Privacy Policy

Important information and who we are

Troy Guild Ltd is the controller and is responsible for your personal data (referred to as “Godmode” "we", "us" or "our" in this policy). We have appointed a data privacy manager. If you have any questions about this privacy policy, please contact them using the details set out below.

Contact Details

Our full details are:

• Full name of legal entity: Troy Guild Ltd

• Name or title of data privacy manager: Mehmet Mert Deveci

• Email address: team@troylabs.io

• Postal address: Unit 82a James Carter Road, Mildenhall, Bury St. Edmunds, England, IP28 7DE

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.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review.

This version was last updated on 18 January 2023. It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you when you next start the App or log onto the Website.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.

Third party links

Our Sites may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as Contact Data**.** Please check these policies before you submit any personal data to these websites or use these services.

The data we collect about you

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

• Identity Data.

• Contact Data.

• Transaction Data.

• Device Data.

• Content Data.

• Profile Data.

• Usage Data.

• Marketing and Communications Data.

We explain these categories of data here.

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.

How is your personal data collected?

We will collect and process the following data about you:

• Information you give us. This is information (including Identity, Contact, and Marketing and Communications Data) you consent to giving us about you by filling in forms on Our Sites, or by corresponding with us (for example, by email or chat). It includes information you provide when you register to use Our Sites, download or register an App, subscribe to any of our Services, search for an App or Service, make a purchase on Our Sites, share data via Our Sites’ social media functions, or enter a competition, promotion or survey, and when you report a problem with an App, our Services, or any of Our Sites. If you contact us, we will keep a record of that correspondence.

• Information we collect about you and your device. Each time you visit one of Our Sites we will automatically collect personal data including Device, Content and Usage Data. We collect this data using cookies and other similar technologies. Please see our cookie policy for further details.

• Information we receive from other sources including third parties and publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:

• Device Data from the following parties: analytics providers such as Plausible.io in the UK; and

• Identity and Contact Data from data brokers or aggregators such as Auth0 and Google Login.

Data Sharing with Third-Party Tools

Our app is committed to upholding the highest standards of data privacy and protection. As part of our operations, we may share certain user data with third-party tools, including but not limited to, Artificial Intelligence (AI) models, to enhance your experience and provide you with our full range of services.

• We use OpenAI, Anthropic and open source models from Amazon Web Services to enable artificial intelligence functionality.

• To provide the services of a customer relationship management, we may process your messages and contacts information with large language models

• You can opt out of this by emailing us at team@troylabs.io

Personal Information: This includes your name, email address, calendar events, your contacts' email addresses and other personally identifiable information you provide during the registration or usage of our app.

1. Usage Data: We collect data about how you interact with our app, such as the features you use, the time spent on the app, and your app preferences.

2. Device Information: This includes information about the device you use to access our app, such as the device model, operating system, and IP address.

Purpose of Data Sharing:

• Enhancing User Experience: We use AI models to personalize your experience, recommend features, and optimize our app's performance.

• Analytical Purposes: Third-party analytics tools help us understand app usage patterns to improve our service.

• Security Measures: Certain data is shared to enhance the security of our app and protect against fraudulent activities.

Cookies

We use cookies and/or other tracking technologies to distinguish you from other users of Our Sites and to remember your preferences. This helps us to provide you with a good experience when you use or browse any of Our Sites and also allows us to improve Our Sites. For detailed information on the cookies we use, the purposes for which we use them and how you can exercise your choices regarding our use of your cookies, see our cookie policy.

How we use your personal data

We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:

• Where you have consented before the processing.

• Where we need to perform a contract we are about to enter or have entered 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 or regulatory obligation.

Click here to find out more about the types of lawful basis that we will rely on to process your personal data.

We will only send you direct marketing communications by email or text if we have your consent. You have the right to withdraw that consent at any time by contacting us.

