Privacy Policy

1. Introduction

1.1. Novo World Ltd and our Group Companies ("Ampere", "we", "our", "us" as applicable) are an all-in-one financial service for business uniting accounts, payments, cards and acquiring in one unique ecosystem. Ampere consists of an all-in-one financial service platform (the "Platform") allowing customers and merchants to process, manage, pay and hold different currencies in a secure and seamlessly integrated way (the "Ampere Services" or "Services"). We are fully committed to the requirements of the European Union's General Data Protection Regulation ("GDPR"). Ampere is the "data controller" of your information collected in provision of the Ampere Service. The contact information of the controller of the Ampere Services is as follows:

Name: NOVO WORLD LTD
Registry Number: 13894648
Address: Meridien House, 42 Upper Berkeley Street, London, England, W1H 5QL
Email: support@ampere.co.uk

2. Purpose of the Policy

2.1. The purpose of this Privacy Policy is to provide you with information about the processing and protection of your personal data, which we collect as you access or use the Ampere Services (collectively the "Services"). In this Policy, we explain our reasons for processing of your personal data and how we collect, handle, and store it. We also explain what your rights are regarding this data, how you can contact us and what methods you have if you desire to exercise these rights.

2.2. Please read this Policy carefully as it is legally binding. This Policy is completed and effective as of the last updated date above.

2.3. By using the Services you agree to the terms of this Privacy Policy as may be amended by us from time to time.

3. Principles we follow when processing your personal data

3.1. We are committed to processing your personal data in accordance with our responsibilities under the GDPR and data protection principles outlined below. The data protection principles are the following:

• 3.1.1. Accuracy: We will take reasonable steps to ensure that your data is accurate, maintain this accuracy and ensure that any inaccuracies are erased or rectified without delay.
• 3.1.2. Fairness and lawfulness: We collect and process your personal data in a legal and fair manner.
• 3.1.3. Necessity ("data minimization"): We process your personal data in a way that is adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed.
• 3.1.4. Restricted to a specific purpose ("purpose limitation"): We process your personal data only for specific, explicit and legitimate purposes as outlined in this Policy.
• 3.1.5. Security and Confidentiality: We process your personal data in a way that ensures security and confidentiality of the personal data using appropriate technical or organizational measures.
• 3.1.6. Transparency: You are informed of how your data is being collected, processed and used.

4. How we collect your data

4.1. We collect personal data which you provide us directly. For example, when you: (i) open an Ampere Account, or (ii) communicate with us.

4.2. We collect personal data through your use of the Services. For example, when you use our Services, we may gather the information relating to such usage, either independently or through the help of third-party services as detailed in our Cookie policy.

5. What type of personal data we collect

5.1. Below is a list of personal information we collect through our Services which is submitted directly by you:

• 5.1.1. First name
• 5.1.2. Last name
• 5.1.3. Date of birth
• 5.1.4. Phone number
• 5.1.5. E-mail address
• 5.1.6. Country of Residence
• 5.1.7. Residential Address
• 5.1.8. Card/Bank account number and other financial information that we may need in order to provide our Services
• 5.1.9. device fingerprint (e.g. geolocation data & IP address)
• 5.1.10. photographic ID
• 5.1.11. Passport/ID data
• 5.1.12. Information provided in the utility bill/address confirmation
• 5.1.13. "Identifiers" – information which we treat as your personal data as it relates to you and your use of our Services but is not directly provided by you;
• 5.1.14. transaction and activity information on the Services.

5.2. We reserve a right to request from you any additional information confirming your age and/or any other information related to the usage of our Services. We have to do this for a number of reasons, including to check your identity, and to meet our legal and regulatory requirements.

