Contract analysis

1. Who We Are — Identity of the Controller The controller of your personal data is Northgate Telecommunications PLC ("NTP," "we," "us," or "our"), a public limited company incorporated in England and Wales under Company Number 04837291. Our registered office address is: Northgate Telecommunications PLC 140 Queensway Place Reading, Berkshire RG1 4QT United Kingdom Our principal office address, from which our day-to-da

2. How to Contact Our Data Protection Officer NTP has appointed a Data Protection Officer ("DPO") in accordance with Article 37 of the GDPR and the UK GDPR. The DPO is responsible for overseeing NTP's compliance with applicable data protection legislation, advising on data protection impact assessments, and serving as the primary point of contact for data subjects and supervisory authorities in relation to all matter

3. What Personal Data We Collect This section sets out the categories of personal data that NTP processes in connection with NorthCloud consumer subscriber accounts. The specific data processed in relation to your account will depend on the NorthCloud subscription tier you have chosen (including the freemium, standard, and premium tiers), the features and services you use, and your interactions with NTP and the North

4. How We Collect Your Personal Data NTP collects personal data from range sources, which we describe below. 4.1 Data Provided Directly by You We collect personal data that you provide to us directly through your interactions with NTP and the NorthCloud platform. This includes, but is not limited to, data provided: • When you register for a NorthCloud consumer subscriber account; • When you complete subscription form

5. Purposes and Legal Bases for Processing This section explains the specific purposes for which NTP processes your personal data and the lawful basis that we rely upon for each purpose, as required by Articles 13(1)(c) and 14(1)(c) of the GDPR and the UK GDPR. Where we rely on legitimate interests as the lawful basis, we have identified the specific legitimate interest pursued and have conducted a balancing assessme

6. Automated Decision-Making and Profiling NTP uses automated processing, including profiling, in certain contexts in connection with the NorthCloud platform. In accordance with Articles 13(2)(f), 14(2)(g), and 22 of the GDPR and the UK GDPR, we provide you with the following information regarding these activities. 6.1 Customer Churn Prediction NTP operates an AI-driven customer churn prediction model on the NorthClo

7. Who We Share Your Personal Data With NTP does not sell your personal data. We share your personal data only with the categories of recipients described below and only to the extent necessary for the purposes identified in this Privacy Notice. 7.1 NTP Group Companies NTP shares personal data with the following NTP Group companies in connection with the delivery, support, and operation of NorthCloud services: Data s

8. International Transfers of Your Personal Data NTP operates data centres in London, Frankfurt, Amsterdam, and Dublin, and processes the majority of NorthCloud consumer subscriber data within the United Kingdom and the European Economic Area ("EEA"). However, in connection with certain processing activities described in this Privacy Notice, your personal data may be transferred to, and processed in, countries outsid

9. How Long We Keep Your Personal Data NTP retains personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required or permitted by applicable law. We have established specific retention periods for each category of personal data, which are set out in NTP's internal Data Retention Schedule and summarised in the table below. Upon the expiry of the applicable retention perio

10. Your Data Protection Rights Under the GDPR and the UK GDPR, you have a number of rights in relation to your personal data. These rights are subject to certain conditions and exceptions as set out in the applicable legislation. NTP is committed to respecting and facilitating the exercise of your data protection rights in a transparent and timely manner. 10.1 Right of Access (Article 15) You have the right to reque

11. Right to Lodge a Complaint with a Supervisory Authority If you are dissatisfied with how NTP handles your personal data or the exercise of your data protection rights, you have the right to lodge a complaint with the relevant data protection supervisory authority. NTP encourages you to contact our DPO in the first instance so that we may seek to resolve your concern, but this does not affect your right to complai

12. Cookies and Similar Technologies NTP uses cookies and similar tracking technologies on the NorthCloud platform to provide essential functionality, to analyse how the platform is used, and—where you have given your consent—to deliver targeted advertising. Essential cookies are strictly necessary for the operation of the NorthCloud platform and are placed automatically when you access the platform. These cookies do

13. Changes to This Privacy Notice NTP may update this Privacy Notice from time to time to reflect changes in our processing activities, changes in applicable legal or regulatory requirements, changes in our business operations, or improvements to our data protection practices. The current version of this Privacy Notice will always be available on the NorthCloud platform. We encourage you to review this Privacy Notic

14. Contact Us If you have any questions, concerns, or requests regarding this Privacy Notice, the processing of your personal data by NTP, or the exercise of your data protection rights, please contact: Data Protection Officer: Sanjay Mehta Address: Northgate Tower, 88 Canary Wharf Boulevard, London E14 5HN, United Kingdom Email: dpo@northgatetelecoms.com General privacy inquiries can also be directed to Northgate T