PRIVACY POLICY

Last updated: May 2024 www.virtualy.co.uk is provided by Corbenyah Ltd. In doing so, we may be in a position to receive and process personal information relating to you. As the controller of this information, we have prepared this Privacy Notice to explain our approach to your personal information. This Notice forms part of the Terms & Conditions which govern the use of this website. We intend only to process personal information fairly and transparently, as required by data protection law including the General Data Protection Regulation (GDPR). In particular, before obtaining information from you we intend to alert you to this Notice, let you know how we intend to process the information and (unless processing is necessary for at least one of the 5 reasons outlined in clause 2 below) we will only process the information if you consent to that processing. The GDPR also defines certain ‘special categories’ of personal information that are considered more sensitive. These categories require a higher level of protection, as explained below. Of course, you may browse parts of this website without providing any information about yourself and without accepting cookies. In that case, it is highly unlikely we will gather and process any information relating to you. We will start this Notice by setting out the conditions we must satisfy before processing your data. However, you may wish to skip to clause 4, which summarises what we intend to collect, and our use of cookies. The Notice also explains some of the security measures we take to protect your personal information, and tells you certain things we will or won’t do. You should read this Notice in conjunction with the Terms & Conditions. Sometimes, when you take a new service or product from us, or discuss taking a new service or product but decide against it, we might wish to provide you with further information about similar services or products by email or other written electronic communication. In that situation, we will always give you the opportunity to refuse to receive that further information and if you change your mind please let us know. We will endeavour to remind you of your right to opt-out on each occasion that we provide such information.

Company Name: Corbenyah Ltd Registered office: Jubilee House, East Beach, Lytham, Lancashire, FY8 5FT 1.2 Telephone at: +44 (0)1253 206144 Email at: investedinlife@corbenyah.com

We will only collect personal information relating to you if one of the following conditions have been satisfied: 2.1.You have clearly told us that you are happy for us to collect that information for a certain purpose or purposes that we will have specified. 2.2.The processing is necessary for the performance a contract that we have with you. 2.3.The processing is necessary so that we can comply with the law. 2.4.The processing is necessary to protect someone’slife. 2.5.The processing is necessary for performance of a task that is in the publicinterest. 2.6.The processing is necessary for our or another’s legitimate interest – but in this case, we willbalance those interests against yourinterests.

At the point of collecting the information, we will endeavour to explain how we intend to use the information and which of these purposes apply. If we rely on consent, we will provide you with the opportunity to tell us that you are happy to provide the information. If at any point in time you change your mind and decide that you do not consent, please let us know and we will endeavour to stop processing your information in the specified manner, or we will delete your data if there is no continuing reason for possessing it. If you don’t consent to a particular bit of processing, we will endeavour to ensure that the website and our service continue to operate without the need for that information.

No sensitive personal information is collected.

5.1.We envisage asking for the following types of information fromyou: Name / Email / Telephone number / from our online contact form. We ask for this to process your communication to Corbenyah Ltd. and duly reply to your correspondence. 5.2.We may collect personal information about you from a number of sources, including thefollowing: From you when you agree to take a service or product from us, in which case this may include your contact details, how you will pay for the product or service and your bank details. From you when you contact us with an enquiry or in response to a communication from us, in which case, this may tell us something about how you use our services. From documents that are available to the public, such as the electoral register. From third parties to whom you have provided information with your consent to pass it on to other organisations or persons – when we receive such information, we will let you know as soon as is reasonably practicable. If you refuse to provide the information requested, then if that information is necessary for a service we provide to you we may need to stop providing that service. At the time of collecting information, by whichever method is used, we will endeavour to alert you and inform you about our purposes and legal basis for processing that information, as well as whether we intend to share the information with anyone else or send it outside of the European Economic Area. If at any point you think you’ve been invited to provide information without explaining why, then feel free to object and ask for our reasons.

