Privacy Policy

This Privacy Policy sets out the approach taken by Edge App Ltd (“Edge App”, “we”, or “us”) to the personal information of our customers, website users and subscribers of our mobile application called the Vozz App. By joining and accessing the Vozz App, our website and the services within this platform (collectively the “Services”), you (“you”) agree that your personal information and data (collectively, “Personal Data”) will be dealt with in accordance with this privacy policy.

Edge App Ltd acts a data controller in its use of your Personal Data, as described in this privacy notice.

Privacy and confidentiality are a critical part of our Services. We take seriously how we collect, store and process your personal data. In line with our values, we want to be an engaged global community that shares ideas, experiences and networks. We treat your Personal Data seriously and make every effort to comply with our obligations under applicable privacy statutes, including the UK Data Protection Act (2018).

This Privacy Policy will inform you as to how we look after your Personal Data when you visit our website or use the Vozz App (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

1. The Personal Data we collect

A. Personal Data, or personal information, 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).

B. We may collect, use, store and transfer different kinds of Personal Data about you which we have grouped together as follows:
- Identity Data includes first name, last name, username or similar identifier.
- Contact Data includes email address and telephone number.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
- Profile Data includes your username and password, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our website, the Vozz App andthe Services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

C. We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your Personal Data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

D. 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.

2. How we collect Personal Data

A. We collect Personal Data directly from you when you register for an account, when you populate your profile screen, when you use certain Services (including when you create or share, and message or communicate with others). This can include information in or about the content you provide or about how you use our Services, such as the types of content you view or engage with, the people and groups you are connected to and how you interact with them or the frequency and duration of your activities.

B. When you populate your profile screen, we will ask you for and/or collect Personal Data directly (such as your headshot, work experience and education) or indirectly (through the “Sync with LinkedIn" option).

C. If you registered with us through the “Sync with LinkedIn" option, you and agree that we may access and store information from your LinkedIn profile.

D. Once you register with us and sign in to our Services, you are not anonymous to us.

E. As you interact with our website and the Vozz App, 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. We may also receive Technical Data about you if you visit other websites employing our cookies.

F. We may receive Technical Data about you from various third parties including analytics providers such as Google and Mixpanel, each based outside the UK.

G. Where we need to collect Personal Data by law, or under the terms of a contract we have with you, and you fail to provide that Personal Data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with Services). In this case, we may have to cancel a Service you have with us but we will notify you if this is the case at the time.

3. How we use your Personal Data

A. We will only use your personal data when the law allows us to. We will, most commonly, use your Personal Data in the following circumstances:
- Where we need to perform the contract, we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal obligation.

B. Generally, we do not rely on consent as a legal basis for processing your Personal Data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

C. We have set out below a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

D. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
- Personal Data and other details about you that you supply as part of the registration process or that are collected by us when you use the Services are used to provide you with the Services and information as set out in our Terms and Conditions. We will not use that information for any purpose other than as set out as part of the Services. Processing your Personal Data in this way is in the performance of a contract with you.
- We use information for general purposes to fulfil your requests for services, improve our services, contact you and conduct research. Processing your Personal Data in this way is (i) in the performance of a contract with you, and (ii) necessary for our legitimate interests (to keep our records updated, to study how customers use our products/services, to develop them and grow our business). We may provide reporting on aggregated engagement metrics to the schools, whose communities you join on the app.
- We use Technical Data to administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data). This is necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) and to comply with our legal obligations.
- We use Financial Data and Transaction Data to process and deliver our Services to you including managing payments, fees and charges, and undertaking our financial reporting obligations. Processing in this manner is necessary for our legitimate interests (to recover debts due to us) and to comply with our legal obligations.

E. We reserve the right to send you certain communications, such as service announcements and administrative messages and other communications relating to our Service, without offering you the opportunity to opt out of receiving them. Your rights to opt-out of other types of communications will be unaffected.

F. We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). You will receive marketing communications from us if you have requested information from us or purchased our Services from us and you have not opted out of receiving that marketing.

G. We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

H. You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you, or by contacting us at any time.

I. 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.

J. 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.

K. 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.

L. Given the nature of the Vozz App, there will be regular user to user communication (depending on how regularly you use the Vozz App), each Member is solely responsible for their own communication on the Vozz App and our processing of any Personal Data within those communications will be solely to facilitate the conversations in accordance with the performance of our contract with you.

