HY10 Global Limited is a company authorised and regulated by the Financial Conduct Authority (FRN: 1004355) under the Electronic Money Regulations 2011 for the issuance of electronic money and provision of payment services (HY10 Payments).

Orbital Mobile Limited is a separate entity within the broader HY10 group. This company offers lifestyle and concierge services and is independently responsible for its personal data processing. It is not regulated by the Financial Conduct Authority (HY10 Lifestyle).

HY10 Payments and HY10 Lifestyle operate as separate data controllers when handling your personal data, as detailed in this privacy notice. This privacy notice applies to HY10 Payments and HY10 Lifestyle (collectively, we, us, or ours). However, specific sections may exclusively apply to either HY10 Payments or HY10 Lifestyle, as indicated in this notice.

HY10 Payments may provide its Services, including payment services, and card and electronic money issuance in collaboration with our partners (Partners) under various brands and where indicated to you. These Partners may market, distribute and support payment service programs and you should also refer to their respective privacy notices.

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.

We collect personal data about you in a number of ways including:

• when you order Services from us or otherwise use our Services;
• when you visit our websites;
• when you submit a query or request to us;
• when you provide feedback or participate in surveys or promotions';
• by tracking your use of our websites and mobile applications;
• from public sources; or
• from third parties who are entitled to disclose that information to us.

In some cases, we may also be required by law to collect certain types of personal data about you. Where we collect personal data from you, we will generally do so ourselves. However, we also collect personal data from third parties, such as through your representatives, our Partners, contractors who provide services to us, or third parties who refer you to us because they think you may be interested in our Services.

HY10 Payments:

When you use HY10 Payments' payment services (including your card and payment account), we shall collect the following personal data from you:

• identifying information, such as your name and date of birth;
• identity verification information, such as images of your government issued ID, passport, national ID card, utility bill or driving licence contact information, such as your postal address, email address and telephone numbers;
• transactional and financial information where you use a card issued by us to make transactions;
• financial information, such as a credit or debit card, bank account or other payment details and/or other personal wealth information;
• online identifiers that may also constitute personal data, such as your MAC address, computer and mobile device unique device ID and IP information based on your internet connection settings;
• usernames and passwords that you create when registering for an account with us;
• details of any Services that we provide to you and how you use them;
• records of our communications with you, including any messages you send us;
• visual images and personal appearances; and
• lifestyle information such as family.

HY10 Lifestyle:

When you use HY10 Lifestyle's lifestyle concierge services, we shall collect the following personal data from you:

• identifying information, such as your name and date of birth;
• identity verification information, such as images of your government issued ID, passport, national ID card, utility bill or driving licence contact information, such as your postal address, email address and telephone numbers;
• financial information, such as debit card, bank account or other payment details and/or other personal wealth information;
• usernames and passwords that you create when registering with us;
• details of any Services (including travel and booking data) that we provide to you and how you use them; and
• records of our communications with you, including any messages you send us.

Without this information, we may not be able to provide you with our Services (or with all of the features and functionality offered by our Services), to respond to queries or requests that you submit to us and to protect against the risks of cybercrime, fraud and money laundering & terrorist financing.

We will only use your personal data in accordance with applicable law and mostly, in the following circumstances:

• where you consent to it e.g. you have ticked a box to indicate that you are happy for us to use your personal data in a certain way;
• where we enter into a contract with you and need certain personal data to provide our Services to you;
• where it is necessary for our legitimate interests (or those of a third party) and this is reasonable when balanced against your right to privacy;
• where needed to comply with a legal obligation; or
• for HY10 Payments only, where needed to comply with a 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.

HY10 Payments:

• to verify your identity (including age) when you are dealing with us;
• to determine your eligibility for, and enable us to provide, any of our Services, and information that you have requested;
• to determine your compliance with the terms and conditions that apply to any of our Services and applicable law;
• to improve our website based on your information and feedback;
• to manage and resolve any complaints and legal issues;
• to comply with our legal and regulatory obligations;
• to carry out market analysis and research;
• to monitor use of and improve our Services, including creating anonymous data from your personal data for analytical use, including for the purposes of training, testing and system development;
• to carry out education and training programs for our staff;
• to carry out planning and forecasting activities and other internal business processes;
• to keep you informed about our activities, including by sending out newsletters; or
• any other of our legitimate business interests.

HY10 Lifestyle:

• to deliver requested lifestyle concierge Services and personalise your experience;
• to enable us to provide, any of our Services, and information that you have requested;
• to determine your compliance with the terms and conditions that apply to any of our Services and applicable law;
• to monitor use of and improve our Services;
• to comply with our legal obligations to you; or
• any other of our legitimate business interests.

