PRIVACY NOTICE

Last updated: 12 August 2026

Welcome to http://workixo.com/ (the “Website”). We respect your privacy and are committed to protecting your personal data. This Privacy Notice will inform you as to how we look after your personal data when you visit our Website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice 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. This privacy notice supplements the other notices and is not intended to override them.

We keep our Privacy Notice under regular review. 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 your relationship with us.

1. WHO WE ARE

CONTROLLER

[COMPANY NAME] is the controller and responsible for your personal data (collectively referred to as the "Company", "we", "us" or "our" in this privacy notice). We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

CONTACT DETAILS

Our full details are:

Full name of legal entity: [COMPANY NAME]

Company No. [COMPANY NUMBER]

Email address: info@workixo.com

Postal address: [REGISTERED ADDRESS]

HOW TO COMPLAIN

You have the right to make a complaint at any time to the The National Supervisory Authority for Personal Data Processing (ANSPDCP):

B-dul G-ral. Gheorghe Magheru 28-30, Sector 1, post code 010336, Bucharest, Romania Tel: +40.318.059.211 / +40.318.059.212

Fax: +40.318.059.602

Email: anspdcp@dataprotection.ro

Website: www.dataprotection.ro

We would, however, appreciate the chance to deal with your concerns before you approach the ANSPDCP so please contact us in the first instance.

2. THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, gender, government-issued identification, and ID document details used for KYC (Know Your Customer) checks.
• Contact Data includes billing address, delivery address, email address, and telephone numbers.
• Financial Data includes bank account details, preferred payment methods, and payment card details.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us, including account balances and order history.
• Technical Data includes 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, and other technology on the devices you use to access this Website.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback, customer support interactions, and survey responses.
• Usage Data includes information about how you use our Website, products, and services, including user activity logs and communication records.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
• Compliance Data includes data relating to Anti-Money Laundering (AML) and Countering the Financing of Terrorism (CFT) activities, and other legal compliance procedures.

We may also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity.

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

3. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity, Contact, and Financial Data by filling in forms or by corresponding with us by post, phone, email, or otherwise. This includes personal data you provide when you apply for our products or services; create an account on our Website; subscribe to our service or publications; request marketing to be sent to you; enter a competition, promotion, or survey; or give us some feedback.
• Automated technologies or interactions. As you interact with our Website, we may automatically collect Technical Data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies, server logs, and other similar technologies. Please see our Cookie Policy for further details.
• Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below: service providers (e.g., payment processors), state authorities, or publicly available sources.

4. HOW WE USE YOUR PERSONAL DATA

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

• Where we need to perform the contract we are about to enter into or have entered into 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.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

5. PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.

1. To register you as a new customer/user. Lawful basis: Performance of a contract with you.

2. To process and deliver your order/services, manage payments, fees, and charges, and collect and recover money owed to us. Lawful basis (a) Performance of a contract with you, (b) Necessary for our legitimate interests (to recover debts due to us).

3. To verify and authenticate user identities and prevent fraud. Lawful basis: (a) Necessary to comply with a legal obligation (AML/KYC), (b) Necessary for our legitimate interests (to protect our business from fraudulent activities).

4. To manage our relationship with you which will include notifying you about changes to our terms or privacy policy, and asking you to leave a review or take a survey. Lawful basis: (a) Performance of a contract with you, (b) Necessary to comply with a legal obligation, (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services).

5. To administer and protect our business and this Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting, and hosting of data). Lawful basis: (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security), (b) Necessary to comply with a legal obligation.

6. To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you. Lawful basis: Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy).

7. To use data analytics to improve our Website, products/services, marketing, customer relationships, and experiences. Lawful basis: Necessary for our legitimate interests (to define types of customers for our products and services, to keep our Website updated and relevant, to develop our business and to inform our marketing strategy).

6. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below for the purposes set out in the section above.

• Internal Third Parties: Other companies in the Company's group acting as joint controllers or processors.
• External Third Parties: Service providers acting as processors based within or outside the EU who provide IT and system administration services; professional advisers acting as processors or joint controllers including lawyers, bankers, auditors based in the EU who provide consultancy, banking, legal, insurance, and accounting services; regulators, and other authorities acting as processors or joint controllers based in the EU who require reporting of processing activities in certain circumstances.
• Business Transfers: 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 notice.

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-party service providers 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.

7. INTERNATIONAL TRANSFERS

Your personal data may be transferred to and processed in countries outside the European Economic Area (EEA) and the European Union (EU). These transfers are essential for providing our services and may involve your data being handled in jurisdictions that do not offer the same level of data protection as within the EEA and EU. To ensure your personal data is adequately protected during these transfers, we implement stringent safeguards, such as the European Commission's Standard Contractual Clauses, binding corporate rules, or other legally recognized mechanisms. In cases where the European Commission has issued an adequacy decision, recognizing that a non-EU/EEA country provides an adequate level of data protection, transfers to that country will be conducted under such a decision. These measures are designed to ensure that your data receives a level of protection equivalent to that provided within the EEA and EU, regardless of where it is processed.

8. 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. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

9. DATA RETENTION

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes. Data related to Anti-Money Laundering (AML) checks will be kept for five years from the end of the business relationship as legally required.

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

10. AUTOMATED DECISION-MAKING

You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you. We do not envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes.

11. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data:

• 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: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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 (d) 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.

If you wish to exercise any of the rights set out above, please contact us at info@workixo.com.

You will not have to pay a fee to access your personal data (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 may refuse to comply with your request in these circumstances.

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

We try to respond to all legitimate requests within one month. Occasionally it may 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.

12. AGE RESTRICTIONS

This Website and our Services are not intended for children and we do not knowingly collect data relating to children. Users must be aged 18 or older to use our Services. If we become aware that we have collected personal data from a child under the age of 18 without verification of parental consent, we will take steps to remove that information from our servers immediately.