PRIVACY POLICY

1 INTRODUCTION

This Privacy Policy is provided by 4Admin Ltd. (Company number 15449473) trading as 4Admin

(hereinafter referred to as the “Company”, “we”, “our” or “us”) and describes how we collect, store,

use, share and process your information when you use our Services, including when you visit our

website at https://4admin.app or any other websites we operate with the same domain name and

different extensions (“Website”) for administrative tasks and document analysis; or engage with us

in other related ways, including sales, marketing, or events.

We take data protection very seriously. Please read this privacy policy carefully as it contains

important information on how we process personal data when you use our Services, including

document analysis and administrative tools.

It also explains your rights in relation to your personal data and how to contact us or the relevant

regulator in the event you have a complaint. Our collection, storage, use and sharing of your personal

data is regulated by law, including under the UK General Data Protection Regulation (UK GDPR),

the EU General Data Protection Regulation (EU GDPR), and the Swiss Federal Act on Data

Protection (FADP), depending on your location.

2 WHAT THIS POLICY APPLIES TO

This privacy policy relates to your use of the Website and for accessing the services through the

Website.

The Website may link to or rely on other apps, websites, APIs or service owned and operated by us

or by certain trusted third parties to enable us to provide you with the service through the Website.

These integrated third-party services, such as document processing APIs, administrative tools, and

secure storage providers, may process your data in accordance with their own privacy policies, which

will be clearly disclosed to you before any such integration is enabled. Any such processing will be

limited to what is necessary for providing the requested document analysis and administrative

services. For privacy information relating to these other apps, websites or service, please consult

their privacy policies as appropriate. For more information see the section ‘Who we share your

personal data with’ below.

3 PERSONAL DATA WE COLLECT ABOUT YOU

The personal data we process depends on your use of our Website and Services. This includes data

from documents you submit for analysis, as well as data from any optional integrations with email

communications, financial documents, and telephone systems that you choose to enable. These

integrations are entirely optional and not required to access core Services. For integrated data, we

maintain a 6-month automatic deletion policy, though you may manually delete this data at any time

through your account settings. We will process the following personal data:

Categories of

Personal Data

Processed

In more detail

Identify and account

data you input into the

Website

Registration is

mandatory in order to

access the services

through the Website

• Your email address, first and last name, gender, mobile phone

number, etc.

• Your account details, such as username and password

• When processing payments for our Services, payment details and

billingaddresses as required under our Terms are securelyhandled

by our payment processing partners through encrypted

connections. We do not store any financial information directly.

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Categories of

Personal Data

Processed

In more detail

Datacollected when

you use specific

functions in the

Website

Data you store online with us using the Website and placing a request

for accessing any services, through the Website, including your usage

history, service request history or preferences (while such data may not

always be personal data as defined at law in all cases, we will assume

it is and treat it in accordance with this policy as if it were)

Datacollected when

you permit the

collectionof location

data

If enabled, location data may be collected. This feature is optional and

can be controlled through your account settings.

Other data the

Website collects

automatically when

you use it

• Your activities on, and use of, the Website which reveal your

preferences, interests or manner of use of the Website and the

times of use

• Other information such as device type, IMEA numbers, MAC

address of networks, other unique device identification, device

operating system, mobile network information, storage usage, data

usage, time zone settings etc

Data collected when

you make an enquiry

with us

Your name and email address

Marketing and

communications data

Your preferences in receiving marketing emails from us and our third

parties and your communication preferences

If you do not provide personal data we ask for where it is required, including the geo-localisation

service, it may prevent us from providing certain features of the Services to you through the Website.

However, optional integrations with email, financial documents, and telephone systems are not

required to access and use the core Services.

We also collect, use and share aggregated data such as statistical or demographic data which is not

personal data as it does not directly (or indirectly) reveal your identity. For example, we may

aggregate individuals’ usage data (including information about how users interact with and use the

Website and place any request for accessing services through the Website) to calculate the

percentage of users accessing a specific feature of the Website in order to analyse general trends in

how users are interacting with the Website to help improve the Website and our offerings.

We collect and use this personal data for the purposes described in the section ‘How and why we

use your personal data’ below.

