Last updated: 7 October 2025

Goldbug collects and uses certain Personal Data (as defined below) in relation to our websites and services. At Goldbug we respect everyone’s privacy and we are committed to keeping all Personal Data secure.

This Privacy Policy explains how and why we collect, store, use, share and protect your information as well as your rights in relation to your personal information and details of how to contact us and supervisory authorities if you have a complaint.

We use the following definitions in this Privacy Policy:

‘Goldbug’, we or ‘us’ means Goldbug Communications Ltd.

‘Personal Data’ means any data that relates to a living person who can be identified, directly or indirectly, from that information alone or when combined with other data.

This Privacy Policy applies to:

• Individuals who visit and use our website (the “Website”) and engage with us via our social media accounts.
• Individuals we deal with in their business capacity.
• Individuals who apply to work with us.

It is important that you read this Privacy Policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing Personal Data about you so that you are fully aware of how and why we are using your data.

AGE OF CONSENT

By using the Website, you represent that you are at least the age necessary to sign up to our services and enter into contracts with us.

INFORMATION THAT WE COLLECT ABOUT YOU
We may collect and use information about you, this includes:

Identity Data including your first name and surname.
Contact Data including contact details such as your email address and telephone numbers.
Business Data including the name of the organisation you represent, your position, department and business ID numbers.
Personal Verification Data including passport / ID, and proof of address where required.
Transactional Data including information about our business dealings, transactions and interactions with you.
Technical Data including your IP address and passwords when you visit or engage with our website or social media accounts.
Usage Data including information about how you use or search our website including any user preferences and notes.
Content Data including website content such as text, images and videos uploaded by you.
Customer Client Data including your client’s Identity Data, Contact Data, Business Data, Personal Verification Data, and Content Data, as described in this section.
Recruitment Data including data related to your employment history and salary expectations for the purpose of considering and progressing your application to work for us.

We will indicate where any Personal Data we have requested is mandatory. We will also explain the consequences should you decide not to provide information which we have indicated is mandatory. In some circumstances this may mean we are unable to provide you with a certain service.

HOW WE USE PERSONAL DATA

Lawful basis for processing
We will only process your Personal Data where we have a lawful basis to do so. The lawful basis will depend on the purposes for which we have collected and use your personal information. In almost every case, the lawful basis will be one of the following:

Our legitimate business interests: Where we have a legitimate interest to use Personal Data regarding you in relation to the operation of our business.
Performance of an agreement with you (or in order to take steps prior to entering into an agreement with you). For example, where you have provided your Personal
Data in relation to applying for employment with us.
Compliance with the law: Where we are subject to a legal obligation and need to use your Personal Data in order to comply with that obligation.
Consent: Where you have given consent for us to process your Personal Data for a specific purpose.

We collect most categories of Personal Data from you directly or when you use our website or engage with us via social media.

However, we may also collect your Personal Data from third parties, such as a recruitment agency when you are applying for a job with us, a reference provider or background check provided, or sometimes we collect information that is available in the public domain such as from social media platforms (including LinkedIn).

THE TYPE OF PERSONAL DATA THAT WE MIGHT COLLECT, AND THE LAWFUL BASIS FOR PROCESSING IT

IF I FAIL TO PROVIDE MY PERSONAL DATA
Where we need to collect Personal Data by law, or under the terms of an agreement we have with you, and you fail to provide that data when requested, we may not be able to perform the agreement we have or are trying to enter into with you (for example, to provide you with our services). In this case, we may have to cancel the performance of our services, but we will notify you if this is the case at the time.

HOW LONG DO WE KEEP PERSONAL DATA?
We retain your information for as long as it is necessary for the purposes for which it was collected and processed. Additionally, we retain Personal Data where we arerequired to do so under any legal, regulatory, accounting, finance, tax, reporting and insurance requirements after which time it will be destroyed or de-identified when the information is no longer required for any purpose for which it may be used or disclosed by us and we are no longer required to law or regulation to retain the information. Please note that this will be assessed on a case-by-case basis.
After our agreement with you expires or terminates, or our relationship with you has otherwise ended, we may also store your information in an aggregated and anonymised format.

DISCLOSURE OF YOUR INFORMATION
The Personal Data we process is processed by our team at Goldbug. We may also share your Personal Data with our suppliers, distributors, business partners and other providers, such as the supplier who hosts our website. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality. However, these third-party service providers may have their own privacy policies in respect of the information we are required to provide to them. For these providers, we recommend that you read their privacy policies so you can understand the manner in which your Personal Data will be handled by them. Once you leave our website, for example via a link, you are no longer governed by this Privacy Policy.

