Privacy Policy — ComplyMate

This Privacy Notice for 1494 Group Limited ("we", "us", or "our") describes how and why we might access, collect, store, use, and/or share ("process") your personal information when you use our services ("Services"), including when you:

• Download and use our mobile application, ComplyMate

• Use ComplyMate. The App helps directors and officers of UK limited companies track and manage their statutory filing obligations with Companies House, in particular Confirmation Statements and Annual Accounts. The App retrieves publicly available company data from the Companies House API and presents it to the user in an organised, easy-to-follow format, including a dashboard of tracked companies, a calendar of upcoming deadlines, and notifications when a filing is submitted or a deadline changes. Depending on the user's subscription tier, the App also provides company tagging, private notes, bulk import of multiple companies via CSV, and access to a company's filing history and officer information. The App is a tracking and reminder tool only. It does not submit, file, or lodge any documents with Companies House or any other government body on the user's behalf, and it does not constitute accounting, legal, or tax advice. Users remain solely responsible for meeting their own statutory filing obligations, and for verifying the accuracy and currency of any information displayed in the App against the official Companies House register. 1494 Group Ltd is not affiliated with, endorsed by, or acting on behalf of Companies House. The App is offered on a subscription basis, with a free tier and paid tiers offering additional features and higher usage limits.

• Engage with us in other related ways, including responding to your inquiries or feedback

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us via the contact form on our website, or by email at complymate@1494group.com.

Summary of Key Points

This summary provides key points from our Privacy Notice, but you can find out more details about any of these topics by using our table of contents below to find the section you are looking for.

What personal information do we process? When you use our Services, we may process personal information depending on how you interact with us and the choices you make. Learn more about personal information you disclose to us (Section 1).

Do we process any sensitive personal information? Some information may be considered "special" or "sensitive" in certain jurisdictions — for example racial or ethnic origin, sexual orientation, or religious beliefs. We do not process sensitive personal information.

Do we collect any information from third parties? We do not collect information about you from third-party sources such as data brokers or social login providers. The App displays certain publicly available information about company officers and directors, sourced from the UK Companies House public register, for the purposes of the App's core compliance-tracking functionality. This information is drawn from a public register maintained by Companies House and is not otherwise obtained by us from third parties.

How do we process your information? 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 process your information only when we have a valid legal reason to do so. Learn more about how we process your information (Section 2).

In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties. Learn more about when and with whom we share your personal information (Section 4).

How do we keep your information safe? We have adequate organisational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security. Learn more about how we keep your information safe (Section 6).

What are your rights? Depending on where you are located geographically, applicable privacy law may mean you have certain rights regarding your personal information. Learn more about your privacy rights (Section 7).

How do you exercise your rights? The easiest way to exercise your rights is via the contact form on our website, or by contacting us at complymate@1494group.com. We will consider and act upon any request in accordance with applicable data protection laws.

Table of Contents

What Information Do We Collect?
How Do We Process Your Information?
What Legal Bases Do We Rely On?
When And With Whom Do We Share Information?
How Long Do We Keep Your Information?
How Do We Keep Your Information Safe?
What Are Your Privacy Rights?
Controls For Do-Not-Track Features
Do We Make Updates To This Notice?
How Can You Contact Us?
Review, Update, Or Delete Your Data

1. What Information Do We Collect?

Personal information you disclose to us

We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Services, 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
The content of any notes you create within the App about your tracked companies
The UK limited companies you choose to track, and any tags or labels you assign to them

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 Apple Inc. and Google LLC (Google Play). You may find their privacy notice links here: apple.com/uk/legal/privacy and policies.google.com/privacy.

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?

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 facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.
To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.
To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.
To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.
To fulfil and manage your orders and payments. We may process your information to fulfil and manage your subscription orders and payments made through the Services.
To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.
To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.
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.
Companies House data retrieval and display. To retrieve and display Companies House filing and compliance data associated with the companies a user chooses to track within the App. (Retention period: for as long as the user keeps the company tracked in their account, or until the account is deleted.)
Deadline monitoring and notifications. To monitor tracked companies for filing submissions and deadline changes, and to notify users of relevant updates accordingly. (Retention period: individual notifications are automatically deleted 12 months after creation.)
Email verification for paid tiers. To verify a user's email address before granting access to paid subscription features, for fraud and chargeback prevention purposes. (Retention period: for as long as the account remains active on a paid or paid-eligible plan.)

