1. Introduction

1.1 Important information and who we are

Welcome to Welleness Ltd's Privacy and Data Protection Policy ("Privacy Policy").

At Welleness Ltd ("we", "us", or "our") we are committed to protecting and respecting your privacy and Personal Data in compliance with the United Kingdom General Data Protection Regulation ("UK GDPR"), the Data Protection Act 2018 and all other mandatory laws and regulations of the United Kingdom.

This Privacy Policy explains how we collect, process and keep your data safe. It will tell you about your privacy rights, how the law protects you, and inform our employees and staff members of all their obligations and protocols when processing data.

The individuals from which we may gather and use data can include customers and any other people that the organisation has a relationship with or may need to contact.

This Privacy Policy applies to all our employees and staff members and all Personal Data processed at any time by us.

1.2 Your data controller

Welleness Ltd is your Data Controller and responsible for your Personal Data. We are not obliged by the UK GDPR to appoint a data protection officer and have not voluntarily appointed one at this time. Any enquiries about your data should be sent to us by email at hello@welleness.ai or by post to Dept 6208, 126 East Ferry Road, Canary Wharf, London, E14 9FP, United Kingdom.

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

1.3 Processing data on behalf of a controller and processors' responsibility to you

In discharging our responsibilities as a Data Controller we have employees who will deal with your data on our behalf (known as "Processors"). The Data Controller and our Processors have the following responsibilities:

• Ensure that all processing of Personal Data is governed by one of the legal bases laid out in the UK GDPR;
• Ensure that Processors authorised to process Personal Data have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality;
• Implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk associated with the processing of Personal Data;
• Obtain the prior specific or general authorisation of the Controller before engaging another Processor;
• Assist the Controller in the fulfilment of the Controller's obligation to respond to requests for exercising the data subject's rights;
• Make available to the Controller all information necessary to demonstrate compliance with the obligations laid down in the UK GDPR and allow for and contribute to audits;
• Maintain a record of all categories of processing activities carried out on behalf of a Controller;
• Cooperate, on request, with the supervisory authority in the performance of its tasks;
• Ensure that any person acting under the authority of the Processor who has access to Personal Data does not process Personal Data except on instructions from the Controller; and
• Notify the Controller without undue delay after becoming aware of a Personal Data Breach.

2. Legal basis for data collection

2.1 Types of data / privacy policy scope

"Personal Data" 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 below. Not all of the following types of data will necessarily be collected from you, but this is the full scope of data that we collect and when we collect it:

• Profile/Identity Data: Your first name, last name, gender, date of birth.
• Contact Data: Your phone number, addresses, and email addresses.
• Financial Data: Your financial health score, financial goals, income range, savings and investment information, and any other financial information you choose to share with us or that is generated through your use of our platform.
• Marketing and Communications Data: Your preferences in receiving marketing information and other communications from us.
• Usage Data: Information about how you use our website, products and services.

We do not collect 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. Whilst we collect financial information, this is not classified as a Special Category under UK GDPR. We treat financial data with the highest level of care and security given its sensitive nature.

2.2 The legal basis for collecting that data

There are a number of justifiable reasons under the UK GDPR that allow collection and processing of Personal Data. The main bases we rely on are:

• Consent: Certain situations allow us to collect your Personal Data, such as when you tick a box confirming you are happy to receive email communications from us, or opt in to a service.
• Contractual Obligations: We may require certain information from you in order to fulfil our contractual obligations and provide you with the promised service.
• Legal Compliance: We are required by law to collect and process certain types of data, such as in relation to fraudulent activity or other illegal actions.
• Legitimate Interest: We may need to collect certain information from you to meet our legitimate interests - this covers aspects that can be reasonably expected as part of running our business, that will not have a material impact on your rights, freedom or interests.

3. How we use your personal data

3.1 Our data uses

We will only use your Personal Data when the law allows us to. Set out below is a table containing the different types of Personal Data we collect and the lawful basis for processing that data.

Activity	Type of data	Legal justification	Lawful basis for processing
When a customer signs up	Profile/Identity Data, Contact Data, Marketing and Communications Data	Consent / Explicit Consent	Customer chooses to create an account with a username and password.
When a user generates a financial health score	Financial Data, Profile/Identity Data	Contractual Obligations / Legitimate Interest	To provide the core service, generate a personalised financial health score, and where applicable, facilitate connection with a regulated financial adviser.

3.2 Marketing and content updates

You will receive marketing and new content communications from us if you have created an account and chosen to opt in to receiving those communications. From time to time we may make suggestions and recommendations to you about goods or services that may be of interest to you.

3.3 Change of purpose

We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

4. Your rights and how you are protected by us

4.1 Your legal rights

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

• Right to be informed. You have a right to be informed about our purposes for processing your personal data, how long we store it for, and who it will be shared with.
• Right of access. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it (also known as a "data subject access request").
• Right to rectification. You have a right to request correction of the personal data that we hold about you.
• Right to erasure. You have the right to ask us to delete or remove personal data where there is no good reason for us continuing to process it.
• Right to object. You can object to the processing of personal data we hold about you in certain circumstances, including where we are processing your personal data for direct marketing purposes.
• Right to restrict processing. You have the right to request the restriction or suppression of your personal data in certain circumstances.
• Right to data portability. You have the right to request the transfer of your personal data to you or to a third party in a structured, commonly used, machine-readable format.