6. How we use your personal data

6.1. The information we collect, which may include your personal data, is used for the following purposes:

• 6.1.1. to set up your Ampere Account and to provide our Services (e.g. process your payments; etc.)
• 6.1.2. to identify and authenticate your access to certain features of the Services;
• 6.1.3. to communicate with you and to keep you informed of our latest updates;
• 6.1.4. to serve you advertisements when you use our Services;
• 6.1.5. to perform research or to conduct anonymous analytics in order to improve and customise our Services to your needs and interests;
• 6.1.6. to support and troubleshoot our Services and to respond to your queries; and
• 6.1.7. to investigate violations and enforce our policies, and as required by law, regulation or other governmental authority; or
• 6.1.8. to comply with a subpoena or similar legal process; or
• 6.1.9. respond to a government request;
• 6.1.10. to monitor transactions for the purposes of preventing fraud, money laundering and terrorist financing. Please note that this may involve utilising products and services from third parties (including the sharing of information with such third parties) to monitor transactions, detect patterns requiring investigation or otherwise profile and assess the likelihood of fraud or money laundering occurring;
• 6.1.11. to handle any concerns, complaints or disputes you may have;

6.2. We may use the information obtained about you from credit reference agencies and fraud prevention agencies to check you and/or your business’s credit status/profile and identity on a periodic basis. The agencies may record our enquiries and may in turn share it with other third parties and fraud prevention agencies. Information regarding how you manage your account, and/or any debt may be supplied to other organisations by credit reference and fraud prevention agencies to perform similar checks and to trace your whereabouts and recover any debts that you owe. Records remain on file at such agencies for 6 years after they are closed, whether settled by you or defaulted. If you would like further information on our use of credit reference agencies, please contact us.

7. Legal Basis for collecting and processing your personal data

7.1. Ampere's legal basis for collecting and using the personal data described in this Policy depends on the personal data we collect and the context in which we collect the information. Under the GDPR, the lawful bases we rely on for processing your personal data are:

7.2. Your consent: You have given Ampere permission to collect and process your personal data by signing up for an Ampere Account or using our Service in our Ampere App or Ampere Website according to the stipulated Terms and Conditions. Kindly note that you can withdraw your consent at any time by contacting us, using the contact information detailed in this Policy.

7.3. Contract: Ampere is entering into a contract with you if you use our Services according to the Terms and Conditions. We collect information to fulfil our contractual obligation to you.

7.4. Legal obligation: Ampere needs to comply with legal and regulatory obligations which require us to collect this information. For example, the Anti Money Laundering and Counter-Terrorism Financing legislation.

7.5. Legitimate interests: When processing your personal data is in Ampere´s legitimate interests such as providing, maintaining, improving and developing effective services to meet the needs of our users, and developing useful new features.

8. Data Subject Access Request

8.1. Data subjects may make subject access requests ("SARs") at any time to find out more about the personal data which we hold, what it is doing with that personal data, and why.

8.2. Responses to SARs are normally made within one month of receipt, however, this may be extended by up to two months if the SAR is complex and/or numerous requests are made. If such additional time is required, the data subject shall be informed accordingly.

8.3. We do not charge a fee for the handling of normal SARs. We reserve the right to charge reasonable fees for additional copies of information that has already been supplied to a data subject, and for requests that are manifestly unfounded or excessive, particularly where such requests are repetitive.

9. Rectification of Personal Data

9.1. Data subjects have the right to require the Company to rectify any of their personal data that is inaccurate or incomplete.

9.2. We shall rectify the personal data in question, and inform the data subject of that rectification, within one month of the data subject informing the Company of the issue. The period can be extended by up to two months in the case of complex requests. If such additional time is required, the data subject shall be informed. Some rectifications might require additional documental confirmation.

9.3. In the event that any affected personal data has been disclosed to third parties, those parties shall be informed of any rectification that must be made to that personal data.

10. Data Holding & Erasure

10.1. Your data will be kept as long as you have an Ampere Account with us. After our business relationship with you ends, we will retain your personal data for 5 years after. We will retain your data to the extent necessary to provide our Services to you, comply with our legal obligations, resolve disputes, and enforce the purposes set out in this Policy.

10.2. Data subjects have the right to request the erasure of your personal data under certain circumstances. We will honour your request in accordance with applicable laws and regulations.
Specifically:

• 10.2.1. You may request the deletion of your data if it is no longer necessary for the purposes for which it was collected, if you withdraw consent (where applicable), or if the data has been unlawfully processed.
• 10.2.2. Submit a request for data erasure by contacting us. We will verify your identity to ensure the security of your data. We will assess your request to determine if it meets the criteria for erasure under data protection laws. If your request is approved, we will erase your data and notify you of the completion. If we are unable to erase your data due to legal or regulatory obligations, we will inform you of the reasons and the retention period. We may retain certain data if required for compliance with legal obligations, for the establishment, exercise, or defence of legal claims, or for reasons of public interest.

