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Privacy Notice

Last updated: September 2025

Welcome to https://easygen.tech/ (the “Website”). We value your trust and are committed to protecting your personal information. This Privacy Notice (“Notice”) explains how NOVOBRUK LIMITED collects, uses, shares, and safeguards your data. Please read it carefully. If you disagree with any part of this Notice, please do not use our Website or Services.

By accessing or using our Website and Services, you confirm that you have read and understood this Notice and consent to the practices described here.

As the data controller under the EU General Data Protection Regulation (“GDPR”) and the UK Data Protection Act 2018 (“UK GDPR”), NOVOBRUK LIMITED determines how and why your personal data is processed.

Our Contact Details Company: NOVOBRUK LIMITED Company Number: 16702343 Registered Address: 167 – 169 Great Portland Street, 5th Floor, London, England, W1W 5PF Email: support@easygen.tech

Information We Collect

Depending on how you interact with us, we may collect the following categories of personal data:

  • Account Data: login credentials, usernames, user settings, and activity logs.
  • Contact Details: email address, telephone number, country of residence, and postal address.
  • Identity Data: full name, government-issued identification, or verification documents.
  • Communications: emails, chats, and correspondence with our support team.
  • Transactions: orders, payment history, and billing details.
  • Payment Information: card or bank details (processed securely via third parties).
  • Technical Data: IP address, browser type, device information, and system settings.
  • Support Data: details about requests, issues, and resolutions.
  • Compliance Data: information collected for AML, KYC, or other legal checks.
  • Marketing Data: communication preferences and participation in promotions.
  • Visitor Data: where relevant, CCTV or visitor information from our premises.

Payment Data and PSD2 Compliance

When processing payments, we may collect limited payment-related data (e.g., payment method, transaction details). Full card or banking details are handled directly by regulated payment providers in compliance with PSD2.

In line with PSD2 and Strong Customer Authentication (SCA) requirements, you may be asked to provide additional authentication (e.g., OTP codes, biometrics) to complete certain transactions.

We may also share limited data with licensed Third-Party Providers (TPPs) who facilitate or verify payments, strictly for the purpose of completing transactions securely. These providers are bound by applicable financial regulations and contractual obligations to protect your data.

How We Use Your Information

We use personal data for the following purposes (with corresponding legal bases):

  • To create and manage your account (contractual necessity).
  • To deliver our services (contractual necessity).
  • To verify your identity (legal obligation, legitimate interest).
  • To communicate with you and provide support (contractual necessity, legitimate interest).
  • To process transactions and orders (contractual necessity).
  • To meet legal and regulatory obligations (legal obligation, public task).
  • To prevent fraud and misuse of our Services (legal obligation, legitimate interest).
  • For marketing and personalization (consent, legitimate interest).
  • For technical support and service improvements (contractual necessity, legitimate interest).
  • To resolve disputes or enforce agreements (contractual necessity, legal obligation).

How We Collect Data

  • Directly from you: when you register, subscribe, or contact us.
  • Automatically: through cookies, logs, and similar technologies (see our Cookie Notice).
  • From third parties: such as service providers, regulators, or publicly available sources.

Mandatory vs. Optional Data

Some information is essential for us to provide Services (e.g., payment details, verification). Optional information may improve your experience but is not required. Where data is mandatory, it will be clearly indicated.

Data Sharing

We do not sell your personal data. We may share it:

  • With trusted service providers (e.g., payment processors, hosting providers).
  • With regulators or authorities when legally required.
  • With partners or contractors where necessary to provide Services.

Data Protection

We implement robust security measures, including:

  • Encryption of data in transit and at rest.
  • Access controls and authentication protocols.
  • Regular staff training on privacy and security.
  • Periodic audits and risk assessments.
  • Data minimization practices.
  • Incident response procedures.

We also encourage you to:

  • Use strong and unique passwords.
  • Enable two-factor authentication (2FA).
  • Stay alert for phishing attempts.
  • Keep your software up to date.

International Transfers

If your data is transferred outside the UK, EU, or EEA, we ensure adequate safeguards, such as Standard Contractual Clauses (SCCs), so your data receives the same level of protection.

Your Rights

Under GDPR and UK GDPR, you may:

  • Access your personal data.
  • Correct inaccurate information.
  • Request deletion of your data under certain conditions.
  • Restrict processing of your data.
  • Object to specific uses of your data.
  • Request portability of your data in a machine-readable format.
  • Withdraw consent where processing relies on consent.

To exercise these rights, contact us at support@easygen.tech. We may need to verify your identity before responding. Some rights may be limited by law or regulation.

Data Retention

We retain personal data only as long as necessary for the purposes described, or as required by law. Examples:

  • AML-related data: typically kept for 5 years.
  • Other contractual or legal data: retained up to 10 years.
  • After retention periods expire, data is securely deleted or anonymized.

Age Restrictions

Our Services are intended for individuals aged 18 and older. We do not knowingly collect information from children under 18. If we become aware that such data has been collected, we will delete it.

Automated Decision-Making

We do not use automated decision-making, including profiling, that produces significant legal or similar effects on you.

Complaints

If you have concerns about how we handle your data, please contact us first. You may also lodge a complaint with your local data protection authority. In the UK, this is the Information Commissioner’s Office (ICO):

Information Commissioner’s Office Wycliffe House Water Lane Wilmslow Cheshire, SK9 5AF Helpline: 0303 123 1113 Website: www.ico.org.uk/make-a-complaint

Updates to This Notice

We may update this Privacy Notice from time to time. The updated version will be published on our Website with a new “last updated” date. Where material changes are made, we will notify you via the Website or direct communication.