Data Protection – FGE NexantECA

Effective Date: April 10, 2026

1. Fair Processing Confirmation

Welcome to FGE NexantECA (“FGENX”) privacy notice.

FGENX is committed to protecting and respecting your privacy. This privacy notice sets out the basis on which any data we collect from or on behalf of you, or that you provide to us, will be processed by us. We will always ensure that the processing of your data is undertaken in line with the relevant legislation in place and this notice is designed to act as our confirmation to you of the lawful and fair processing of your data.

This privacy notice provides information on how FGENX collects and processes your personal data when you engage with us. It is designed to expand on just visitors to our website and will cover all those who engage with us to purchase or utilise our products or services.

It is important that you read this privacy notice together with our Website Privacy Policy (https://www.fgenexanteca.com/privacy-policy) which contains additional information about our data processing when using our website.

2. Controller and Contact Details

FGENX is the controller and responsible for your personal data. FGENX is part of the Foyle Bidco Limited Group which is made up of different legal entities. When we mention "FGENX", we are referring to FGE NexantECA. Where we mention Foyle Bidco or Foyle Bidco Group we will be referring to the relevant company in the Foyle Bidco Limited Group responsible for processing your data which will be clear to you when you use our services.

If you have any questions about this privacy notice or our data protection practices, our contact details are:

Full name of legal entity: Foyle Bidco Limited

Email address: dpo@fgenexanteca.com

Postal address: 110 Cannon Street, London, EC4N 6EU, United Kingdom

3. Data Protection Principles

We will comply with data protection law. This says that the personal information we hold about you must be:

Used lawfully, fairly and in a transparent way.
Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
Relevant to the purposes we have told you about and limited only to those purposes.
Accurate and kept up to date.
Kept only as long as necessary for the purposes we have told you about.
Kept securely.

4. The Data We Collect

Personal data, or personal information, means any information about an individual from which a natural person can be identified. Such data will include pseudonymised data where a person can be identified with reference to a unique code but will not extend to corporate identities (i.e. company information), anonymised data (i.e. where no individual can be identified at all) and data for deceased persons.

There are certain types of more sensitive personal data which require a higher level of protection, such as information about a person's health or sexual orientation. Information about criminal convictions also warrants this higher level of protection. We do not collect any 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 as part of your usage of our services. We do not knowingly collect the data of children.

The types of data that we do collect are best referred to when grouped into categories:

Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
Contact Data includes billing address, delivery address, email address and telephone numbers.
Financial Data includes bank account 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.
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 purchases or orders made by you, your interests, preferences, feedback and survey responses.
Usage Data includes information about how you use our products and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

The above does not contain details of any data which may be collected by use of our website as the confirmation regarding such data is contained on the Website Privacy Policy

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). Whilst we are not able to require you to give us the necessary information or compel you to provide us with certain data, we do reserve the right to cancel a product or service you have with us on this basis.

5. How is Dour Data Collected?

We will use different sources to collect your data in order to provide you with goods and services and to manage your relationship with us.

The most common source of data will be “direct interactions”. This is where 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, correspond with one of our employees or agents, request information be sent to you, contact us directly or return our requests for contact.

As you use our goods and services we will collate data in respect of your Usage Data, Profile Data and Transaction Data in order to profile the services that you use to better off you goods or services in the future.

We may also collect personal data about you from publicly available sources, this would include Identity Data, Contact Data and Marketing and Communications Data from web searches, websites, companies house, the electoral register and from trade or industry communications.

Under the Privacy and Electronic Communications (EC Directive) Regulations 2003 (PECR) we may make use of a generic email address which is publicly available (i.e. sales@company.com) this will be used to ensure that for the first email no natural person can be identified. Where you respond to a generic mailer which will likely provide your name and contact information which will be process in line with the ‘direct interactions’ statement above.

6. Use of Your Data

We will only use your personal data for the purpose for which we collected it which include the following:

To register you as a new customer.
To process and deliver your order.
To manage your relationship with us.
To invoice you and seek recovery of payments.
To improve our products/services, marketing or customer relationships.
To recommend products or services which may be of interest to you.

