PRIVACY POLICY

Definitions and Interpretation

1. In this Privacy Policy, the following definitions are used:

2. In this Privacy Policy, unless the context requires a different interpretation:

1. the singular includes the plural and vice versa;
2. references to sub-clauses, clauses, schedules or appendices are to sub-clauses, clauses, schedules or appendices of this Privacy Policy;
3. a reference to a person includes firms, companies, government entities, trusts and partnerships;
4. "including" is understood to mean "including without limitation";
5. reference to any statutory provision includes any modification or amendment of it;
6. the headings and sub-headings do not form part of this Privacy Policy.

Scope of this Privacy Policy

3. This Privacy Policy applies only to the actions of Moxim Holdings Limited and Users with respect to this Website. It does not extend to any websites that can be accessed from this Website including, but not limited to, any links we may provide to social media websites.

4. For purposes of the applicable Data Protection Laws, Moxim Holdings Limited is the "data controller". This means that Moxim Holdings Limited determines the purposes for which, and the manner in which, your Data is processed.

Data Collected

5. We may collect the following Data, which includes personal Data, from you:

1. name;
2. contact information such as email addresses and telephone numbers;
3. company name;
4. communications (messages and inquiries you send to us, including messages you send to the AI concierge on the experience page);
5. IP address (automatically collected);
6. web browser type and version (automatically collected);
7. usage patterns;

in each case, in accordance with this Privacy Policy.

How We Collect Data

6. We collect Data in the following ways:

1. data is given to us by you; and
2. data is collected automatically.

Data That is Given to Us by You

7. Moxim Holdings Limited will collect your Data in a number of ways, for example:

1. when you contact us through the Website, by telephone, post, e-mail or through any other means;
2. when you elect to receive marketing communications from us;

in each case, in accordance with this Privacy Policy.

Data That is Collected Automatically

8. To the extent that you access the Website, we will collect your Data automatically, for example:

1. we automatically collect some information about your visit to the Website. This information helps us to make improvements to Website content and navigation, and includes your IP address, the date, times and frequency with which you access the Website and the way you use and interact with its content.

The AI Concierge

8A. The experience page includes an AI concierge. Messages you choose to send to the concierge (which may include financial details you volunteer, such as an approximate income) are processed by an AI language model to generate the conversation. On our side, the conversation is held only for the duration of your session (currently up to 30 minutes of inactivity) to keep its thread. Separately, a copy of the conversation is stored in your own browser, on your device, for up to 7 days so that you can pick up where you left off if you return — this copy never leaves your device for that purpose, and you can remove it at any time by choosing “Start again” in the conversation or by clearing your browser data. Except as described in clause 8C (early access) below, concierge conversations are not used for marketing and are not used to make any lending or eligibility decision. Everything the concierge shows is illustrative and educational only.

8C. Early access (pre-launch). While Moxim is in early access and the full experience is not yet open, the concierge does not hold a live conversation. If you send a first message and then choose to join the early-access list (by continuing with Google or submitting your email), that first message is saved together with your contact details as part of your early-access record, so that we can understand your interest and refer to it when we contact you about early access. Unlike the session-only handling described in clause 8A, this early-access record is retained as set out in the Data Retention section below, and the details you provide (including that message) may be used to contact you about early access and related updates. You can ask us to delete your early-access record at any time.

Cookies

8B. The Website sets two strictly-necessary, httpOnly session cookies when you use the AI concierge: one holding a session identifier so the conversation can keep its thread, and one binding that session to your browser. Both expire after 30 minutes of inactivity. If you choose to sign in, the Website also sets strictly-necessary, httpOnly cookies to hold your sign-in session and to complete the sign-in securely. If you provide a name, phone number or message while signing up, one further strictly-necessary, httpOnly cookie carries those details for up to ten minutes while your sign-in completes, so they can be attached to your early-access record once your email address is confirmed; it is cleared as soon as you return. The Website does not set analytics, advertising or tracking cookies.

8D. Analytics. We measure how the Website is used with privacy-preserving, cookieless analytics. This counts page views and referrers in aggregate, and also counts which parts of the Website were used — for example, that a sign-up was started or completed, or that the introduction finished playing. These are recorded as fixed labels and counts only: we do not record what you typed or any other free text. It does not set cookies, does not store anything on your device, does not use a persistent identifier, and does not follow you across other websites, so there is nothing here for you to consent to or opt out of — and we cannot identify you from it.

8E. Advertising measurement. If you reach the Website by clicking a Moxim advertisement, the advertising platform adds a click identifier to the web address. If you then join the early-access list on that visit, we record that identifier — on its own, separately from your contact details, and with nothing that identifies you attached to it — and share it with Google together with the fact that a sign-up happened, so that we can tell which advertisements are working. The identifier is read from the web address only: we do not store it, or anything else for this purpose, on your device. We do not share your name, email address, phone number or message with the advertising platform for this purpose, and this measurement is not used to build a profile of you or to target advertising at you.

Our Use of Data

9. Any or all of the above Data may be required by us from time to time in order to provide you with the best possible service and experience when using our Website. Specifically, Data may be used by us for the following reasons:

1. internal record keeping;
2. respond to your inquiries and provide customer support;
3. improvement of our products / services;
4. transmission by email of marketing materials;
5. send you updates about our launch and services (with your consent);
6. conduct business development activities;
7. contact for market research purposes which may be done using email, telephone or mail. Such information may be used to customise or update the Website;
8. compliance with legal and regulatory requirements;

in each case, in accordance with this Privacy Policy.