4 SENSITIVE DATA

Sensitive personal data (also known as special category data under UK/EU GDPR and particularly

worthy personal data under Swiss FADP) means information related to personal data revealing racial

or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership; genetic

data; biometric data (where used for identification purposes); data concerning health; data

concerning a person’s sex life; and data concerning a person’s sexual orientation.

We do not actively collect or process sensitive personal information as part of our core services.

Please do not submit sensitive personal data or information about criminal convictions to us through

our document analysis or administrative services.

If sensitive data is inadvertently submitted through the Website or our document analysis services,

we will promptly delete such data upon discovery or notification. Any forum features are not intended

for and must not be used to share sensitive personal data, as by publishing it through any forum

feature, we will assume that you have purposefully made such data manifestly public.

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5 LOCATION SERVICE/DATA

The Website may request your consent to use location services only when necessary for specific

features like address auto-completion or location-based document organisation. This consent is

requested each session (i.e. each time the Website is opened or has been placed in the

background for more than 30 seconds). At present, no features require such permissions.

We do not collect or process location data when location services are turned off in your device’s

settings. When you allow your device to use location service/data, data will also be collected by

Google in accordance with their Privacy Policy, as this is the analytics service integrated into our

app.

We exert no control over Google’s Privacy Policy and we therefore recommend that you consult

their privacy policy for further information on how Google protect personal data please visit their

site - https://policies.google.com/privacy?hl=en-US. For more information see the section ‘Who we

share your personal data with’ below.

6 HOW YOUR PERSONAL DATA IS COLLECTED

We use different methods to collect data from and about you including through:

(i) Your interaction with us: We collect personal data from you directly when you sign up to

the Website, upload documents for analysis, use our administrative tools, request specific

services, subscribe to our communications, request marketing emails, contact us directly

or reach out to us via social media, participate in our community forums when available, or

indirectly through your activity while using the Website, including your document

processing patterns and participation in feedback or surveys.

(ii) Automated technologies or interactions: As you interact with the Website, we will

automatically collect technical data about your equipment, browsing actions and patterns.

We collect this personal data by using cookies, server logs and other similar technologies.

7 HOW AND WHY, WE USE YOUR PERSONAL DATA

Under UK GDPR, EU GDPR, and Swiss FADP, we can only use your personal data if we have a

proper legal basis, specifically:

(i) where you have given consent

(ii) to comply with our legal and regulatory obligations

(iii) for the performance of a contract with you or to take steps at your request before entering

into a contract, or

(iv) for our legitimate interests or those of a third party

A legitimate interest is when we have a business or commercial reason to use your information, so

long as this is not overridden by your own rights and interests. We will carry out an assessment when

relying on legitimate interests, to balance our interests against your own. You can obtain details of

this assessment by contacting us (see ‘How to contact us’ below).

The table below explains what we use your personal data for and why.

What we use your personal

data for

Our reasons

Create and manageyour

account with us

To perform our contract with you or to take steps at your request

before entering into a contract

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What we use your personal

data for

Our reasons

Providing service and/or the

functionalities of the Website to

you

Depending on the circumstances:

• to perform our contract with you or to take steps at your

request before entering into a contract (in this case, the

contract means the Terms and Conditions of Use which apply

to the Website)

• to share your details with relevant service providers

necessary for delivering the requested document analysis or

administrative services through the Website

• the Maps Function will use data relating to your location only

based on your consent as described in ‘Location

service/data’ (above)

To enforce legal rights or defend

or undertake legal proceedings

Depending on the circumstances:

• to comply with our legal and regulatory obligations

• in other cases, for our legitimate interests or those of a third

party, i.e. to protect our business, interests and rights or

those of others

Sending relevant marketing

communications andfor making

personalised suggestions and

recommendations to you about

the products that may be of

interest to you based on your

profile data

Based on your explicit consent to receive direct marketing

communications about our document analysis and administrative

services. We will only send such communications after obtaining

your consent and will provide easy opt-out options in all marketing

messages. Marketing will be tailored to your service usage

patterns and preferences.

Carryout market research

through your voluntary

participation in surveys

Necessary for our legitimate interests to study how customers use

our Website and to help us improve and develop our Website and

services offered through the Website.