Data protection, privacy and security are important to us, and we shall only use your personal information for specified purposes and shall not keep such personal information longer than is necessary to fulfil these purposes. The following are examples of such purposes. We have also indicated below which GDPR justification applies. However, it will depend on the circumstances of each case. At the time of collecting we will provide further information, and you may always ask for further information from us. 6.1.1.To help us to identify you when you contact us. This will normally be necessary for the performance of ourcontract. 6.1.2.To help us to identify accounts, services and/or products which you could have from us or selected partners from time to time. We may do this by automatic means using a scoring system, whichuses the personal information you’ve provided and/or any information we hold about you as well as personal information from third party agencies (including credit reference agencies). We will only use your information for this purpose if you agree to it. 6.1.3.To help us to administer and to contact you about improved administration of any accounts, services and products we have provided before, do provide now or will or may provide in the future. This will often be necessary, but sometimes the improvements will not be necessary in which case we will ask whether youagree. 6.1.4.To allow us to carry out marketing analysis and customer profiling (including with transactional information), conduct research, including creating statistical and testing information.This will sometimes require that you consent, but will sometimes be exempt as marketresearch. 6.1.5.To help to prevent and detect fraud or loss. This will only be done in certain circumstances when we consider it necessary or the law requires it. 6.1.6.To allow us to contact you by written electronic means (such as email, text or multimedia messages) about products and services offered by uswhere: these products are similar to those you have already purchased from us, you are given the opportunity to opt-out of being contacted by us at the time your personal information was originally collected by us and at the time of our subsequent communications with you, and you have not opted out of us contacting you. 6.1.7.To allow us to contact you in any way (including mail, email, telephone, visit, text or multimedia messages) about products and services offered by us and selected partners where you have expressly consented to us doing so. 6.1.8.To keep you up to date with our member benefit scheme under which, as part of your membership benefits, we will give you membership information and details of discounts and offers we negotiate from time to time on behalf of our members. we will only do this if you have told us that you would likethis benefit. 6.1.9.We may monitor and record communications with you (including phone conversations and emails) for quality assurance andcompliance. Before doing that, we will always tell you of our intentions and of the specific purpose in making the recording. Sometimes such recordings will be necessary to comply with the law. Alternatively, sometimes the recording will be necessary for our legitimate interest, but in that case we will only record the call if our interest outweighs yours. This will depend on all the circumstances, in particular, the importance of the information and whether we can obtain the information another way that’s less intrusive. If we think the recording would be useful for us but that it’s not necessary, we will ask whether you consent to the recording, and will provide an option for you to tell us that you consent. In those situations, if you don’t consent, the call will either automatically end or will not be recorded. 6.1.10.When it’s required by law, we will check your details with fraud prevention agencies. If youprovide false or inaccurate information and we suspect fraud, we intend to recordthis. 6.2.We will not disclose your personal information to any third party except in accordance with this Notice, and in particular in these circumstances: 6.2.1.They will be processing the data on our behalf as a data processor (where we will be the data controller). In that situation, we will always have a contract with the data processor as set out in the GDPR. This contract provides significant restrictions as to how the data processor operates so thatyou can be confident your data is protected to the same degree as provided in thisNotice. Sometimes it might be necessary to share data with another data controller. Before doing that, we will always tell you. Note that if we receive information about you from a third party, then as soon as reasonably practicable afterwards we will let you know; that’s required by the GDPR. Alternatively, sometimes we might consider it to be in your interest to send your information to a third party. If that’s the case, we will always ask whether you agree before sending. 6.3.Where you give us personal information on behalf of someone else, you confirm that you have provided them with the information set out in this Notice and that they have not objected to such use of their personalinformation. In connection with any transaction which we enter into with you: 6.4.1.We may carry out one or more credit checks where you have given us your expressconsent. 6.4.2.We may carry out one or more fraud prevention checks with licensed fraud preventionagencies. 6.4.3.We and they may keep a record of the search. Information held about you by these agencies maybe linked to records relating to other people living at the same address with whom you are financiallylinked. These records may also be taken into account in credit and fraud prevention checks. Information from the application and payment details of your account will be recorded with one or more of these agencies and may be shared with other organisations to help make credit and insurance decisions about you and members of your household with whom you are financially linked and for debt collection and fraud prevention. This includes those who have moved house and who have missed payments. If you provide false or inaccurate information to us and we suspect fraud, we will record this and may share it with other people and organisations. We, and other credit and insurance organisations, may also use technology to detect and prevent fraud. If you need details of those credit agencies and fraud prevention agencies from which we obtain and with which we record information about you, please write to our Data Protection Department as detailed in clause 1.3. 6.4.6.We may need to transmit the payment and delivery information provided by you during the order process for the purpose of obtaining authorisation from your bank or from PayPal. 6.5.We may allow other people and organisations to use personal information we hold about you in the followingcircumstances: If we, or substantially all of our assets, are acquired or are in the process of being acquired by a third party, in which case personal information held by us about our customers, will be one of the transferred assets. If we have been legitimately asked to provide information for legal or regulatory purposes or as part of legal proceedings or prospective legal proceedings. 6.5.3.We may employ companies and individuals to perform functions on our behalf and we may disclose your personal information to these parties for the purposes set out above, for example, for fulfilling orders, delivering packages, sending postal mail and email, removing repetitive information from customer lists, analysing data, providing marketing assistance, providing search results and links (including paid listings and links), processing credit and debit card payments and providing customer service. Those parties will be bound by strict contractual provisions with us and will only have access to personal information needed to perform their functions, and they may not use it for any other purpose. Further, they must processthe personal information in accordance with this Notice and as permitted by the GDPR. From time to time, these other people and organisations to whom we may pass your personal information may be outside the European Economic Area. we will take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this Notice and the GDPR.