4. Sharing your Personal Data

A. The Personal Data you provide us on the profile page, including but not limited to your name, headshot, work experience and education, will be displayed to other users of the platform in order to utilise the Services and outcomes intended from the Vozz App.

B. The Personal Data you shared with us during registration (excluding the above), will not be displayed to other users of the platform.

C. The Personal Data you provide us on the profile page, including your name, headshot, work experience and education, may be shared with the schools, whose communities you join on the Vozz App.

D. We do not rent, sell, or share Personal Data about you with other people or non-affiliated companies except under the following circumstances:

A. We may share your Personal Data with service provides (acting as processors) based in the UK who provide us with assistance in delivering our Services to you.
B. Responding to court orders, legal process, or to any legitimate request by authorities with which we must comply; and
C. To investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our terms of use, or as otherwise required by law.

E. We require all third parties to respect the security of your Personal Data and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our instructions.

F. We are based in the UK and we only use servers located within the UK and as such, we do not transfer your personal data outside the UK. However, if we are required to transfer your Personal Data out of the UK, we will confirm the same to you ensure a similar degree of protection is afforded to it by ensuring that safeguards are implemented. Such safeguards include either (i) only transferring your Personal Data to countries that have been deemed to provide an adequate level of protection for

Personal Data, or (ii) using specific contracts approved for use in the UK which give
Personal Data the same protection it has in the UK.

5. Edit and delete your information and preferences

A. You can edit your profile page Personal Data at any time.

B. You can re-sync your account with your LinkedIn Account at any time.

C. We will endeavor to correct any material error in your Personal Data that you make us aware of.

D. You may delete your account by emailing us at help@vozz.ai, verifying your password once more and confirming your choice to terminate the account. We may, however, retain certain aspects of your account and other Personal Data for the purposes of maintaining records of our dealings with you, analysis and/or statistics.

E. We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your Personal Data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

F. To determine the appropriate retention period for Personal Data, we consider the amount, nature and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

G. Please note that:
• Information that you have shared with others and that others have shared about you is not part of your account and will not be deleted when you delete your account or request that information about you be deleted; and
• It may take up to 60 days to delete data stored in backup systems

6. Confidentiality and security

A. Your Personal Data is stored in electronic and physical records maintained by us and / or our service providers.

B. The security of all personally identifiable information associated with you is taken very seriously and all Personal Data supplied is treated confidentially. We therefore have several security measures in place to try to protect against the loss, unauthorised use and corruption of any Personal Data that is under our control. We review our security and privacy policies regularly and improve them where it is reasonably possible to do so. We do not guarantee that loss, unauthorized use, corruption and/or alteration of information will never occur, but we use all reasonable efforts to prevent it.

C. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

D. Please note that the input of data over the internet is never fully secure. We cannot, therefore, guarantee the security of data you submit via the app in transit over the internet and any such submission is at entirely your own risk. Please ensure that you never leave your device logged on or use the Services in a public place where others can potentially see your details.

E. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

7. External links

A. If you follow a link to any external web links mentioned throughout the Application, please note that we do not control these external websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal information to these websites.

8. Your Legal Rights

A. Under certain circumstances, you have rights under data protection laws in relation to your personal data, including the right to:

- request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data that we hold about you and to check that we are lawfully processing it.
- request correction of your personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are
required to erase your personal data to comply with local laws. Please note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground, as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to
process your information which override your rights and freedoms.
- request restriction of processing your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

• If you want us to establish the data's accuracy.
• Where our use of the data is unlawful, but you do not want us to erase it.
• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
• You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.

- request transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- withdraw consent where we are relying on consent to process your personal data.
However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

B. If you wish to exercise any of the rights set out above, please contact us using the details in section 12 below.

C. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

D. We may need to request specific information from you to help us confirm your identity
and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

E. We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

9. Changes to this Privacy Policy

A. We may amend this policy from time to time. If we make any substantial changes in the way we use your Personal Data we will notify you by sending a notice to the primary email address specified in your account. However, you should review this policy on a regular basis to check for any changes made to it.

10. Contact

A. Our CEO is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, our privacy practices, or if you would like to exercise your legal rights, please contact the CEO using the details set out below.

Full name of legal entity: Edge App Ltd
Email address: help@vozz.ai
Postal address: Venture X White City, One Ariel Way, London, W12 7SL

B. You have the right to make a complaint at any time to the Information Commissioner's
Office (ICO), the UK regulator 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.