We may process your personal data without human intervention to evaluate your personal situation such as transactional history and account opening anniversary events. We may do this to decide what marketing communications are suitable for you, to analyse statistics and to assess risks.

We may also automatically decide that you pose a fraud or money laundering risk if our processing reveals your behaviour to be consistent with money laundering or known fraudulent conduct, or is inconsistent with your previous submissions, or you appear to have deliberately hidden your true identity.

This is all done on the basis of our legitimate interests, to protect our business, and to develop and improve our products and services. If we use automated decision making including profiling activity to assess your application, this will be performed on the basis of it being necessary to perform the contract.

We may from time to time use your personal data in order to send you marketing materials about our Services that we think you may be interested in but we shall always give you the opportunity to easily opt out of any such communications. You can opt out of receiving marketing communications from us following the instructions on the relevant communication.

We will get your express opt-in consent before we share your personal data with any company outside our group of companies for marketing purposes.

HY10 Payments may share certain personal data (such as your name, address, identification verification information and) payment details with HY10 Lifestyle when necessary to provide the Services to you.

We may also disclose your personal data to:

• your representatives, advisers and others you have authorised to interact with us on your behalf;
• our staff who need the information to discharge their duties;
• related entities within our corporate group;
• our business partners, agents and service providers;
• payment system operators and financial institutions;
• identity verification agents;
• fraud and crime prevention agencies and organisations;
• credit reference agencies;
• prospective purchasers of all or part of our business or a related entity;
• professional advisers who we engage to provide advice on our business;
• regulators; and/or
• government authorities and bodies, supra-national authorities and bodies, crime investigation agencies, courts and others who ask us to disclose that information as required by law.

We may also disclose your personal information where it is necessary to do so (some examples are listed below):

• for compliance with a legal obligation;
• in order to protect the vital interests of you or another natural person; and/or
• for the establishment, exercise or defence of legal claims.

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.

Whenever we transfer your personal data out of the United Kingdom (UK) or European Economic Area (EEA), we will ensure that it is sufficiently safeguarded in accordance with applicable laws: please contact us if you want further information on the specific safeguarding mechanism used by us.

We may send your personal data outside of the UK/EEA to:

• provide you with the products/services you have requested; or
• comply with global legal/regulatory requirements, law enforcement authorities, fraud prevention agencies and credit reference agencies.

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 would like an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

We may also process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

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.

Your personal data will only be kept as long as required to meet our legal obligations and no longer than is necessary. In most cases we will retain your personal data for a period of between 1 to 6 years after our relationship ends. In some cases we may be obliged to retain some of your personal data for longer periods as is required by applicable law.

You have rights under data protection laws in relation to your personal data, which are set out below:

Your right of access: you have the right to ask us for copies of your personal data.

Your right to rectification: you have the right to ask us to rectify personal data you think is inaccurate or to complete personal information you think is incomplete.

Your right to erasure: you have the right to ask us to erase your 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.

Please note that if you request the erasure of your personal information:

• We may retain some of your personal information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety.
• We may retain and use your personal information to the extent necessary to comply with our legal obligations.

Your right to restriction of processing: you have the right to ask us to restrict the processing of your personal data in the following circumstances:

1. if you want us to establish the data's accuracy;
2. where our use of the data is unlawful but you do not want us to erase it;
3. 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
4. you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. Please note that any requests in relation to the restriction of the processing of your data means that we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel your use of our services but we will notify you if this is the case at the time.

Your right to data portability: on your request, we can provide your personal data in a structured, commonly used, machine-readable format, which you can then transfer to an applicable third party. 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.

Withdrawal of 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 Services to you. We will advise you if this is the case at the time you withdraw your consent.

Please contact HY10 Payments and/or HY10 Lifestyle, as applicable (please see paragraph 20: contact and complaints) if you wish to exercise any of these rights.

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 unfounded, repetitive or excessive, we may charge a reasonable fee, or alternatively and as a last resort, may refuse to comply with your request.

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.

Some pages made available through the Services include links to third-party websites: clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control such websites and are not responsible for their privacy statements. We encourage you to read the privacy policy of every website you visit.

Any changes we make to our privacy notice in the future will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to our privacy notice.

If you have any questions about our notice, privacy practices, or the personal data that we hold about you, please contact our respective Data Protection Officers at:

HY10 Payments:

• Email: infohy10.uk
• Mail: 16-17 Little Portland Street, London, England, W1W 8BP

HY10 Lifestyle:

• Email: infoorbital.me
• Mail: 71-75 Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ

If you are unsatisfied by our response, you can contact the Information Commissioner's Office.