Privacy Policy

1. Introduction

Definitions

GDPR — means Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing directive 95/46/EC as updated, superseded or repealed from time to time.

Important Information and Who We Are

Welcome to 1fs Group Limited's Privacy and Data Protection Policy ("Privacy Policy").

At 1fs Group Limited ("we", "us", or "our") we are committed to protecting and respecting your privacy and Personal Data in compliance with the United Kingdom General Data Protection Regulation ("GDPR"), the Data Protection Act 2018 and all other mandatory laws and regulations of the United Kingdom.

This Privacy Policy explains how we collect, process and keep your data safe. The Privacy Policy will tell you about your privacy rights, how the law protects you, and inform our employees and staff members of all their obligations and protocols when processing data.

The individuals from which we may gather and use data can include:

• Customers
• Suppliers
• Business contacts
• Employees/Staff Members
• Third parties connected to your customers and any other people that the organisation has a relationship with or may need to contact.

This Privacy Policy applies to all our employees and staff members and all Personal Data processed at any time by us.

Who is Your Data Controller

1fs Group Limited is your Data Controller and responsible for your Personal Data. We are not obliged by the GDPR to appoint a data protection officer and have not voluntarily appointed one at this time. Therefore, any inquiries about your data should either be sent to us on email at support@1fs.co or sent in a letter to 12 Park House Richmond Hill, Richmond, TW10 6RA, United Kingdom.

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Processing Data on Behalf of a Controller and Processors' Responsibility to You

In discharging our responsibilities as a Data Controller we have employees who will deal with your data on our behalf (known as "Processors"). Therefore, the responsibilities described below may be assigned to an individual, or may be taken to apply to the organisation as a whole. The Data Controller and our Processors have the following responsibilities:

• Ensure that all processing of Personal Data is governed by one of the legal bases laid out in the GDPR;
• Ensure that Processors authorised to process Personal Data have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality;
• Implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk associated with the processing of Personal Data;
• Obtain the prior specific or general authorisation of the Controller before engaging another Processor;
• Assist the Controller in the fulfilment of the Controller's obligation to respond to requests for exercising the data subject's rights;
• Make available to the Controller all information necessary to demonstrate compliance with the obligations laid down in the GDPR and allow for and contribute to audits;
• Maintain a record of all categories of processing activities carried out on behalf of a Controller;
• Cooperate, on request, with the supervisory authority in the performance of its tasks;
• Ensure that any person acting under the authority of the Processor who has access to Personal Data does not process Personal Data except on instructions from the Controller; and
• Notify the Controller without undue delay after becoming aware of a Personal Data Breach.

2. Legal Basis for Data Collection

Types of Data / Privacy Policy Scope

"Personal Data" means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of Personal Data about you which we have grouped together below. Not all of the following types of data will necessarily be collected from you but this is the full scope of data that we collect and when we collect it from you:

• Profile/Identity Data: This is data relating to your first name, last name, gender, date of birth.
• Contact Data: This is data relating to your phone number, addresses, email addresses, phone numbers.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

The Legal Basis for Collecting That Data

There are a number of justifiable reasons under the GDPR that allow collection and processing of Personal Data. The main avenues we rely on are:

• "Consent": Certain situations allow us to collect your Personal Data, such as when you tick a box that confirms you are happy to receive email newsletters from us, or 'opt in' to a service.
• "Contractual Obligations": We may require certain information from you in order to fulfil our contractual obligations and provide you with the promised service.
• "Legal Compliance": We're required by law to collect and process certain types of data, such as fraudulent activity or other illegal actions.
• "Legitimate Interest": We might need to collect certain information from you to be able to meet our legitimate interests - this covers aspects that can be reasonably expected as part of running our business, that will not have a material impact on your rights, freedom or interests.

3. How We Use Your Personal Data

Our Uses

We will only use your Personal Data when the law allows us to. The examples provided below are indicative in nature and the purposes for which we use your data may be broader than described but we will never process your data without a legal basis for doing so and it is for a related purpose. For further inquiries please contact us.

Marketing and Content Updates

You will receive marketing and new content communications from us unless you specifically request that you would not like to receive these communications. From time to time we may make suggestions and recommendations to you about goods or services that may be of interest to you.

