Augur Privacy Notice

Who Are We?

AUGUR INITIATIVE LTD is the data controller responsible for your personal data (collectively referred to as "AUGUR" "we", "us" or "our" in this Privacy Notice).

You can contact us at the above address should you have any questions about this Privacy Notice, or if you would like to exercise any of your rights under Data Protection Laws, which we set out below.

What Types of Information Do We Collect From You?

We may collect, use, store and transfer different kinds of personal information about you such as:

• Identity and Contact Information about you including first name, last name, email addresses, login data.
• Financial and Transaction Information including your payment details, billing address, details about payments to and from you and other details of the Services you have purchased from us.
• Technical and Usage Information including 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, device ID and other technology on the devices you use to access our website, platform and information about how you interact with and use our website and Services.
• Marketing and Communications Information including your preferences in receiving marketing from us and our third parties and your communication preferences, tracking pixels to determine marketing effectiveness etc.

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

How and Why Do We Use Your Personal Information?

How your information is collected:

• When you interact with us: you may share your personal information with us when you provide information using any means on our website, such as when you book a demo, complete account creation and when you engage with us, or when you correspond with us by email, post, telephone or any other means, including through using our Services and our platform.
• Automated Technologies and Cookies: We do not use cookies or any other tracking technologies on this website. Our site is purely informational and does not collect, store or access any data from your device.

How your information is used:

Data Protection Laws require us to have a legal basis for everything that we do with your personal information falling under one of the following categories:

• Performance of a contract with you: Where we need to perform a contract we are about to enter into or have entered into with you.
• Legitimate interests: We may use your personal information where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and/or enable us to give you the best user experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal information for our legitimate interests. We do not use your personal information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
• Legal obligation: We may use your personal information where it is necessary for compliance with a legal obligation that we are subject to.
• Consent: We rely on consent only where we have obtained your active agreement to use your personal information for a specified purpose, in relation to receiving marketing emails from us.
• Vital Interests: We may process your personal information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

We use your personal information in a number of different ways and for different reasons. Due to the length of detailed tables, please refer to our full documentation or contact us for specific use cases.

How Can You Manage Your Marketing Preferences?

We intend for any marketing we send to be B2B, to corporate subscribers. Where doing so we rely on legitimate interests. You have the right to object to any such marketing – you may either let us know by contacting us directly, or by clicking the unsubscribe link featured in such marketing communications.

You can also contact us at [email protected]

What About Cookies?

Who Do We Share Your Personal Information With?

We may share your personal information with third parties who provide services to us, for example, our IT, communications, CRM, email and marketing automation and hosting providers. We require all third parties to respect the security of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.

The categories of data recipients we may disclose your personal information to are as follows:

Service Providers and Processors

We engage third party service providers, from time to time, including:

• IT & website hosting, task tracking and note taker, communications and analytics service providers;
• Professional advisors such as tax or legal advisors (for example, as necessary for the establishment, exercise or defence of legal claims or to protect the rights or safety of the website, platform or us;
• Consultants, insurance companies/claim managers and accountants; and
• Agents, suppliers or sub-contractors and other associated organisations where they are engaged by us to help deliver a service that we have instructed them on.

Third parties in case of a legal requirement

We also disclose your personal information if disclosure is required by law or in the context of an investigation, regulatory requirement, judicial proceeding, court order or legal process (including to law enforcement or competent authorities like the police/tax authorities, such as HMRC in the UK).

Third parties in case of a corporate transaction

In addition, information about our customers and users, including personal information, may be disclosed as part of any merger, sale, transfer of our assets, investment, acquisition, bankruptcy, or similar event, including while engaging with our actual or potential investors.

We may provide anonymous information to analytics and search engine providers to help us improve and optimise our services. We will only share this information in a form that does not directly identify you.

What Happens If We Share Your Information With Organisations Outside of the UK?

Whenever we transfer your personal information out of the UK or the EEA to service providers or any other third party, we ensure a similar degree of protection is afforded to it by ensuring that the necessary safeguards are in place, for example:

• We will only transfer your personal information to countries that have been deemed by regulators in the UK or the EU to provide an adequate level of protection for personal information; or
• We may use specific standard contractual terms as amended by the UK addendum approved for use in the UK and EU which give the transferred personal information the same protection as it has in the UK and EU.

Where possible we choose to host your personal data within the UK/EEA.

For more information about these safeguards, please contact us at [email protected]

How Do We Protect Your Personal Information?

We are committed to protecting individuals' personal information. We put in place appropriate technical and organisational measures to help protect the security of your personal information. However, be aware that no system is ever completely secure.

We have put various safeguards in place to guard against unauthorised access and unnecessary retention of personal information in our systems. These include pseudonymisation, encryption, access, and retention policies.

How Long Do We Keep Your Personal Information For?

We will only retain your personal information 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 information 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.

For further information about specific retention periods, please contact us at [email protected]

What Are Your Rights in Relation to the Personal Information We Hold?

You have a number of rights under data protection laws in relation to your personal information.

You have the right to:

• Request access to your personal information (commonly known as a "subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
• Request correction of the personal information 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 information in certain circumstances. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it.
• Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data. You also have the absolute right to object any time to the processing of your personal information for direct marketing purposes.
• Request the transfer of your personal information to you or to a third party in a structured, commonly used, machine-readable format.
• Withdraw consent at any time where we are relying on consent to process your personal information.
• Request restriction of processing of your personal information in certain scenarios.

You will not have to pay a fee to access your personal information (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.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information 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.

Time limit to respond

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.

Contact Us If You Have a Question or a Complaint

You have the right to make a complaint at any time to the relevant data protection regulator. In the UK this is the Information Commissioner's Office (ICO) (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach any regulator, so in the first instance please contact us at [email protected]

Updates to This Privacy Notice

We may update this Privacy Notice from time to time and we keep it under regular review. This version was last updated on 31 October 2025.