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

Purposes for which we will use your personal data

| Purpose/activity                                                                                     | Type of data                                         | Lawful basis for processing                                                                                                                   |
|------------------------------------------------------------------------------------------------------|------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------|
| To install the App and register you as a new user of Our Sites and implement the sign in process generally. | Identity<br>Contact<br>Device                         | Your consent<br>Performance of a Contract with you<br>Necessary for our legitimate interests (to facilitate the sign in process).             |
| To process purchases on Our Sites and deliver Services                                               | Identity<br>Contact<br>Transaction<br>Device<br>Marketing and Communications         | Performance of a contract with you<br>Necessary for our legitimate interests (to recover debts due to us)                                      |
| To manage our relationship with you including notifying you of changes to Our Sites or any Services  | Identity<br>Contact<br>Profile<br>Marketing and Communications                     | Performance of a contract with you<br>Necessary for our legitimate interests (to keep records updated and to analyse how customers use our products/ Services)<br>Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions) |
| To enable you to participate in a prize draw, competition or complete a survey                        | Identity<br>Contact<br>Device<br>Profile<br>Marketing and Communications           | Performance of a contract with you<br>Necessary for our legitimate interests (to analyse how customers use our products/Services and to develop them and grow our business)                             |
| To administer and protect our business and Our Sites including troubleshooting, data analysis and system testing | Identity<br>Contact<br>Device                          | Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security)              |
| To deliver content and advertisements to you<br>To track your behaviour across Our Sites and make recommendations to you about goods or services which may interest you<br>To measure and analyse the effectiveness of the advertising we serve you<br>To monitor trends so we can improve Our Sites | Identity<br>Contact<br>Device<br>Content<br>Profile<br>Usage<br>Marketing and Communications | Consent<br>

Disclosures of your personal data

When you consent to providing us with your personal data, we will also ask you for your consent to share your personal data with the third parties set out below for the purposes set out in the table Purposes for which we will use your personal data:

• External Third Parties as set out in the Glossary.

• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

International transfers

We do not usually transfer your personal data outside of the UK, however, if we were to do this we would ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We would only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.

• Where we use certain service providers, we may use specific contracts approved by the UK which give personal data the same protection it has in the UK.

Please contact us if you want further information whether we transfer your personal data out of the UK.

Data security

All information you provide to us is stored on our secure servers. Any payment transactions carried out by our chosen third-party provider of payment processing services will be encrypted. Where we have given you (or where you have chosen) a password that enables you to access certain parts of Our Sites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.

Data retention

By law we have to keep basic information about our customers (including Contact, Identity, and Transaction Data) for six years after they cease being customers.

In some circumstances you can ask us to delete your data: see Your Legal Rights below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you. In the event that you do not use your account via either the App or the Website for a period of 24 months then we will treat the account as expired and your personal data may be deleted.

Your legal rights

Under certain circumstances you have the following rights under data protection laws in relation to your personal data.

Please click on the links below to find out more about these rights:

• Request access to your personal data

• Request correction of your personal data

• Request erasure of your personal data

• Object to processing of your personal data

• Request restriction of processing your personal data

• Request transfer or your personal data

• Right to withdraw consent

You also have the right to ask us not to continue to process your personal data for marketing purposes.

You can exercise any of these rights at any time by contacting us at team@troylabs.io.

Glossary

Lawful basis

Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us. Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data 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). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us. Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract. Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Third Parties

External third parties

Service providers acting as processors who provide IT and system administration services. Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services. HM Revenue and Customs, regulators and other authorities acting as processors or joint controllers who require reporting of processing activities in certain circumstances.

Your legal rights

You have 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 we hold about you and to check that we are lawfully processing it.

• Request correction of the 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 law. 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 of 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; or

  • you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

• Request the 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. 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 at any time 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.

Description of categories of personal data

• Identity Data: first name, last name, username or similar identifier, social media account name or identifier, date of birth, gender.

• Contact Data: billing address, email address and telephone numbers.

• Transaction Data: includes details about payments to and from you and details of purchases via Our Sites.

• Content Data: includes information stored on your Device, including login information photos, videos or other digital content.

• Profile Data: includes your username and password, purchase history, your interests, preferences, feedback and survey responses.

• Usage Data: includes details of your use of or visits to any of Our Sites including, but not limited to, traffic data and other communication data whether this is required for our own billing purposes or otherwise and the resources that you access.

• Marketing and Communications Data: includes your preferences in receiving marketing from us and our third parties and your communication preferences.