7.1.We have strict security measures to protect personalinformation. 7.2.We work to protect the security of your information during transmission by using Secure SocketsLayer (SSL) software to encrypt information youinput. 7.3.We maintain physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of personally identifiable customer information. Our security procedures mean that we may occasionally request proof of identity before we disclose personal information toyou.

If you communicate with us using the Internet, we may occasionally email you about our services and products. When you first give us personal information through the website, we will normally give you the opportunity to say whether you would prefer that we don’t contact you by email. You can also always send us an email (at investedinlife@corbenyah.com) at any time if you change your mind. Please remember that communications over the internet, such as emails and webmails (messages sent through a website), are not secure unless they have been encrypted. Your communications may go through a number of countries before they are delivered – this is the nature of the internet. We cannot accept responsibility for any unauthorised access or loss of personal information that is beyond our control. We exclude all liability for loss that you may incur when interacting with this third-party advertising or using these third-party websites unless you’ve consented in accordance with this privacy notice.

9.1.When we provide services, we want to make them easy, useful and reliable. This sometimes involves placingsmallamountsofinformationonyourcomputer,whichissentbacktousatalatertime.Theseare called ‘cookies’. These cookies are listed in our cookie policy. Some websites don’t use cookies but use related technology for gaining information about website users such as JavaScript, web beacons (also known as action tags or single-pixel gifs), and other technologies to measure the effectiveness of their ads and to personalise advertising content. Multiple cookies may be found in a single file depending on which browser youuse. 9.2.Where applicable, this section of the Notice also relates to that technology but the term ‘cookie’is used throughout. Some of these cookies are essential to the services you’ve requested from us, whereas others are used to improve services for you, for example through: Letting you navigate between pages efficiently. Enabling a service to recognise your computer so you do not have to give the same information during one task. Recognising that you have already given a username and password so you don’t need to enter it for every web page requested. Measuring how many people are using services, so they can be made easier to use and that there is enough capacity to ensure they are fast. 9.4.To learn more about cookies, you may wish to visit:https://ico.org.uk/for-organisations/guide-to-pecr/ guidance-on-the-use-of-cookies-and-similar-technologies/ 9.5.This website uses cookies as specified in our cookie policy. As with any other information we may collect from you, we will work to protect the security of your information during transmission by using Secure Sockets Layer (SSL) software to encrypt information you input. 9.7.The Website may include third-party advertising and links to third-party websites. We do not provide any personally identifiable customer personal information to these third-party advertisers or third-party websites except where you’ve consented in accordance with this Privacy Notice. However, as to cookies please see above clause Cookies and other internet trackingtechnology.