Change of Purpose

We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Account Information Services (AIS)

1fs Wealth Limited provides you with regulated account information services as an agent of Plaid Financial Ltd., an authorised payment institution regulated by the Financial Conduct Authority under the Payment Services Regulations 2017 (Firm Registration Number: 804718) for the provision of payment services, including account information services.

4. Your Rights and How You Are Protected by Us

What Control Do I Have Over 1fs Group Limited's Use Of My Personal Data?

You may delete your account at any time – this will remove your account page from our systems and our related software. We guarantee this will delete all stored data.

Your account information will be protected by a password for your privacy and security. You need to prevent unauthorized access to your account and personal information by selecting and protecting your password appropriately and limiting access to your computer or device and by signing off after you have finished accessing your account.

California Privacy Rights: Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of personal customer information which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to support@1fs.co.

How Does 1fs Group Limited Protect Customers' Personal Data?

We are concerned with keeping your data secure and protecting it from inappropriate disclosure. We implement a variety of security measures to ensure the security of your Personal Data on our systems, including data encryption at rest and in transit. Any Personal Data collected by us is only accessible by a limited number of employees who have special access rights to such systems and are bound by obligations of confidentiality.

If and when we use subcontractors to store your data, we will not relinquish control of your Personal Data or expose it to security risks that would not have arisen had the data remained in our possession. However, unfortunately no transmission of data over the internet is guaranteed to be completely secure. It may be possible for third parties not under the control of 1fs Group Limited to intercept or access transmissions or private communications unlawfully. While we strive to protect your Personal Data, we cannot ensure or warrant the security of any Personal Data you transmit to us. Any such transmission is done at your own risk.

Opting Out Of Marketing Promotions

You can ask us to stop sending you marketing messages at any time by email. Where you opt out of receiving these marketing messages, we will continue to retain other Personal Data provided to us as a result of interactions with us not related to your marketing preferences.

How to Request your Data and the Process for Obtaining it

You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, if your request is clearly unfounded, we could refuse to comply with your request.

We may need to request specific information from you to help us confirm your identity and ensure you have the right to access your Personal Data. This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it.

The Right of Access

We, as the data controller, must provide you with the following: confirmation that your data is being processed, access to your personal data, and other supplementary information. For further information on how to make a Subject Access Request application contact support@1fs.co.

The Right to Rectification

You can ask us to correct any personal information it holds about you to ensure your data is accurate. You may also ask us to complete incomplete data held about yourself.

The Right to Erasure / Be Forgotten

You have the right to (under certain circumstances) ask for your personal data to be erased where:

• Your personal data is no longer necessary in relation to the purpose for which it was collected/processed
• You withdraw your consent or object to the processing and there is no overriding legitimate interest to continue processing
• You object to the processing and there are no overriding legitimate grounds for the processing
• Your personal data was processed for direct marketing purposes
• Your personal data was unlawfully processed or should be erased to comply with a legal obligation
• Your personal data is processed in relation to the offer of information society services to a child

We can refuse to erase your personal data where it is processed to comply with a legal obligation, for the exercise or defence of legal claims, or for purposes relating to public health, archiving in the public interest, scientific/historical research or statistics.

The Right to Restrict Processing

You have the right to restrict the processing of personal data held by us where you have contested its accuracy, you have objected to the processing, processing is unlawful, or we no longer need the data but you require it to establish, exercise or defend a legal claim.

The Right to Data Portability

The right to data portability allows individuals to move, copy or transfer personal data easily from one IT environment to another in a safe and secure way. This right only applies to personal data that an individual has personally provided to us, where the processing is based on consent or the performance of a contract, and where processing is carried out by automated means.

The Right to Object

You have the right to object to the processing of your personal data in certain circumstances and have an absolute right to stop your data from being used for direct marketing. In other circumstances, the right to object is not absolute and you must give specific reasons why you are objecting to the processing of your data.

5. Your Data and Third Parties

Will We Share Your Data With Third Parties?

We may also share Personal Data with interested parties in the event that 1fs Group Limited anticipates a change in control or the acquisition of all or part of our business or assets or with interested parties in connection with the licensing of our technology.

If 1fs Group Limited is sold or makes a sale or transfer, we may, in our sole discretion, transfer, sell or assign your Personal Data to a third party as part of or in connection with that transaction. We may share your Personal Data at any time if required for legal reasons or in order to enforce our terms or this Privacy Policy.