Communications with you not

related to marketing, including

about changes to our terms or

policies or updates concerning

the requests placed by you

through the Website or changes

to the Website or service or

other important notices

Depending on the circumstances:

• to comply with our legal and regulatory obligations

• to keep you updated on the requests placed by you

• in other cases, for our legitimate interests or those of a third

party, i.e., to provide the best service to you

Protect the security of systems

and data

We have organisational and technical processes and procedures

in place to protect your personal information in accordance with

UK GDPR, EU GDPR, and Swiss FADP requirements, including

encryption and secure processing measures for document

analysis, and any data obtained through optional email, financial

document, and telephone system integrations. For users in the

EU/EEA, UK, and Switzerland, we ensure that any transfer of

personal data outside these regions complies with applicable data

transfer requirements and safeguards. We maintain strict access

controls and secure deletion protocols for all analysed documents.

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 and improperly collect, access, steal, or

modify your information.

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What we use your personal

data for

Our reasons

Operational reasons, such as

improving efficiency, training,

and quality control or to provide

support to you

For our legitimate interests or those of a third party, i.e., to be as

efficient as we can so we can deliver the best service to you

Statistical analysis to help us

manage our business, e.g., in

relation to our performance,

customer base, functionalities

andofferings orother efficiency

measures

For our legitimate interests or those of a third party, i.e. to be as

efficient as we can so we can deliver the best service to you and

improve and develop our Service and the Website.

Updating and enhancing user

records

Depending on the circumstances:

• to perform our contract with you or to take steps at your

request before entering into a contract (in this case, the

contract means the Terms and Conditions of Use which apply

to the Website)

• to comply with our legal and regulatory obligations

• where neither of the above apply, for our legitimate interests

or those of a third party, e.g., making sure that we can keep

in touch with our customers about their accounts and new

products or functionalities related to the Website and the

products and service offered through the Website

To comply with our legal and

regulatory obligations

Depending on the circumstances:

• to perform our contract with you or to take steps at your

request before entering into a contract (in this case, the

contract means the Terms and Conditions of Use which apply

to the Website)

• to comply with our legal and regulatory obligations

where neither of the above apply, for our legitimate interests or

those of a third party, e.g. making sure that we can keep in touch

with our customers about their accounts and new services or

functionalities related to the Website

To share your personal data

with members of our group and

third parties in connection with a

significant corporate transaction

or restructuring, including a

merger, acquisition, asset sale,

initial public offering or in the

event of our insolvency.

In such cases information will be

anonymised where possible and

only shared where necessary

Depending on the circumstances:

• to comply with our legal and regulatory obligations

• in other cases, for our legitimate interests or those of a third

party, i.e., to protect, realise or grow the value in our

business and assets

See ‘Who we share your personal data with’ for further information on the steps we will take to

protect your personal data where we need to share it with others.

8 MARKETING

Communications with you, including marketing (communications with your consent), service updates

regarding core and integration features, and other important notices

We will send service-related communications and, with your consent, marketing communications

directly to you as a user of our services. All communications will be in accordance with your

preferences and applicable data protection laws.

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You will have the right to opt out of receiving marketing communications at any time by:

o contacting us at: support@4admin.co.uk

o usingthe‘unsubscribe’ link includedin all service-related communications you may receive

from us

We may share information in specific situations and with specific third parties, primarily to process

payments and securely store login information. When you upload documents for analysis to 4Admin,

or when we access data through authorised integrations (such as email and phone systems), we

process them securely using our AI hosted by Microsoft Azure. All uploaded documents are used

only for the requested analysis and are permanently deleted upon completion. Data that is not

viewed or modified for 9 months is automatically deleted, though you may manually delete this data

at any time through your account settings.

For more information on data subject rights and how they should be exercised through your

organisation as the data controller, see ‘Your rights’ below.

9 WHO WE SHARE YOUR PERSONAL DATA WITH

We may share personal information with specific third parties to process payments and securely

store information. When you upload documents to our Website, we use them for one-off analyses

with our AI – securely hosted by Microsoft Azure. Upon completion of analysis, the files are removed

entirely from our systems. Any third-party service providers we engage process data under strict

confidentiality obligations.

