JARVIS TECH - INTERNET PRIVACY POLICY

This Internet Privacy Policy sets out the basis on which any of your personal information we collect from you or third parties, or that you provide to us, will be processed by us. Please read the following Policy to understand our practices regarding your personal information, we process the personal data of all of our users. This website is operated by Jarvis Tech Limited (“Company”, “we” or “us”), a company registered in England and Wales, Company Number: 04307848, with the registered office at Napier House, Crown Technical Centre, Burwash Road, Heathfield, East Sussex, TN21 8QZ. This internet privacy policy explains how our Company uses the personal data we collect from you when you use our website.

OUR LEGAL BASIS FOR PROCESSING

Under the UK General Data Protection Regulations (UKGDPR) there are various legal bases for the processing of personal data

Conditions

(a) Explicit consent (except where the law states otherwise).

(b) Other limited reasons: Substantial public interest on basis of law (subject to the data subject’s rights).

(c) Legal Obligation: Where we are subject to a legal obligation and need to use your personal information in order to comply with that obligation.

What data we collect?

Jarvis Tech Limited takes the security and privacy of the personal information that you provide very seriously and is committed to protecting and respecting your privacy. Jarvis Tech Limited takes every reasonable precaution to ensure that your information is used only in ways as outlined in this Privacy Policy and handled within compliance of the Jarvis Tech Limited Terms & Conditions of Sale. Jarvis Tech Limited operates in accordance with these terms, as well as The Privacy and Electronic Communications (EC Directive) Regulations 2003 (the, “Directive”), and the General Data Protection Act 2018 (the, “UKGDPR”).

How do we collect your data?

You directly provide our Company with the data we collect. We collect data and process data when you:

How will we use your data?

Our Company collects your data so that we can:

Marketing

We may also use your information for the purpose of Email Marketing directly from Jarvis Tech Limited. We will only contact you about enquiries related to your original submission e.g. if you submitted a form asking for information we may contact you about products/services or information relevant to that enquiry, or follow up on your original inquiry to check your satisfaction. We may also use the email address provided by you to make sure your information provided is still accurate and up to date, and remove your information from our systems if it is no longer accurate and/or relevant. Our Company would like to send you information about products and services ofo urs that we think you might like, as well as those of our partner companies, as list of partner companies canbe requested by email; privacy@jarvistech.co.uk. If you have agreed to receive marketing, you may always opt out at a later date, please email the Company to remove any marketing data we may have collected about you.

KEY CONTACT DETAILS & REPORTING

Should you have any questions regarding your privacy and/or data that are not detailed throughout this Internet Privacy Policy then we provide you with the following details for contact, the Data Controller and Data Processor accepts full liability for the lawful processing of your data and agrees to only use your data lawfully and only collect necessary and non-excessive data. The Data Controller and Data Processor for the purpose of this Privacy Policy is Jarvis Tech Limited, and can be contacted via privacy@jarvistech.co.uk with the subject header “Data Protection”. In the instance of data that is gathered directly via Jarvis Tech Limited we act as the Data Controller and Data Processor and no third parties will be used in relation to any and all personal data. In our core trading activity, we may receive data from 3rd parties (GDPR Compliant data providers). In these instances, we act as the data processor, we will not market to these customers without prior permission obtained via our telemarketing teams using an Opt-In process. Any information we are requested to delete we shall do instantly, and can provide the process in writing on how this is achieved. If you believe you have found a security vulnerability, please report to privacy@jarvistech.co.uk. Please include the details of the website, IP or any other vulnerability observed.

What are your data protection rights?

Please be aware of your data protection rights. Your rights under the Data Protection Act 2018 and UKGDPR are listed below. Please contact our Data Protection Officer to discuss any of these rights and how we may assist: privacy@jarvistech.co.uk

DATA WE MAY COLLECT & LAWFUL PURPOSE OF YOUR DATA

We may collect the follow personal information about you from your use of the Site: Including but not limited to; browser signature, IP address, location data, profile data, email address, name, telephone number. This data can also be collected via Cookies on the website and is contained in more detail below in the Cookies section of this privacy policy.

This information is collected by you completing one of our on-site contact forms of purchasing products via the site for the purposes of:

What are cookies?