We may disclose your Personal Data to other third parties in the following cases:

• in the event that we sell any business or assets, in which case we may disclose your Personal Data to the prospective buyer of such business or assets;
• if we are under a duty to disclose or share your Personal Data in order to comply with any legal or regulatory obligation or request;in the case of an emergency, in which case we shall share Personal Data as is necessary and proportionate; or
• to protect the rights, property or safety of us or our users, or others, and in order to enforce or apply the terms of our contracts with clients (this includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction).
• 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 parties 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.

We have a Data Protection framework in place to oversee the effective and secure processing of your Personal Data.

COOKIES

• Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our website. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer. Cookies contain information that is transferred to your computer’s hard drive. We use the following cookies:

Necessary cookies. These cookies make our website usable by enabling basic functions like page navigation.

Statistics cookies. These cookies allow us to understand how visitors interact with our website by collecting and reporting information anonymously, helping us to improve how it functions.

You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

You can choose which Statistics cookies we can set by clicking on the buttons in our cookies banner at the bottom of the home page of our website. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this Website may become inaccessible or not function properly.

We do not share the information collected by the cookies with any third parties.

PERSONAL DATA STORAGE
We keep your information in data centres within the United Kingdom (“UK”), the European Economic Area (“EEA”) or United States of America (“USA”). For technical reasons, our application vendors may transfer your Personal Data to countries outside the UK or EEA. When this is the case, we will take steps which are reasonably necessary to ensure that appropriate safeguards are in place to protect your Personal Data and to make sure it is treated securely and in accordance with this Privacy Policy. In these cases, we rely on approved data transfer mechanisms; namely, the European Commission’s “standard contractual clauses” or the UK “International Data Transfer Agreement” or “UK Addendum” to ensure your Personal Data is subject to adequate safeguards in the recipient count.

YOUR RIGHTS
Goldbug takes your privacy very seriously and wants you to be aware of your rights as follows:

• Access: You can request: confirmation of whether we process your Personal Data; and a copy of the information that we hold about you.
• Correction: We want to make sure that your personal information is accurate and up to date. You may ask us to correct or complete information you think is inaccurate or incomplete.
• Erasure: In certain situations, you have the right to have your Personal Data erased.
• Object: In certain situations, you have the right to object to our processing of Personal Data regarding you.
• Restrict processing: In certain situations, you have the right to restrict our processing of Personal Data regarding you.
• Data portability: You can ask us to transfer your Personal Data from our IT environment to another, either to another company’s or your own, where technically feasible.
• Withdrawing consent: Where the processing of your Personal Data is based on your consent, you can withdraw your consent at any time without impact to any data processing activities that have taken place before such withdrawal.
• Automated processing: You have the right not to be subject to any decisions based solely on automated processing, including profiling, which has legal or other similarly significantly effects on you unless we have your consent, it is authorised by law, or it is necessary for the performance of an agreement.

Before we can respond to a request to exercise one or more of the rights listed above, you may be required to verify your identity. 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.

Contact details are at the end of this policy.

DATA SECURITY
We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We take steps to ensure that your information is treated securely and in accordance with this policy. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Data, for example, by encryption, we cannot guarantee the security of your information transmitted via the internet; any transmission is at your own risk.

We have appropriate technical and organisational measures to ensure a level of security appropriate to the risk of varying likelihood and severity for the rights and freedoms of you and other individuals. We maintain these technical and organisational measures and will amend them from time to time to improve the overall security of our systems.

In addition, we limit access to your Personal Data to those employees and other third parties who have a business need to know.

CHANGES TO THIS POLICY
We keep our Privacy Policy under regular review and we will place any updates on this webpage. You should look at this policy regularly to check for any changes. This Privacy Policy was last updated on 7th October 2025. Your continued engagement with us after the date of the updated policy constitutes your acceptance of the updated policy. If you do not agree to the updated policy, you must stop your engagement with us.

QUESTIONS AND CONCERNS
If you have any questions about this policy, how we use your information, or your data privacy rights, please contact us. You can do that using the following contact details:

Goldbug Agency
4-5 Langham Place
London W1B 3DG
E-mail: hello@goldbug.agency

In the event that you wish to make a complaint about how we process your Personal Data, please contact us in the first instance at hello@goldbug.agency and we will endeavour to deal with your request as soon as possible.

If you are not satisfied with our response to a request you make, or how we process your personal information, you can contact ICO, the UK’s data protection regulator or the data protection regulator in your place of residence. Upon request Goldbug can provide the contact details for that regulator.
For the purposes of UK and EU laws regarding data protection, the data controller is Goldbug, and we are registered with the UK Information Commissioner’s Office (ICO) under registration number ZA437930.

GOLDBUG’S REGISTRATION DETAILS
Registration number: 09066171
Registered address: 62 Stakes Road, Waterlooville, Hampshire PO7 5NT.