know how we respond to web browser DNT signals. Because there is not currently an industry or legal standard for recognizing or honouring DNT signals, we do not respond to them at this time.

10. Do United States residents have specific privacy rights?

In Short: If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to, correct, obtain a copy of, or delete the personal information we maintain about you, and to withdraw consent to our processing of it. These rights may be limited in some circumstances by applicable law.

Categories of personal information we collect

The table below shows the categories of personal information we have collected in the past twelve months. It includes illustrative examples of each category and does not necessarily reflect the personal information we collect from you — see the "What information do we collect?" section above for the full picture.

We may also collect other personal information outside of these categories when you interact with us in person, online, or by phone or mail, for example when receiving help through our customer support channels, participating in surveys or contests, or in the delivery of our Services and responses to your inquiries.

Will your information be shared with anyone else?

We may disclose your personal information to our service providers under a written contract. We may also use your personal information for our own business purposes, such as internal research for technological development — this is not considered "selling" your personal information. We have not disclosed, sold, or shared any personal information with third parties for a business or commercial purpose in the preceding twelve months, and we will not sell or share personal information belonging to website visitors, users, and other consumers in future.

Your rights

You have rights under certain US state data protection laws, though these are not absolute and we may decline a request as permitted by law, including the right to:

• Know whether or not we are processing your personal data
• Access your personal data
• Correct inaccuracies in your personal data
• Request the deletion of your personal data
• Obtain a copy of the personal data you previously shared with us
• Non-discrimination for exercising your rights
• Opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or certain profiling

Depending on where you live, you may also have the right to:

• Access the categories of personal data being processed
• Obtain a list of the categories, or specific parties, we've disclosed personal data to
• Obtain a list of third parties we've sold personal data to
• Review, understand, question, and correct how your personal data has been profiled
• Limit the use and disclosure of sensitive personal data
• Opt out of the collection of data through voice or facial recognition features

How to exercise your rights

To exercise these rights, you can contact us by emailing garbuttrhys130@tutamail.com or by referring to the contact details below. Under certain US state laws, you can designate an authorized agent to make a request on your behalf; we may deny a request from an agent that does not submit proof of valid authorization.

Request verification

Upon receiving your request, we will need to verify your identity to determine you are the person about whom we have information in our system, using only the information provided in your request. If we cannot verify your identity from information we already hold, we may request additional information for verification and security or fraud-prevention purposes. If submitted through an authorized agent, we may need to collect additional information to verify your identity, and the agent will need to provide written, signed permission to submit the request on your behalf.

Appeals

Under certain US state data protection laws, if we decline to act on your request, you may appeal by emailing garbuttrhys130@tutamail.com. We will inform you in writing of any action taken or not taken in response, including our reasoning. If your appeal is denied, you may submit a complaint to your state attorney general.

California "Shine the Light" law

California Civil Code Section 1798.83 permits our users who are California residents to request and obtain, once a year and free of charge, information about the categories of personal information (if any) we disclosed to third parties for direct marketing purposes, and the names and addresses of those third parties, in the immediately preceding calendar year. California residents can make such a request using the contact details in the "How can you contact us" section below.

11. Do we make updates to this notice?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated "Last updated" date at the top of this Privacy Notice. If we make material changes, we may notify you by prominently posting a notice of the changes or by directly notifying you. We encourage you to review this Privacy Notice periodically.

12. How can you contact us about this notice?

If you have questions or comments about this notice, you may email us at garbuttrhys130@tutamail.com, or write to us at:

Rhys Garbutt
Ireland

13. How can you review, update, or delete the data we collect from you?

Based on the applicable laws of your country or state of residence, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correction of inaccuracies, or deletion of your personal information. You may also have the right to withdraw your consent to our processing of it. These rights may be limited in some circumstances by applicable law. To make such a request, please email garbuttrhys130@tutamail.com.