Privacy Policy

Last updated: March 28, 2022

This privacy policy (“Privacy Policy”) is entered into between you and AQRU PLC (the “Company,” “we,” or “us”). We are committed to protecting your privacy. It is our policy to respect your privacy and comply with any applicable law and regulation regarding any personal information we may collect about you through your use of this website (the “Website“). By using our Website you agree to the use of the data we collect in accordance with this Privacy Policy.

Personal information is any information about you which can be used to identify you. This includes information about you as a person (such as name, address, and date of birth), your devices, payment details, and even information about how you use a website or online service.

In the event our Website contains links to third-party sites and services or other sites and services not administered by the Company, please be aware that those sites and services have their own privacy policies which we are not responsible for. After following a link to any other website or third-party content, you should read their posted privacy policy information about how they collect and use personal information. This Privacy Policy does not apply to any of your activities after you leave our Website.

Information We Collect

Information we collect falls into one of two categories: “voluntarily provided” information and “automatically collected” information.

“Voluntarily provided” information refers to any information you knowingly and actively provide us when using or participating in any of our services and promotions.

“Automatically collected” information refers to any information automatically sent by your devices in the course of accessing our products and services.

We collect information you provide directly to us. For example, we collect information when you request customer support or otherwise communicate with us.

Log Data

When you visit our Website, our servers may automatically log the standard data provided by your web browser. It may include your device’s internet protocol (IP) address, your browser type and version, the pages you visit, the time and date of your visit, the time spent on each page, and other details about your visit.

Additionally, if you encounter certain errors while using the Website, we may automatically collect data about the error and the circumstances surrounding its occurrence. This data may include technical details about your device, what you were trying to do when the error happened, and other technical information relating to the problem. You may or may not receive notice of such errors, even in the moment they occur, that they have occurred, or what the nature of the error is.

Please be aware that while this information may not be personally identifying by itself, it may be possible to combine it with other data to personally identify individual persons.

Device Data

When you visit our Website or interact with our services, we may automatically collect data about your device, such as:

• Device type; and
• Operating system.

Data we collect can depend on the individual settings of your device and software. We recommend checking the policies of your device manufacturer or software provider to learn what information they make available to us.

Collection and Use of Information

We may collect information from you when you do any of the following on our Website:

• Use a mobile device or web browser to access our content;
• Contact us via email, social media, or on any similar technologies; and
• When you mention us on social media.

We may collect, hold, use, and disclose information for the following purposes, and personal information will not be further processed in a manner that is incompatible with these purposes:

• to contact and communicate with you;
• to enable you to access and use our Website, associated applications, and associated social media platforms; and
• to comply with our legal obligations and resolve any disputes that we may have.

We may combine voluntarily provided and automatically collected personal information with general information or research data we receive from other trusted sources. For example, our marketing and market research activities may uncover data and insights, which we may combine with information about how visitors use our Website to improve it and your experience on it.

Security of Your Personal Information

When we collect and process personal information, and while we retain this information, we will protect it within commercially acceptable means to prevent loss and theft, as well as unauthorized access, disclosure, copying, use, or modification.

Although we will do our best to protect the personal information you provide to us, we advise that no method of electronic transmission or storage is 100% secure, and no one can guarantee absolute data security.

You are responsible for selecting any password and its overall security strength, ensuring the security of your own information within the bounds of our services. For example, ensuring any passwords associated with accessing your personal information and accounts are secure and confidential.

Children’s Privacy

We do not aim any of our products or services directly at children under the age of 13, and we do not knowingly collect personal information about children under 13.

Disclosure of Personal Information to Third Parties

We may disclose personal information to:

• a parent, subsidiary, or affiliate of the Company;
• third-party service providers for the purpose of enabling them to provide their services, including (without limitation) IT service providers, data storage, hosting and server providers, analytics, error loggers, debt collectors, maintenance or problem-solving providers, professional advisors, and payment systems operators;
• our employees, contractors, and/or related entities;
• our existing or potential agents or business partners;
• credit reporting agencies, courts, tribunals, and regulatory authorities, in the event you fail to pay for goods or services we have provided to you;
• courts, tribunals, regulatory authorities, and law enforcement officers, as required by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise, or defend our legal rights;
• third parties, including agents or sub-contractors, who assist us in providing information, products, services, or direct marketing to you;
• third parties to collect and process data;
• an entity that buys, or to which we transfer all or substantially all of our assets and business;
• With vendors, consultants and other service providers who need access to such information to carry out work on our behalf; it is our practice to require such parties to handle the information in a manner consistent with our policies;
• In response to a request for information if we believe disclosure is in accordance with, or as otherwise required by, any applicable law, regulation or legal process;
• If we believe your actions are inconsistent with the spirit or language of our user agreements or policies, or to protect the rights, property and safety of us or others;
• In connection with, or during negotiations of, any merger, sale of our assets, financing or acquisition of all or a portion of our business to another company; and
• With your consent or at your direction, including if we notify you through our Website that the information you provide will be shared in a particular manner and you provide such information.

Your Rights and Controlling Your Personal Information

• Your choice:If you provide us with personal information, you understand we will collect, hold, use, and disclose your personal information in accordance with this Privacy Policy. You do not have to provide personal information to us.
• Information from third parties:If we receive personal information about you from a third party, we will protect it as set out in this Privacy Policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person’s consent to provide the personal information to us.
• Access:You may request details of the personal information that we hold about you.
• Correction:If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant, or misleading, please contact us using the details provided in this Privacy Policy. We will take reasonable steps to correct any information found to be inaccurate, incomplete, misleading, or out of date.
• Non-discrimination:We will not discriminate against you for exercising any of your rights over your personal information. Unless your personal information is required to provide you with a particular service or offer (for example providing user support), we will not deny you goods or services and/or charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties, or provide you with a different level or quality of goods or services.
• Notification of data breaches:We will comply with laws applicable to us in respect of any data breach.
• Complaints:If you believe that we have breached a relevant data protection law and wish to make a complaint, please contact us and provide us with full details of the alleged breach. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint. You also have the right to contact a regulatory body or data protection authority in relation to your complaint.

Use of Cookies

We use “cookies” to collect information about you and your activity across our Website. A cookie is a small piece of data that our Website stores on your computer, and accesses each time you visit, so we can understand how you use our Website. This helps us serve you content based on preferences you have specified. Please refer to our Cookie Policy.

Business Transfers

If we or our assets are acquired, or in the event that we go out of business or enter bankruptcy, we would include data, including your personal information, among the assets transferred to any parties who acquire us. You acknowledge that such transfers may occur, and that any parties who acquire us may, to the extent permitted by applicable law, continue to use your personal information according to this Privacy Policy, which they will be required to assume as it is the basis for any ownership or use rights we have over such information.

Limits of Our Policy

Our Website may link to external sites that are not operated by us. Please be aware that we have no control over the content and policies of those sites and cannot accept responsibility or liability for their respective privacy practices.

Changes to This Policy

At our discretion, we may change our Privacy Policy to reflect updates to our business processes, current acceptable practices, or legislative or regulatory changes. If we decide to change this Privacy Policy, we will post the changes here at the same link by which you are accessing this Privacy Policy.