Privacy Policy

1. Introduction

Wellbeing Places Equip Limited (“we”, “us”, or “our”) is committed to protecting your personal data and respecting your privacy.

This Privacy Policy explains how we collect, use, store, and protect personal data when you:

• visit our website;
• use any secure investor or partner portal;
• contact us or engage with us professionally; or
• otherwise interact with us.

This policy is provided in accordance with the UK General Data Protection Regulation (“UK GDPR”) and the Data Protection Act 2018.

2. Who We Are

Data Controller: Wellbeing Places Equip Limited

Company number: 16883203

Registered office: 5/6 Salmon Fields Business Village, Oldham, Lancashire, OL2 6HT, United Kingdom

Contact email: privacy@wellbeingplacesequip.com

3. Personal Data We Collect

Depending on how you interact with us, we may collect the following categories of personal data:

• Identity data: name, job title, organisation
• Contact data: email address, telephone number, postal address
• Professional data: role, business interests, company affiliation
• Technical data: IP address, browser type, device information
• Usage data: pages visited, interactions with our website or portal
• Communications: emails, messages, or correspondence sent to us

We do not intentionally collect special category personal data (such as health data) through our website or portal.

4. How We Use Your Personal Data

We use personal data for the following purposes:

• to operate, maintain, and improve our website and portal;
• to respond to enquiries and communications;
• to manage professional and investor relationships;
• to provide access to secure areas of the site where applicable;
• to comply with legal and regulatory obligations;
• to protect our legitimate business interests; and
• to manage access to secure areas, enforce confidentiality obligations and maintain audit logs relating to NDA-gated materials.

5. Lawful Bases for Processing

Under UK GDPR, we rely on one or more of the following lawful bases:

• Legitimate interests — where processing is necessary for our business operations and does not override your rights;
• Contractual necessity — where processing is required in connection with a contract or potential contract;
• Legal obligation — where processing is required to comply with law;
• Consent — where you have provided consent (for example, in relation to non-essential cookies).

6. Cookies and Similar Technologies

Our website uses cookies and similar technologies to operate effectively and, where applicable, to analyse usage.

Details of cookies used, their purpose, and how you can manage your preferences are set out in our Cookie Policy, available via the website footer.

7. Sharing Your Personal Data

We may share personal data with trusted third parties where necessary, including:

• IT and hosting service providers;
• website and portal service providers;
• professional advisers (such as legal or compliance advisers); and
• regulatory or public authorities where legally required.

We do not sell personal data.

Where third parties process data on our behalf, we take steps to ensure appropriate contractual and security safeguards are in place.

8. International Transfers

We aim to keep personal data within the UK.

Where personal data is transferred outside the UK, we ensure appropriate safeguards are applied in accordance with UK GDPR.

9. Data Security

We apply proportionate technical and organisational measures to protect personal data against unauthorised access, loss, or misuse.

While no system can be guaranteed to be completely secure, we take information security seriously and review protections periodically.

10. Data Retention

We retain personal data only for as long as necessary for the purposes for which it was collected, including to meet legal, regulatory, or contractual requirements.

Retention periods vary depending on the nature of the data and the context of the relationship.

11. Your Rights

Under UK data protection law, you have rights including:

• the right to access your personal data;
• the right to correct inaccurate or incomplete data;
• the right to request deletion of data in certain circumstances;
• the right to restrict or object to certain processing; and
• the right to data portability, where applicable.

Requests can be made using the contact details set out above.

12. Complaints

If you have concerns about how we handle personal data, we encourage you to contact us first.

You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO):

Website: https://www.ico.org.uk

Telephone: 0303 123 1113

13. Changes to This Policy

We may update this Privacy Policy from time to time.

The most recent version will always be available on our website, and the “Last updated” date will be revised accordingly.

14. Contact Us

If you have any questions about this Privacy Policy or how we handle personal data, please contact:

Email: privacy@wellbeingplacesequip.com

Post: Wellbeing Places Equip Limited, 5/6 Salmon Fields Business Village, Oldham, OL2 6HT