Cookies are text files placed on your computer to collect standard Internet log information and visitor behaviour information. We may use "cookies" and other software so as to be able to build up a profile of your interests and preferences and this may be used by us to develop and operate our business. See section "Cookies" below for more information. Jarvis Tech Limited also use cookies to improve your experience of the Site as well as to provide information to the Site. By using the site you accept the use of cookies. You may control the cookies used by the Site by modifying the settings in your browser to change your cookie preferences. If cookies are disabled, this may mean that the Site will not work effectively. For more detailed information about cookies and how they can be managed and deleted please visit www.allaboutcookies.org. You may refuse to accept cookies by activating the settings on your browser. However, if you select this setting you may be unable to access certain parts of our site. We may disclose to third parties aggregated data on the use of this web site or our services, provided that a single individual is not identifiable in such data. When you visit our websites, we may collect information from you automatically through cookies or similar technology. For further information please email; privacy@jarvistech.co.uk. When you visit our website and/or app, we may also collect information from you automatically, for example using cookies and other similar technologies. A cookie is a small file of letters and numbers that we may set on your device. Cookies generally only work with web browsers, but there are similar technologies that are used with apps.

Our Company uses cookies in a range of ways to improve your experience on our website, including:

The cookies we use fall into the following categories

DATA STORAGE & SECURITY

Jarvis Tech Limited securely collects, stores, transfers your data in the UK. Any transfer of personal data which are undergoing processing or are intended for processing after transfer to a third country or to an international organisation or company shall ensure that the level of protection of natural persons is guaranteed by UKGDPR regulation and not undermined at any time. A transfer, or set of transfers may be made where the transfer is;

(1) Consent (explicit & informed of potential risks) Article 49 (1) (a);

(2) Contract performance Article (1)(b) (c), (e) and (g), the information on data transfer is also available at https://ico.org.uk/ for-organisations/dp-at-the-end-of-the-transition-period/data- protection-and-the-eu-in-detail/the- uk-gdpr/international-data-transfers/.

Whenever we transfer your information, we will take steps that are reasonably necessary to ensure that adequate safeguards are in place to protect your personal information and to make sure it is treated securely and in accordance with this Internet Privacy Policy. In these cases, we rely on approved data transfer mechanisms (such as standard contractual clauses) to ensure your information is subject to adequate safeguards in the recipient country. If you are located in the UK or the EEA, you may contact us for a copy of the safeguards which we have put in place to protect your personal information and privacy rights in these circumstances. Our Company is compliant with the Data Protection Act 2018, including UKGDPR. All account information you use or supply on Jarvis Tech’s Web site when ordering or tracking products is completely secure. We use the most advanced encryption technology to protect you from unauthorised use of information supplied on our Web site, however, the transmission of data 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. All data stored is kept accurate and up to date, we only keep relevant data in accordance with the GDPR. In the unfortunate event of any data breaches you will be made aware within 72 hours of us discovering any breach that concerns your personal data to give you the best ability to protect yourself. We also store local backups of your data to ensure it is kept safe in the event that any of servers fail and your data is lost, this will allow us to maintain the high level of service you expect completely uninterrupted. The local backup is encrypted, password protected, virus & malware protected and regularly maintained.

DISCLOSURE OF YOUR INFORMATION

We may disclose your personal information to any member of our group. This includes affiliates, subsidiaries, and our ultimate holding company and its subsidiaries, as defined within section 1159 of the UK Companies Act 2006. We explicitly only deal with companies that comply with the DPA, GDPR, and the Directive. They must also be registered with all required regulators for their industry and without strikes or unresolved legal or civil action against them. In the event that the Site or Jarvis Tech Limited has either its entirety or part of its assets acquired by a third party, the information we hold can be considered as part of its total assets. This can result in your information transferring to that third party as part of the acquisition process. We may also be required to disclose your information to legal, government, or local authority agencies as part of an investigating when reasonable evidence is provided by the agency in question. We allow our visitors to access their own information where this relates to account and order processing information. (For example, users can access things such as their online account details). We sometimes use third party companies to help us provide our products and services to you and to help us prevent fraudulent transactions. Some of these companies are given access to some, or all, of the information you provide to us and may use cookies on our behalf. These companies are contractually restricted from using your information in any manner, other than in helping us to provide you with the products and services available on our site or to help us prevent fraudulent transactions and activity.

You agree that you do not object to us, or such third parties contacting you for any of the above purposes whether by telephone, e-mail or in writing and you confirm that you do not and will not consider any of the above as being a breach of any of your rights under the The Privacy and Electronic Communications (EC Directive) Regulations 2003 (the, “Directive”), and the General Data Protection Regulation 2018 (the, “GDPR”). You should be aware that if we are requested by the police or any regulatory or government authority investigating suspected illegal activities, to provide your user information and/or information concerning your activities whilst using this web site we shall do so. We also reserve the right to disclose individually identifiable information to third parties where a complaint arises concerning your use of this web site, and that use is deemed by us inconsistent with these terms.