When you visit our Website or any related websites with the same domain name and different

extension, we act as a data controller for all processing activities, including website usage data, AI

analysis services, andintegrated communication systems. We engage service providers who provide

sufficient guarantees to implement appropriate technical and organisational measures that meet

GDPR requirements and ensure the protection of your rights. All service providers are bound by

written contracts that include specific data protection obligations, confidentiality requirements,

security measures, and appropriate safeguards for your personal data. and require them to only

process personal data on documented instructions from us, acting on behalf of the data controller

(your organisation). These contracts include confidentiality obligations, security requirements, and

audit rights that are at least as protective as those in our agreement with the data controller.

We or the third parties mentioned above may occasionally also need to share your personal data

with:

▪ external auditors, e.g. in relation to the audit of our accounts and our company —the

recipient of the information will be bound by confidentiality obligations

▪ professionaladvisors (such as lawyers andother advisors)—therecipient of theinformation

will be bound by confidentiality obligations

▪ law enforcement agencies, courts or tribunals and regulatory bodies to comply with legal

and regulatory obligations

▪ other parties in connection with a significant corporate transaction or restructuring,

including a merger, acquisition, asset sale, initial public offering or in the event of our

insolvency—usually, information will be anonymised but this may not always be possible,

however, the recipient of the information will be bound by confidentiality obligations

If you would like more information about who we share our data with and why,pleasecontact us (see

‘How to contact us’ below).

We will not share your personal data with any third parties other than those specified above.

10 HOW LONG YOUR PERSONAL DATA WILL BE KEPT

We will retain and process your personal data only for as long as necessary to fulfil the purposes

outlined in this privacy notice, or as required by applicable laws. For integrated email and telephone

communications data, we maintain a 6-month automatic deletion policy, though you may manually

delete this data at any time through your account settings. We may retain certain other data as

required by law or for legitimate business purposes, such as audit requirements, dispute resolution,

and enforcement of agreements.

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Following the end of the aforementioned retention period, we will delete or anonymise your personal

data in accordance with applicable technical standards and industry best practices, unless retention

is required by law or for legitimate business purposes as outlined above.

11 INTERNATIONAL TRANSFERS OF WORKFORCE REPRESENTATIVE DATA

While we primarily process and store your personal data within the UK and European Economic Area

(EEA) when you use our Website or any website of ours that links to this privacy notice, we may in

the future need to transfer your personal data outside these regions to provide our services

effectively. Any such transfers will only be made in compliance with UK GDPR, EU GDPR, and Swiss

data protection laws, with appropriate safeguards in place. If this changes, we would comply with

applicable UK laws designed to ensure the continued protection and privacy of your personal data.

Any updated destinations to which we send your personal data, would be indicated in the present

section and notified to you in accordance with the section on ‘Change to this privacy policy’ below.

Furthermore, under UK GDPR, EU GDPR, and Swiss Federal Data Protection Act, we will only

transfer personal data outside the UK, EEA, or Switzerland where permitted by applicable data

protectionlawsand with appropriate safeguards in place. Any such transfers would only occur where:

the UK government has decided the particular country ensures an adequate level of protection of

personal data (known as an ‘adequacy regulation’) under Article 45 of the UK GDPR; there are

appropriate safeguards in place, together with enforceable rights and effective legal remedies for

data subjects; or a specific exception applies under relevant data protection law. If international

transfers were to be implemented, they would only be done with prior notification to and approval

from the data controller. Accordingly, if we were to start transferring your personal data from the UK

to:

▪ The EEA: transfers would be conducted under the adequacy finding granted by the UK to

the EU under the Withdrawal Agreement; for any transfers from the EU to the UK, we would

rely on the adequacy regulation granted to the UK under the Adequacy Decision.

▪ For any transfers of personal data outside the UK/EEA, we will only process data in

compliance with appropriate safeguards under the UK GDPR and other applicable data

protection laws, which may include the relevant Standard Contractual Clauses or other

approved transfer mechanisms included in our data processing agreements

In the event we could not or choose not to continue to rely on either of those mechanisms at any

time we would not transfer your personal data outside the UK unless we could do so on the basis of

an alternative mechanism or exception provided by UK data protection law.

12 YOUR RIGHTS

You have certain rights regarding your personal information when using our website and services,

including any optional integrated communications features (such as email, financial documents, and

telephone system integrations). To exercise your rights, please contact us directly at

support@4admin.co.uk. If you do not agree with our policies and practices, including those regarding

optional integrations, please do not use our Services. We will consider and act upon any request in

accordance with applicable data protection laws.