11. Who we share your information with ("Recipients")

11.1. We do not rent, sell, or share your personal data with third parties except with third parties whose services we use to provide Services to you or you use directly in obtaining Services from us whether described in this Privacy Policy or in our Cookie policy or not. The personal data will be disclosed to a third party only to the extent required for the specific purpose and in compliance with applicable law.

11.2. In addition to the purposes listed in this Policy, we may share personal data with our Recipients, who may be located in different jurisdictions across the world, for any of the following purposes:

• 11.2.1. providing you with our Services;
• 11.2.2. storing such information on your behalf;
• 11.2.3. processing such information to assist us with our business operations (e.g. to process payments and your deposits; authenticate your access; auditing our operations, provide customer support, customer retention services, etc.);
• 11.2.4. performing research, technical diagnostics or analytics.

11.3. Since we operate globally, it may be necessary to transfer your personal data to countries outside the UK. The data protection and other laws of these countries may not be as comprehensive as those applicable in the UK − in these instances we will take steps to ensure that a similar level of protection is given to your personal data. In accepting this Privacy Policy and our Cookie policy which forms part of your registration and Ampere Account information, you consent to transfer of your personal information to countries outside the UK, within the assurances made herein.

11.4. We may transfer or disclose personal data to our subsidiaries, affiliated companies and subcontractors for the purposes listed in this Privacy Policy.

11.5. We may also disclose your personal data, or any information you submitted in order to use our Services if we have a reasonable grounds to believe that disclosure of such information is helpful or reasonably necessary to: (i) comply with any applicable law, regulation, legal process or governmental request; (ii) enforce our policies (including our Terms and Conditions), including investigations of potential violations thereof; (iii) investigate, detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues; (iv) to establish or exercise our rights to defend against legal claims; (v) prevent harm to the rights, property or safety of us, our users, yourself or any third party; or (vi) for the purpose of collaborating with law enforcement agencies or (vii) in case we find it necessary in order to enforce intellectual property or other legal rights.

11.6. Some information may be shared with our trusted financial service provider – Railsbank Technology Limited, trading as ("Railsr") and its subsidiary PayrNet Limited (UK) for the purpose of providing you payment and/or card services. For information on Railsr's collection and use of data in accordance with the GDPR, please follow this link: https://www.railsr.com/payrnet

11.7. We may share Information, including personal data, in the event of a corporate transaction (e.g. sale of a substantial part of our business, merger, consolidation or asset sale of an asset or transfer in the operation thereof) of the Company or of any other company within the Group. In the event of the above, the acquiring company or transferee will assume the rights and obligations as described in this Privacy Policy.

11.8. The personal information we have collected from you will be shared with fraud prevention agencies who will use it to prevent fraud and money-laundering and to verify your identity. If fraud is detected, you could be refused certain services, finance, or employment. Further details of how your information will be used by us and these fraud prevention agencies, and your data protection rights, can be found in our privacy policy. Further details of how your information will be used by us and these fraud prevention agencies, and your data protection rights, can also be found by visiting.

11.9. Whenever fraud prevention agencies transfer your personal data outside of the UK and the European Economic Area, they impose contractual obligations on the recipients of that data to protect your personal data to the standard required in the UK and the European Economic Area. They may also require the recipient to subscribe to "international frameworks" intended to enable secure data sharing

11.10. In case you apply for business loans some information may be shared with our trusted financial service provider – Iwoca Ltd, trading as ("iwoca") for the purpose to provide you business loans. For information on iwoca's collection and use of data in accordance with the GDPR, please follow this link: https://www.iwoca.co.uk/compliance/customer-privacy-policy

11.11. In case you apply for business loans some information may be shared with our trusted financial service provider – YouLend Limited, trading as ("YouLend") for the purpose to provide you business loans. For information on Youlends's collection and use of data in accordance with the GDPR, please follow this link: https://youlend.com/privacypolicy

