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Privacy Policy

Effective Date: July 31, 2025

1. Introduction

Ginnova Ltd. (trading as 'Ginnova Global') ('we', 'us', 'our') is committed to protecting your privacy and complying with the UK General Data Protection Regulation (UK GDPR) and the EU General Data Protection Regulation (GDPR). This Privacy Policy explains how we collect, use, store, protect, and share your personal data when you visit our website https://ginnova.co.uk or use our services.

For the purposes of UK GDPR and EU GDPR, Ginnova Ltd. is the 'data controller' of your personal data. Our company details are: Ginnova Ltd., registered in England and Wales under company number 16619391, registered office at 128 City Road, London, EC1V 2NX, United Kingdom. You can contact us regarding data protection matters at info@ginnova.co.uk.

2. What Personal Data We Collect

We collect and process the following categories of personal data:

• Contact Information: Name, email address, phone number, postal address when you contact us or subscribe to our newsletter.

• Professional Information: Company name, job title, professional interests, investor status when you engage with our investment services.

• Technical Data: IP address, browser type and version, time zone setting, browser plug-in types and versions, operating system, platform, and other technology on the devices you use to access our website.

• Usage Data: Information about how you use our website, products and services, including pages visited, time spent, referral source, and interaction tracking.

• Cookie Data: Information collected through cookies and similar tracking technologies as detailed in our Cookie Policy.

• Investment Information: Investment preferences, risk tolerance, financial information relevant to investor applications, and KYC/AML documentation.

• Third-Party Service Data: When you submit contact forms or send emails through our website, your information is initially processed by third-party email service providers (such as FormSubmit and email delivery services) before being delivered to us. We use these services to ensure reliable delivery and security of communications.

2. Legal Basis for Processing

We only process your personal data when we have a lawful basis to do so under UK GDPR and EU GDPR:

• Legitimate Interest: To provide our services, improve our website, for security purposes, and for direct marketing where it does not override your fundamental rights and freedoms.

• Consent: When you actively consent to us processing your data for specific purposes, such as marketing communications.

• Contractual Necessity: When processing is necessary to perform a contract with you.

• Legal Obligation: When we need to comply with UK and EU laws.

• Vital Interests: In rare cases where necessary to protect your vital interests or those of another person.

3. How We Use Your Personal Data

We use your personal data for the following purposes:

• Service Provision: To provide our services, respond to your inquiries, and manage our relationship with you.

• Communication: To send you information about our services and company updates (with your consent where required).

• Website Improvement: To analyse website usage patterns and improve our services and user experience.

• Legal Compliance: To comply with UK and EU laws and other legal obligations.

• Security: To protect our systems, prevent fraud, and ensure the security of our services.

• Marketing: To send you relevant marketing communications about our services (you can opt-out at any time).

4. Data Storage and Security

We implement appropriate technical and organisational security measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. These include:

• SSL encryption for data transmission

• Secure servers hosted in the UK and EU

• Regular security assessments and updates

• Access controls and authentication procedures

• Staff training on data protection

We retain your personal data for no longer than is necessary for the purposes for which it was collected, in accordance with our legal obligations and industry standards.

5. Your Rights Under UK GDPR and EU GDPR

You have the following rights regarding your personal data:

• Right of Access: To request a copy of your personal data we hold.

• Right to Rectification: To request correction of inaccurate personal data.

• Right to Erasure: To request deletion of your personal data in certain circumstances.

• Right to Restrict Processing: To request restriction of processing of your personal data.

• Right to Data Portability: To request transfer of your data to another controller.

• Right to Object: To object to processing of your personal data where based on legitimate interest.

• Rights Related to Automated Decision-Making: Including profiling.

To exercise these rights, please contact us at info@ginnova.co.uk. We will respond within one month in accordance with UK and EU law.

6. International Data Transfers

Your personal data is primarily stored and processed within the UK and European Union. We only transfer your personal data outside the UK and EU when:

• You have given explicit consent to the transfer

• The transfer is necessary for the performance of a contract with you

• The transfer is necessary for important reasons of public interest

• The transfer is necessary for the establishment, exercise or defence of legal claims

• We ensure appropriate safeguards are in place, such as Standard Contractual Clauses approved by the UK ICO and European Commission

7. Third-Party Sharing

We may share your personal data with third parties in the following circumstances:

• Service Providers: With our trusted third-party service providers who process data on our behalf (e.g., email providers, website hosting). All providers are subject to contractual obligations to protect your data.

• Legal Authorities: When required by UK or EU law, court order, or government regulation.

• Business Transfers: In the event of a merger, acquisition, or sale of assets, subject to appropriate protections.

We do not sell your personal data to third parties for marketing purposes.

8. Cookies and Tracking Technologies

Our website uses cookies and similar tracking technologies. For detailed information about the cookies we use, their purposes, and your choices, please refer to our Cookie Policy. You can control cookie settings through your browser preferences and our cookie consent banner.

9. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, applicable laws, or our business operations. We will notify you of any material changes by:

• Posting the updated policy on our website

• Sending you an email notification for significant changes

• Displaying prominent notice on our website

Your continued use of our services after any changes constitutes acceptance of the updated policy.

10. Contact Us

If you have any questions, concerns, or complaints about this Privacy Policy or our data handling practices, please contact:

Ginnova Ltd.

128 City Road, London, EC1V 2NX

United Kingdom

Email: info@ginnova.co.uk

Phone: +44 7520 655417

You also have the right to lodge a complaint with the UK Information Commissioner's Office (ICO) or your local data protection authority in the EU.

This document is legally binding and governs your relationship with Ginnova Ltd.