Privacy Policy

Introduction

Important information and who we are

Welcome to Joyful Insights Ltd's Privacy and Data Protection Policy ("Privacy Policy").

At Joyful Insights Ltd ("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
• 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.

Your Data Controller and Data Protection Officer

Joyful Insights Ltd is your Data Controller and responsible for your Personal Data.

We have appointed a data protection officer ("DPO") who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights surrounding your Personal Data please contact the DPO using the details set out below:

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"). The responsibilities 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, including inspections, conducted by the Controller or another auditor mandated by the Controller;
• 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;
• Designate a data protection officer where required by the GDPR, publish their details and communicate them to the supervisory authority;
• Support the data protection officer in performing their tasks by providing resources necessary to carry out those tasks and access to Personal Data and processing operations and to maintain their expert knowledge;
• 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;
• Notify the Controller without undue delay after becoming aware of a Personal Data Breach.

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:

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.

How we use your Personal Data

We will only use your Personal Data when the law allows us to.

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 our Data Protection Officer.

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.

Your rights and how you are protected by us

Your legal rights

Under certain circumstances, you have the following rights under data protection laws in relation to your personal data:

• Right to be informed. You have a right to be informed about our purposes for processing your personal data, how long we store it for, and who it will be shared with.
• Right of access. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Right to rectification. You have a right to request correction of the personal data that we hold about you.
• Right to erasure. You have the right to ask us to delete or remove personal data where there is no good reason for us continuing to process it.
• Right to object. You can object to the processing of personal data we hold about you.
• Right to restrict processing. You have the right to request the restriction or suppression of their personal data.
• Right to data portability. You have the right to request the transfer of your personal data to you or to a third party.

If you wish to make a request under any of these rights, please contact us at data@joyfulinsights.com.

How Joyful Insights Ltd protects customers' Personal Data

We are concerned with keeping your data secure and protecting it from inappropriate disclosure. 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.

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.

Your data and third parties

Sharing your data with third parties

We may also share Personal Data with interested parties in the event that Joyful Insights Ltd 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.

How long we retain your data

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.

International transfer of data

Your information may be stored and processed in the US or other countries or jurisdictions outside the US where Joyful Insights Ltd has facilities. By using Joyful Insights Ltd, you are permitting and consenting to the transfer of information, including Personal Data, outside of the US.

Notification of changes and acceptance of policy

We keep our Privacy Policy under review and will place any updates here. This version is dated 10th February 2026.

By using Joyful Insights Ltd, you consent to the collection and use of data by us as set out in this Privacy Policy. Continued access or use of Joyful Insights Ltd will constitute your express acceptance of any modifications to this Privacy Policy.

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 Joyful Insights Ltd, waive rights or make representations (whether contractual or otherwise). If anything contained in an email from a Joyful Insights Ltd 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 Joyful Insights Ltd 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 Joyful Insights Ltd legal department.