Access to a copy of your personal data The right to be provided with a copy of your

personal data directly from us.

Correction (also known as rectification) The right to require us to correct any verified

inaccuracies in your personal data.

Erasure (also known as the right to be

forgotten)

The right to request deletion of your personal data

in certain situations, subject to our legitimate

business interests and other applicable legal

obligations. Note that some information may need

to be retained for legal or administrative purposes.

Restriction of use The right to request restriction of use of your

personal data in certain circumstances, e.g. if you

contest the accuracy of the data while we verify it.

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Data portability The right to receive the personal data you provided

to us in a structured, commonly used and machinereadable format and/or transmit that data to a third

party—in certain situations. We will fulfil these

requests directly as the data controller for our

services.

To object to use The right to object:

• at any time to your personal data being used

for direct marketing (including profiling)

• in certain other situations to our continued use

of your personal data, e.g. where we process

your personal data for our legitimate interests.

Not to be subject to decisions without

human involvement

The right not to be subject to a decision based

solely on automated processing (including profiling)

that produces legal effects concerning you or

similarly significantly affects you

For further information on each of those rights, including the circumstances in which they apply,

please contact us directly at arran@4admin.co.uk. You may find it helpful to refer to guidance from

the UK’s Information Commissioner, the European Data Protection Board, or the Swiss Federal Data

Protection and Information Commissioner on your rights under the UK GDPR, EU GDPR, or Swiss

Federal Data Protection Act respectively.

For any data rights requests or technical issues related to the platform, please:

o sufficient provide information to verify your identity as an authorised platform user

(including your full name, username, and any additional verification information we may

reasonably request), and

o clearly describe the technical platform issue you are experiencing or the support you need

13 KEEPING YOUR PERSONAL DATA SECURE

We have implemented appropriate technical and organisational security measures to prevent your

personal data from being accidentally lost, used, or accessed unlawfully. We limit access to personal

data to authorised personnel who have a genuine business need to access it for the purpose of

providing our administrative and document analysis services to you, subject to appropriate

confidentiality obligations.

We also have procedures in place to deal with any suspected data security breach. In the event of a

breach affecting your personal data, we will notify you and the relevant supervisory authorities

without undue delay, in accordance with applicable data protection laws.

For information about our platform security measures and how we protect data, please contact us.

14 COOKIES

A cookie is a small text file which is placed onto your device (e.g. your smartphone or other electronic

device) when you use the Website. When we use cookies on the Website, you will be presented with

a cookie banner that allows you to make informed choices about which cookies you accept.

Cookies help us to recognise you and your device and allow us to store some information about your

preferences or past actions, and remember your preferences next time you visit the Website.

For example, we may monitor how many times you use our Website, which features you access

(including any optional integration features), which processes you initiate or participate in, and which

parts of the Website you utilise most frequently. This information helps us to understand use of the

Website by our users. Some of this data will be aggregated or statistical, which means that we will

not be able to identify you individually. However, some cookies may collect personal data, as detailed

in the cookie table below and our Privacy Policy.

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For further information on our use of cookies, including a detailed list of what information we and our

authorised partners may collect through cookies to facilitate our administrative and document

analysis services, please see below.

For further information on cookies generally, including how to control and manage them, visit the

guidance on cookies published by the UK Information Commissioner’s Office, www.aboutcookies.org

or www.allaboutcookies.org.

15 CONSENT TO USE COOKIES AND CHANGING SETTINGS

We will ask for your permission through a clear and prominent notice before placing any nonessential cookies or other similar technologies on your device. Strictly necessary cookies that are

essential for core platform functionality (e.g. to maintain secure access to your account, enable

document processing features, manage administrative tasks, and ensure proper access to your

stored documents) will be placed without explicit consent, as they are required for the service to

function.

You can withdraw any previously given consent or manage your cookie preferences at any time by

using our cookie management tool available within the Website itself. Your choices will be respected

and implemented immediately upon selection. You can then adjust sliders or untick boxes as

appropriate to reflect your choice. It may be necessary to refresh or restart the Website for the

updated settings to take effect.