3. What Legal Bases Do We Rely On To Process Your Personal Information?

We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e. legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfil our contractual obligations, to protect your rights, or to fulfil our legitimate business interests.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order 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 your personal information for a specific purpose. You can withdraw your consent at any time (see "Withdrawing your consent" under Section 7).
Performance of a Contract. We may process your personal information when we believe it is necessary to fulfil our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.
Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information to diagnose problems and/or prevent fraudulent activities; understand how our users use our products and services so we can improve user experience; and protect the integrity of our tiered pricing model and ensure fair usage of free-tier features for all users.
Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

4. When And With Whom Do We Share Your Personal Information?

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

We use a small number of third-party service providers to operate the Services, each of whom processes personal information on our behalf and only to the extent necessary to provide their service to us:

Google LLC (Firebase / Google Cloud Platform). Firebase provides our backend infrastructure, including account authentication and database storage. All data described in this Notice is hosted and processed via Firebase, based in the United Kingdom. Google's privacy notice is available at: policies.google.com/privacy.
Apple Inc. and Google LLC (Google Play), as payment processors. As described under "Payment Data" in Section 1, all subscription payments are processed and stored directly by Apple and Google — we never receive or store your card details.

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

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 to another company.

5. How Long Do We Keep Your Information?

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). Specific retention periods for certain kinds of information are set out in Section 2 above. Where no specific period is given, we will not keep your personal information for longer than the period of time in which you have an account with us.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

6. How Do We Keep Your Information Safe?

We aim to protect your personal information through a system of organisational and technical security measures.

We have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

7. What Are Your Privacy Rights?

In some regions, such as the European Economic Area (EEA), United Kingdom (UK), and Switzerland, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time, depending on your country, province, or state of residence.

In some regions (like the EEA, UK, and Switzerland), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure, (iii) to restrict the processing of your personal information, (iv) if applicable, to data portability, and (v) not to be subject to automated decision-making. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us using the contact details in Section 10 below.

We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the UK and are unhappy with how we have handled your personal information, you can make a complaint directly to us. This is in addition to the rights you have under the UK General Data Protection Regulation and the Data Protection Act 2018.

How to contact us

Via the contact form on our website
Email: complymate@1494group.com
Post: see Section 10 below

What happens after you complain

We will acknowledge your complaint within 30 days of receiving it.
We will investigate without unjustifiable or excessive delay.
We will keep you informed of progress and explain the outcome.

If you are not happy with our final response, you can refer your complaint to the Information Commissioner's Office, the UK supervisory authority:

Website: ico.org.uk/make-a-complaint
Helpline: 0303 123 1113
Post: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or the UK data protection authority.

If you are located 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 your consent at any time by contacting us using the contact details in Section 10 below. However, please note that this will not affect the lawfulness of the processing before its withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can contact us using the contact information provided in Section 10.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

If you have questions or comments about your privacy rights, you may contact us via the contact form on our website, or by email at complymate@1494group.com.

8. Controls For Do-Not-Track Features

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognising and implementing DNT signals has been finalised. As such, 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 the future, we will inform you about that practice in a revised version of this Privacy Notice.

9. Do We Make Updates To This Notice?

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 to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.

10. How Can You Contact Us About This Notice?

If you have questions or comments about this notice, you may contact us via the contact form on our website, email us at complymate@1494group.com, or contact us by post at:

1494 Group Limited

Fifth Floor, 167-169 Great Portland Street

London, England, W1W 5PF

United Kingdom

11. How Can You Review, Update, Or Delete The Data We Collect From You?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law.

To request to review, update, or delete your personal information, please contact us via the contact form on our website, or by email at complymate@1494group.com.