Analytics & Tracking Technologies

We use Google Analytics 4 (GA4) to understand how visitors engage with our website and to enhance user experience. GA4 employs first-party cookies to distinguish between users and sessions. These cookies generally have a 2-year expiration period.

• No personal data (PII) is collected via GA4.
• Cookies are only set after you give consent through our cookie banner or cookie settings.
• To opt out of tracking-related cookies, please visit our cookie settings page or adjust your browser preferences.
• To opt out entirely from Google Analytics tracking, install Google's browser add-on.
• GA4 cookies store a unique identifier and follow standard browser expiry (usually up to 2 years).
• GA4 does not collect IP addresses or personally identifiable information by default.

We use aggregated data solely to monitor website performance and usability — not for individual profiling.

Third-Party Links

This Site may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Site, we encourage you to read the privacy policy of every website you visit.

6. How Long Will We Retain Your Data For?

We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for. We may retain your Personal Data for a longer period than usual in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

7. Age Limit for Our Users

You must not use 1fs Group Limited unless you are aged 18 or older. If you are under 18 and you access 1fs Group Limited by lying about your age, you must immediately stop using 1fs Group Limited. This website is not intended for children and we do not knowingly collect data relating to children.

8. International Transfer of Data

Your information will be stored and processed in the UK and EEA where 1fs Group Limited has facilities. We are currently storing data in the UK and EEA and so, by using 1fs Group Limited, you are permitting and consenting to the transfer of information, including Personal Data, within the UK and EEA.

9. Notification of Changes and Acceptance of Policy

We keep our Privacy Policy under review and will place any updates on this webpage. This version is dated 4 March 2020. By using 1fs Group Limited, you consent to the collection and use of data by us as set out in this Privacy Policy. Continued access or use of 1fs Group Limited will constitute your express acceptance of any modifications to this Privacy Policy.

10. Interpretation

All uses of the word "including" mean "including but not limited to" and the enumerated examples are not intended to in any way limit the term which they serve to illustrate. Any email addresses set out in this policy may be used solely for the purpose for which they are stated to be provided, and any unrelated correspondence will be ignored.

Our staff are not authorised to contract on behalf of 1fs Group Limited, waive rights or make representations (whether contractual or otherwise). If anything contained in an email from a 1fs Group Limited address contradicts anything in this policy, our terms or any official public announcement on our website, or is inconsistent with or amounts to a waiver of any 1fs Group Limited rights, the email content will be read down to grant precedence to the latter. The only exception to this is genuine correspondence expressed to be from the 1fs Group Limited legal department.

11. Data Processing Obligations

In respect of any Personal Data to be processed by a party acting as Data Processor pursuant to this Agreement for which the other party is Data Controller, the Data Processor shall:

• Provide appropriate technical and organisational measures designed to ensure the protection of the rights of the data subject and to ensure a level of security appropriate to the risk;
• Not engage any sub-processor without the prior specific or general written authorisation of the Data Controller;
• Ensure that any sub-processor is subject to data protection obligations similar to those applicable to the Data Processor;
• Process that personal data only to perform its obligations under this Agreement or other documented instructions and for no other purpose;
• On termination of this Agreement, at the Data Controller's option either return or destroy the personal data (including all copies of it) immediately;
• Ensure that all persons authorised to access the personal data are subject to obligations of confidentiality;
• Make available to the Data Controller all information necessary to demonstrate compliance with the obligations laid out in Article 28 of GDPR;
• Provide assistance to the Data Controller in connection with the fulfilment of the Controller's obligation to respond to requests for the exercise of data subjects' rights;
• Notify the Data Controller immediately upon becoming aware of a security breach (and in any event, within 24 hours) in respect of Personal Data that it processes on behalf of the Data Controller;
• Maintain a record of its processing activities in accordance with Article 30(1) of the GDPR; and
• Allow the Data Controller to conduct an audit of compliance no more frequently than once per year during the term and on at least 7 days' notice.

Contact Us

If you have any questions about this Privacy Policy or would like to withdraw your consent or opt-in/out of 1fs Wealth's service, you can contact us:

• By email: support@1fs.co
• By visiting this page on our website: www.1fs.co