If you wish to make a request under any of these rights, please contact us at hello@welleness.ai.

4.2 Your control over Welleness Ltd's use of your personal data

You may delete your account at any time. This will remove your account page from our systems and our related software. We guarantee this will delete all stored data.

You can access information associated with your account by logging in to your account. Your account information will be protected by a password for your privacy and security. You need to prevent unauthorised access to your account and personal information by selecting and protecting your password appropriately and limiting access to your computer or device.

4.3 How Welleness Ltd protects customers' personal data

We are committed to keeping your data secure and protecting it from inappropriate disclosure. Any Personal Data collected by us is only accessible by a limited number of employees who have special access rights to such systems and are bound by obligations of confidentiality. If and when we use subcontractors to store your data, we will not relinquish control of your Personal Data or expose it to security risks that would not have arisen had the data remained in our possession.

Unfortunately, no transmission of data over the internet is guaranteed to be completely secure. While we strive to protect your Personal Data, we cannot ensure or warrant the security of any Personal Data you transmit to us. Any such transmission is done at your own risk. If you believe that your interaction with us is no longer secure, please contact us immediately.

4.4 Opting out of marketing communications

You can ask us to stop sending you marketing messages at any time by contacting us at hello@welleness.ai or by using the unsubscribe link at the foot of our marketing emails. Where you opt out of receiving marketing messages, we will continue to retain other Personal Data provided to us as a result of interactions with us not related to your marketing preferences.

4.5 How to request your data and the process for obtaining it

You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, if your request is clearly unfounded, we may refuse to comply.

We may need to request specific information from you to help us confirm your identity and ensure you have the right to access your Personal Data. This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it.

5. Your data and third parties

5.1 Sharing your data with third parties

We may share non-Personal Data with third parties. We may share your Personal Data with subcontractors or affiliates, subject to confidentiality obligations to use it only for the purposes for which we disclose it to them and pursuant to our instructions.

Where you choose to connect with a regulated financial adviser through our platform, we will share relevant Personal Data and Financial Data with that adviser solely for the purpose of providing you with financial guidance. Advisers are bound by their own professional confidentiality obligations and FCA regulatory requirements.

We may also share Personal Data with interested parties in the event that Welleness Ltd anticipates a change in control or the acquisition of all or part of our business or assets. If Welleness Ltd is sold or makes a sale or transfer, we may transfer, sell or assign your Personal Data to a third party as part of or in connection with that transaction. In all other situations your data will remain protected in accordance with this Privacy Policy.

We may share your Personal Data at any time if required for legal reasons or in order to enforce our terms or this Privacy Policy.

6. How long we retain your data

We will retain your Personal Data for as long as your account remains active. If you delete your account, we will delete your Personal Data within 30 days, except where we are required to retain it by law. Financial data generated through use of our platform will be retained for the same period. We may retain certain data for up to 6 years where required for legal or regulatory compliance purposes.

We may retain your Personal Data for a longer period than usual in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect of our relationship with you.

7. Age limit for our users

You must not use Welleness Ltd unless you are aged 18 or older. If you are under 18 and you access Welleness Ltd by misrepresenting your age, you must immediately stop using Welleness Ltd. This website is not intended for children and we do not knowingly collect data relating to children.

8. International transfer of data

Your Personal Data is primarily stored and processed in the UK. Where we use third-party service providers based outside the UK, we ensure that appropriate safeguards are in place in accordance with UK GDPR, including adequacy decisions or Standard Contractual Clauses. We will not transfer your Personal Data outside the UK without ensuring an appropriate level of protection is in place.

9. Cookies

We use cookies and similar tracking technologies on our website and platform. Cookies are small files placed on your device that help us understand how you use our service and improve your experience. We also use cookies to measure the performance of our marketing activity, including Meta advertising. You can control your cookie preferences through your browser settings or our cookie consent tool. A full cookie policy is available on our website.

10. Notification of changes and acceptance of policy

We keep our Privacy Policy under review and will place any updates on this page. This version is dated 11 November 2025.

By using Welleness Ltd, you consent to the collection and use of data by us as set out in this Privacy Policy. Continued access or use of Welleness Ltd will constitute your express acceptance of any modifications to this Privacy Policy.

11. Interpretation

All uses of the word "including" mean "including but not limited to" and the enumerated examples are not intended to limit the term which they serve to illustrate. Any email addresses set out in this policy may be used solely for the purpose for which they are stated to be provided, and any unrelated correspondence will be ignored.

Our staff are not authorised to contract on behalf of Welleness Ltd, waive rights or make representations (whether contractual or otherwise). If anything contained in an email from a Welleness Ltd address contradicts anything in this policy, our terms or any official public announcement on our website, the policy content will take precedence. The only exception to this is genuine correspondence expressed to be from the Welleness Ltd legal department.