16 OUR USE OF COOKIES

We use the following cookies:

(i) Strictly necessary cookies: These are cookies that are required for the operation of the

Website. These essential cookies are always enabled because the Website will not work

properly without them. They include, for example, cookies that enable you to securely

access your account, manage your service settings, and utilise core platform features. You

can switch off these cookies in your browser settings but then you may not be able to

access all or parts of our Website.

(ii) Analytical or performance cookies: These allow us to recognise and count the number

of visitors and to see how users interact with our platform. This helps us improve platform

functionality, for example, by analysing which features are most used, how users navigate

through the Website, and ensuring efficient access to core Services and optional

integrations.

(iii) Functionality cookies: These are used to recognise when you return to the Website. This

enables us to personalise your workspace, maintain your account access, remember your

preferred settings including any enabled integration preferences, and customise your

experience based on your selected Services.

(iv) Targeting cookies: These cookies record your visit to the Website, the features you've

utilised, and your interaction patterns. We will use this information to customise your

experience, such as prioritising relevant features and optional integrations based on your

usage patterns and preferences.

The table below provides more information about the individual cookies we use and why:

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The cookies we use Name Purpose Whether cookie is

essential for us to

provide you with a

service that you have

requested and whether

we will seek your

consent before we

place the cookie

Google Analytics _ga This cookie is used to update

us on real-time usage of

4admin, i.e. the times you

login and the general, nonexact location (i.e. town/city)

where the app is being

accessed from.

This cookie collects

information such as the page

visited, the actions taken and

the amount of time spent on

each page.

We do not exert any control

over Google’s usage of

cookies, which can be read

more about here.

Yes, this cookie is

essential to ensure that

the app is not accessed

from unexpected

territories that may be

representative of

unauthorised access

posing a risk to the

platform andyourself, as

our user.

Authentication session

client_uat

These cookies track whether

you are logged into the app or

not. They are refreshed every

few minutes on an idle page,

else between each request.

Yes, this cookie is

essential to ensure that

only signed up, paying

users can access the

platform.It alsoprovides

a mechanism to ensure

frequent logins, to

prevent unauthorised

access.

17 HOW TO TURN OFF ALL COOKIES AND CONSEQUENCES OF DOING SO

If you do not want to accept cookies, you can use our cookie management tool to reject non-essential

cookies. You may also change your browser settings to block cookies, but this is not recommended

as it may affect essential platform functions. Please note that blocking all cookies (including essential

cookies) will significantly impact your ability to use the platform. Critical features such as secure

account access, document analysis tools, administrative task management, and platform

customisation may become unavailable. For further information about cookies and how to disable

them please go to the guidance on cookies published by the UK Information Commissioner’s Office,

www.aboutcookies.org or www.allaboutcookies.org.

18 HOW TO COMPLAIN

If you have any queries or concerns about how your personal data is processed on the Website, you

may contact us directly. For technical platform issues unrelated to personal data processing, you

may contact our support team (see 'How to contact us' below).

While you have the right to lodge a complaint with the UK Information Commissioner's Office (ICO),

the relevant EU Data Protection Authority in your country, or the Swiss Federal Data Protection and

Information Commissioner (FDPIC), we encourage you to first contact us directly with any concerns

so they can be addressed promptly.

The UK Information Commissioner's Office (ICO) can be contacted at https://ico.org.uk/make-acomplaint or telephone: 0303 123 1113. EU residents can find their national data protection authority

contact details at https://edpb.europa.eu/about-edpb/board/members_en. The Swiss FDPIC can be

contacted at https://www.edoeb.admin.ch.

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19 CHANGES TO THIS POLICY

We may change this privacy policy from time to time. When we make significant changes, we will

update the 'Last updated' date at the top of this privacy policy. For material changes affecting

personal data processing, we will notify you directly through the email address associated with your

account. Changes will also be posted on our platform. Your continued use of our platform after such

changes constitutes acceptance of the updated privacy policy.

20 HOW TO CONTACT US

You can contact us by email at arran@4admin.co.uk if you have any questions about this privacy

policy, the information we process, or our optional integration features. If you do not agree with our

policies and practices, please do not use our Services. We will respond directly to any questions,

concerns, or requests regarding your personal information or integrated data management.