10. We may use your Data for the above purposes if we deem it necessary to do so for our legitimate interests. If you are not satisfied with this, you have the right to object in certain circumstances (see the section headed "Your rights" below).

11. For the delivery of direct marketing to you via e-mail, we'll need your consent, whether via an opt-in or soft-opt-in:

1. soft opt-in consent is a specific type of consent which applies when you have previously engaged with us (for example, you contact us to ask us for more details about a particular product/service, and we are marketing similar products/services). Under "soft opt-in" consent, we will take your consent as given unless you opt-out.
2. for other types of e-marketing, we are required to obtain your explicit consent; that is, you need to take positive and affirmative action when consenting by, for example, checking a tick box that we'll provide.
3. if you are not satisfied with our approach to marketing, you have the right to withdraw consent at any time. To find out how to withdraw your consent, see the section headed "Your rights" below.

Who We Share Data With

12. We may share your Data with the following groups of people for the following reasons:

1. third party service providers who provide services to us which require the processing of personal data - to assist with our operations;
2. relevant authorities - to comply with relevant laws and regulations;

12A. In practice, the service providers who process your Data on our behalf are: our website host and platform provider (Vercel); Google, whose Workspace services hold the early-access list; and our identity provider (Auth0, part of Okta), which handles sign-in and email verification. Where you reach us from an advertisement, the limited advertising measurement described in clause 8E is shared with Google Ads. Each acts under a contract that permits them to process your Data only on our instructions.

12B. International transfers. Some of these providers are based outside the United Kingdom, or may process or store Data outside it. Where Data is transferred out of the UK, we rely on the safeguards permitted by UK data protection law — either that the destination country has been formally recognised by the UK as providing adequate protection, or contractual protections in the form of the UK International Data Transfer Agreement or the UK Addendum to the European Commission’s standard contractual clauses. You can ask us for details of the safeguard applying to a particular provider by contacting us at the address in the “Your rights” section.

in each case, in accordance with this Privacy Policy.

Keeping Data Secure

13. We will use technical and organisational measures to safeguard your Data, for example:

1. access to your account is controlled by a password and a user name that is unique to you.
2. we store your Data on secure servers.

14. Technical and organisational measures include measures to deal with any suspected data breach. If you suspect any misuse or loss or unauthorised access to your Data, please let us know immediately by contacting us via this e-mail address: privacy@moxim.co.uk.

15. If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

Data Retention

16. Unless a longer retention period is required or permitted by law, we will only hold your Data on our systems for the period necessary to fulfil the purposes outlined in this Privacy Policy or until you request that the Data be deleted.

17. Even if we delete your Data, it may persist on backup or archival media for legal, tax or regulatory purposes.

Your Rights

18. You have the following rights in relation to your Data:

1. Right to access - the right to request (i) copies of the information we hold about you at any time, or (ii) that we modify, update or delete such information. If we provide you with access to the information we hold about you, we will not charge you for this, unless your request is "manifestly unfounded or excessive." Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.
2. Right to correct - the right to have your Data rectified if it is inaccurate or incomplete.
3. Right to erase - the right to request that we delete or remove your Data from our systems.
4. Right to restrict our use of your Data - the right to "block" us from using your Data or limit the way in which we can use it.
5. Right to data portability - the right to request that we move, copy or transfer your Data.
6. Right to object - the right to object to our use of your Data including where we use it for our legitimate interests.

19. To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Data (where consent is our legal basis for processing your Data), please contact us via this e-mail address: privacy@moxim.co.uk.

20. If you are not satisfied with the way a complaint you make in relation to your Data is handled by us, you may be able to refer your complaint to the relevant data protection authority. For the UK, this is the Information Commissioner's Office (ICO). The ICO's contact details can be found on their website at https://ico.org.uk/.

21. It is important that the Data we hold about you is accurate and current. Please keep us informed if your Data changes during the period for which we hold it.

Links to Other Websites

22. This Website may, from time to time, provide links to other websites. We have no control over such websites and are not responsible for the content of these websites. This Privacy Policy does not extend to your use of such websites. You are advised to read the Privacy Policy or statement of other websites prior to using them.

Changes of Business Ownership and Control

23. Moxim Holdings Limited may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of Moxim Holdings Limited. Data provided by Users will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use the Data for the purposes for which it was originally supplied to us.

24. We may also disclose Data to a prospective purchaser of our business or any part of it.

25. In the above instances, we will take steps with the aim of ensuring your privacy is protected.

General

26. You may not transfer any of your rights under this Privacy Policy to any other person. We may transfer our rights under this Privacy Policy where we reasonably believe your rights will not be affected.

27. If any court or competent authority finds that any provision of this Privacy Policy (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this Privacy Policy will not be affected.

28. Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.

29. This Agreement will be governed by and interpreted according to the law of England and Wales. All disputes arising under the Agreement will be subject to the exclusive jurisdiction of the English and Welsh courts.

Changes to This Privacy Policy

30. Moxim Holdings Limited reserves the right to change this Privacy Policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the Website and you are deemed to have accepted the terms of the Privacy Policy on your first use of the Website following the alterations. You may contact Moxim Holdings Limited by email at privacy@moxim.co.uk.