11.12. In case you apply for business loans some information may be shared with our trusted financial service provider – Tallaght Financial Ltd, trading as ("CubeFunder") for the purpose to provide you business loans. For information on Cubefunder’s collection and use of data in accordance with the GDPR, please follow this link: https://www.cubefunder.com/privacy-policy/

11.13. In case you engage with our services that involve lifestyle management and concierge support, certain information may be shared with our trusted service partner – PerfectLive Ltd, trading as ("PerfectLive") – to facilitate the provision of personalised concierge services, including but not limited to luxury travel arrangements, exclusive event access, fine dining reservations, and other bespoke lifestyle services. For details on PerfectLive’s collection and use of data in accordance with the GDPR, please refer to their Terms and Conditions: https://perfect.live/terms-and-conditions/

12. Third party access to your data

12.1. Our Policy only addresses the personal data we collect from you and does not address the personal data the third parties we use to provide our Services collect from you. If you disclose any information to other third parties via our Services (e.g. by clicking on a link to another online location), different rules may apply to their use or disclosure of the information disclosed to them that you can check on the websites of the third party service providers.

12.2. Please note that third party sites have their own privacy policy and data handling procedure and we are not the controllers of the data you have provided directly to third parties.

13. How we store and safeguard your personal data

13.1. Ampere employs all best practices and reasonable measures to maintain the security of your personal data and to prevent its unauthorised use. Your information is securely stored in trusted third-party servers in the European Union. We require any third party to comply with similar security requirements, in accordance with this Privacy Policy.

13.2. Although we do our best to safeguard your data, we cannot 100% guarantee that it will be free from abuse or unauthorised access. We will not be responsible for the acts of those who attempt to misuse the system.

14. Length of Retention of Data

14.1. Your data will be kept as long as you have an Ampere Account with us. After our business relationship with you ends, we will retain your personal data for 5 years after. We will retain your data the extent necessary to provide our Services to you, comply with our legal obligations, resolve disputes, and enforce the purposes set out in this Policy.

15. Your Data Protection rights

15.1. Your right of access - You have the right to ask us for copies of your personal information. Your right of access can be exercised in accordance with the relevant data protection legislation.

15.2. Your right to rectification - You have the right to ask us to correct personal information you think is inaccurate, incorrect or out of date. You also have the right to ask us to complete information you think is incomplete.

15.3. Your right to erasure - You have the right to ask us to delete your personal information in certain circumstances.

15.4. Your right to restriction of processing - You have the right to ask us to restrict the processing of your personal information in certain circumstances.

15.5. Your right to object to processing - You have the right to object to the processing of your personal information in certain circumstances.

15.6. Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation in certain circumstances, for instance to move Your personal data to another online platform.

15.7. There is no charge - You are not required to pay any charge for exercising your rights. If you make a request to us, we have one month to respond to you. Please contact us at the contact detailed in this Privacy Policy if you wish to make a request.

16. Changes to this Policy

16.1. We retain the right to modify, amend, change or update this Policy as needed and at our discretion. The most current version will be posted on our Platform. Any changes will be communicated to you via Ampere App or Ampere Website.

16.2. Your continued use of the Services, following the notification of such amendments will be regarded as your consent of such amendments to the Privacy Policy and your agreement to be bound by the new version.

17. Minors

17.1. Our Services should not be used by person under the age of 18. If you are under 18, you should not download, access or use the Services nor provide us with any personal data.

17.2. If we become aware that a user under the age of 18 has shared any information, we will discard this personal data. Please contact us here if you have any reason to believe that a minor has shared any information with us.

18. How to Complain

18.1. If you have any concerns about our use of your personal information, you can make a complaint to us using the contact details listed in this Policy. Any notice, demand, request or other communication which you address to Ampere shall either be sent by certified mail, return receipt requested, or by email. All communication done by email shall be deemed received on the business day following the day of transmission.

18.2. You can also complain to the Information Commissioner's Office (ICO) if you are unhappy with how we have addressed questions concerning processing of your personal data. Please note that you also have the right to lodge a complaint with the supervisory authority regarding the processing of personal information or dissatisfaction with our handling of any request in relation to any data protection rights. Please refer to the following for more information:

18.3. The ICO's address:
Information Commissioner's Office
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Helpline number: 0303 123 1113
Website: https://ico.org.uk/make-a-complaint/