DETAILS OF DATA TRANSFER

Your data will only ever be transferred via secure methods to ensure your data is safe and never passed to any unwarranted third parties, we generally transport your data via a SSL secured HTTPS connection, via TCP secured email, or via SFTP to our local backups. Your data will never be willingly passed to individuals/organisations/companies that do not comply with the GDPR.

RETENTION OF YOUR DATA

We will never excessively store or hold your information for more than legally required, as mentioned above in the Email Marketing section of this Privacy Policy we contact you annually to ensure your data is still up to date and you are still happy for us to hold your information for the purposes detailed in this Privacy Policy. Your data will never be held for more than you have permitted. In the event that we discover your information is no longer relevant or up to date or accurate, we will remove you from our systems unless legally required to do otherwise by any relevant EU laws. We determine a 36-month retention period for your data as suitable for adequate time to develop and business cycles to complete. Whenever your data is renewed or reconfirmed as accurate the 36-month period mentioned is renewed.

ACCURATE RECORD KEEPING

As mentioned in the Retention of Your Data section, we seek to ensure that the records kept are always accurate. This concludes of an annual email from us detailing the information we hold about you and requiring you to confirm the accuracy of the data, updating your data, or requesting to be removed from our systems. In the event that any of the data we hold about you is no longer accurate then you must contact us where possible to allow us to update our records and make sure any information we share with you is still relevant. You can do this by contacting us via email on privacy@jarvistech.co.uk with 3 matching details of the information we hold and the details of the information requiring updating using the subject header “Update My Information”.

YOUR RIGHTS

As detailed within the GDPR you have full rights to access for all of the information we hold about you. This can be retrieved free of charge and will contain a complete record of all the information the Site or Jarvis Tech Limited holds about you. This can be requested via emailing privacy@jarvistech.co.uk with the email subject header “Data Access Request” and by providing reasonable proof of your identity. You also have the right to withdraw consent and complain (both detailed below) along with all other rights as declared by the GDPR. We do not dispute any of your rights and allow you to make any lawful request in-line with the GDPR.

WITHDRAWING CONSENT

If you no longer wish to receive information directly from Jarvis Tech Limited or our subsidiaries, then you are able to simply withdraw your consent. This can be done via providing information via email to privacy@jarvistech.co.uk with the email subject header “Withdrawing Consent”.

Under GDPR you also now have the right to be forgotten, this consists of Jarvis Tech Limited and our subsidiaries ceasing contact with you and delete your information from our records. This can be done via email to privacy@jarvistech.co.uk with the email subject header “Right To Be Forgotten”.

COMPLAINTS

If you believe we have mistreated your information/data and wish to lodge a complaint you can do it in the following ways: You can register a complaint directly with us by email via privacy@jarvistech.co.uk with the email subject header “Complaint”. We will respond to your inquiry within 48 hours. You can register a complaint directly with the ICO by following this guide https://ico.org.uk/concerns/.

AUTOMATED DECISION MAKING

Jarvis Tech Limited does not perform any automated decision making with client or third-party customer data.

LINKS

The Site may, from time to time, contain links to and from the websites of Jarvis Tech Limited partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that Jarvis Tech Limited does not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

TELEPHONE PREFERENCE SERVICE (TPS)

If you are registered with the telephone preference service (TPS) you understand that by agreeing to the terms of this privacy policy you are giving express consent for Jarvis Tech Limited companies to contact you via telephone and SMS (text) for the purpose of progressing your application(s). Further information is available on the ICO website found here: https://ico.org.uk/media/for-organisations/documents/1555/direct-marketing-guidance.pdf https://ico.org.uk/for-organisations/guide-to-pecr/electronic-and-telephonemarketing/telephone- marketing/

CHANGES TO OUR PRIVACY POLICY

Please note that this Privacy Policy forms part of Jarvis Tech Limited Terms and Conditions for use of the Site and forms part of the agreement between you and Jarvis Tech Limited. Jarvis Tech Limited may, from time to time, amend this Privacy Policy, in whole or in part, in Jarvis Tech Limited sole discretion. Any changes to this Privacy Policy will be effective immediately upon the posting of the revised privacy policy on the Site. Depending on the nature of the change, Jarvis Tech Limited may announce the change: (a) on the home page of the Site; or (b) by email, if Jarvis Tech Limited has your email address. In any event, by continuing to use the Site following any changes, you will be deemed to have agreed to such changes. If you do not agree with the terms of this Privacy Policy, as it may be amended from time to time, in whole or part, you must not use the Site.