If you would like any more information or you have any comments about this Notice, then please write to us as detailed in clause 1.1. Please note that we may have to amend this Notice on occasion, for example if we change the cookies that we use. If we do that, we will publish the amended version on the website. In that situation we will endeavour to alert you to the change, but it’s also your responsibility to check regularly to determine whether this Notice has changed. 10.3.You can ask us for a copy of this Notice by emailing us at investedinlife@corbenyah.com. This Notice applies to personal information we hold about individuals. It does not apply to information we hold about companies and other organisations. If you would like access to the personal information that we hold about you, you can do this by emailing us at investedinlife@corbenyah.com . There is not normally a fee for such a request, however, if the request is unfounded, repetitive or excessive we may request a fee or refuse to comply with your request. You can also ask us to send the personal information we hold about you to another controller. 10.5.We aim to keep the personal information we hold about you accurate and up to date. If you tell us that we are holding any inaccurate or incomplete personal information about you, we will promptly amend, complete or delete it accordingly. Please email us at investedinlife@corbenyah.com to update your personal information. You have the right to complain to the Information Commissioner’s Office if we don’t do this. 10.6.You can ask us to delete the personal information that we hold about you if we relied on your consent in holding that information or if it’s no longer necessary. You can also restrict or object to ourprocessing of your personal information in certain circumstances. You can do this by emailing us at investedinlife@ corbenyah.com 10.7.We will tell you if there is a breach, or a likely breach, of your data protectionrights.

Last updated: May 2024 Thank you for accessing: www.virtualy.co.uk (the “Website”). Please read these terms and conditions before using the Website which is operated by Corbenyah Ltd., a public limited company registered in England and Wales (Registration Number: 04550605), whose registered office is at Jubilee House, East Beach, Lytham, Lancashire, England FY8 5FT (“we”, “us” or “our”). By using our Website, you are signifying your acceptance of these terms and conditions in consideration of which we allow you access to the Website. From time to time, we may alter these terms and conditions. Therefore, please continue to review them each time you are accessing or using the Website. If do not wish to accept the Terms at any time, you may refrain from using the Website.

The Website, inclusive of text, content, software, video, audio, graphics, photos, illustrations, images, artwork, names, logos and any other material is our “Content” and is protected by copyright, trademarks and other proprietary rights. This Content includes both content owned or controlled by Corbenyah Ltd. and/or content wholly owned and/or controlled by third parties and licensed to us for our sole use. All written content including articles, reports and all other elements that make up the Website are copyright works and protected. There is no right to acquire and no rights or licences other than that limited right to use the Website in accordance with these Terms for personal, non-commercial use.

The Company have endeavoured to ensure the accuracy of the information on the Website. However, we do not guarantee or provide any warranty as to the accuracy, timeliness or completeness of information or material on the Website. The Website and the Content are provided on an “as is” basis, without any warranties, unless specifically stated.

The Company have endeavoured to ensure the accuracy of the information on the Website. However, we do not guarantee or provide any warranty as to the accuracy, timeliness or completeness of information or material on the Website. The Website and the Content are provided on an “as is” basis, without any warranties, unless specifically stated.

Corbenyah Ltd. have no control over, or responsibility for, links to any third-party websites from this Website. Use of such links to third-party websites is at your sole risk.

We reserve the right to terminate or restrict your access to the Website at any time without notice or for any reason whatsoever. You acknowledge that access to the Website is provided free of charge and if for any reason, you are dissatisfied with the Website, these terms and conditions, or with any content of the Website, then your only remedy is to immediately discontinue the use of the Website. Except in respect of fraud and personal injury or death, to the extent it has resulted from our negligence, we accept no liability whatsoever to you, whether based on warranty, contract, negligence (including tort) or otherwise. In respect of these Terms and Conditions, you agree to indemnify, defend, and hold us harmless from and against any claims, actions, demands or other proceedings brought against us by a third party. To the extent that such claim, suit, action or any other proceeding brought against us is based on or arises in connection with your use of the Website, any breach by you of these terms and conditions, or a claim that your use of the Website infringes on any intellectual property rights of any third party or is libellous or defamatory, or otherwise results in injury or damage to any third party.

Those who access the Website do so on their own initiative and are responsible for compliance with applicable local laws or regulations; legal advice should be sought in cases of doubt. The Website is not directed at any person in any jurisdiction where for any reason the publication or availability of the Website is prohibited. Those in respect of whom such prohibitions apply must not access the Website. We do not represent that either the Website or the Content are appropriate for use or permitted by local laws in all jurisdictions. The Terms are governed by the laws of England and Wales and the parties submit to the exclusive jurisdiction of the English Courts.