The above can be summarised into four fundamental purposes of processing:

Performance of a Contract: this would be where we need the personal data in order to perform the contract we have with you.
Legitimate Interests: this would be where we have a legitimate interest in processing your data for business or other commercial reasons. Where we have a legitimate interest we have set this out on the table below and we will ensure that your fundamental rights always override our legitimate interests (as appropriate).
Legal Obligation: this would be where we have a legal obligation to process your data, such as a report to a regulator or national authority.
Consent: this would be where we have your consent to process your data in a set way where the other grounds for processing do not apply.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new customer	(a) Identity (b) Contact	Performance of a contract with you
To process and deliver your order and administering any orders placed and to provide you or your authorising Licensee with the information, products and services that have been requested including to: (a) Manage payments, fees and charges (b) Collect and recover money owed to us	(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include: (a) Notifying you about changes to our terms and conditions or other relevant privacy information (b) Asking you to leave a review (c) sending direct or indirect correspondence containing guidance about usage of our products and services (d) corresponding with you further either at your request or where we believe this would be necessary (e) following up on usage and gathering feedback (f) notifying you about changes to our goods or services	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications	(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)
To use data analytics to improve our products/services, marketing, customer relationships and experiences including analysing the effectiveness of our marketing information.	(a) Technical (b) Usage (c) Marketing and Communications	Necessary for our legitimate interests (to define types of customers for our products and services, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications	Necessary for our legitimate interests (to develop our products/services and grow our business)
Fraud prevention, crime detection and security vetting	(a) Identity (b) Contact (c) Financial (d) Technical (e) Usage (f) Profile	Necessary for our legitimate interests (to protect our business and customers from crime or fraudulent activity)
Backing up or storage	(a) Identity (b) Contact (c) Financial	(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 on our business to ensure payment for goods or services)

7. Data Transfers

We may share your personal data within the Foyle Bidco Group for busines administration, reporting and commercial / professional support services. We will transfer your data to external services provides for IT and system administration, where we engage with professional advisers such as lawyers, accountants, consultants, insurers, financers and where we engage with regulations such as HMRC or other authorities. We may also transfer your data to those companies or contacts who are required to assist us in the provision of services or where we transfer ownership of FGENX to a third party. We may also transfer your data to a third party where we are involved in a dispute.

We do not normally transfer your personal data outside the UK. If we were to transfer your personal data out of the UK (for instance, on request by you or as part of our agreed package of services), we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

Where we use providers based in the US or other countries that have not been deemed to provide an adequate level of protection, we use UK Government-approved international transfer mechanisms (such as the UK International Data Transfer Agreement or the UK Addendum to the EU Standard Contractual Clauses) to ensure your personal data receives an equivalent level of protection.

8. Confirmations

Retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, regulatory, tax, accounting or other requirements.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.

Anonymisation

In some circumstances we will 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.

Security

We will use various proprietary and confidential technical and organisational measures to safeguard your data.

We store your personal data on secure servers and only disclose your personal data to third parties that also provide adequate protections. Whilst we will use all reasonable efforts to safeguard your data, you acknowledge that the use of the internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any data which are transferred to us on your behalf, from you or to you, or to a third party, via the internet.

Monitoring

We may monitor information about the state of devices connecting to the service, such as calibration status.

We may monitor and record communications with you (such as telephone conversations and emails) for the purpose of training, fraud prevention and compliance.

Information about Others

If you give us information on behalf of someone else, you confirm that the other person has appointed you to act on his/her behalf and has agreed that you can:

give consent on their behalf to the processing of their personal data
receive on their behalf any data protection notices
give approval to the transfer of their personal data

We may ask you to provide written confirmation of the above.

Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. If you wish to exercise any of the rights as set out you should contact us on the Contact Details set out earlier in this Privacy Notice.

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 could refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity (a certified copy of your passport or driving license for instance) 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 could 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.

You have the right to:

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:
- If you want us to establish the data's accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- 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.
- 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.

Amendments

We may amend this Privacy Notice from time to time. You should check the version of this notice provided on each occasion to ensure you are aware of the version which will apply when you access our goods and services.

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.