(1) FE Tech
and
(2) Customer
advertising agreement
CONTENTS
1 Definitions and interpretation 1
2 Commencement date and duration 3
3 Services 3
4 Customer’s obligations 4
5 Supply obligations 5
6 Time for performance 5
7 Fees and expenses 5
8 Data protection 5
9 Limitation of liability 5
10 Costs 6
11 Confidential Information 6
12 Termination 7
13 Dispute resolution 7
14 Entire agreement 8
15 Notices 8
16 Force majeure 8
17 Further assurance 9
18 Variation 9
19 Assignment 9
20 No partnership or agency 9
21 Equitable relief 9
22 Severance 9
23 Waiver 9
24 Counterparts 10
25 Third party rights 10
26 Governing law and jurisdiction 10
Schedule 1 – Advertising Particulars 11
Schedule 2 – Payment Schedule 12
Schedule 3 – Data protection 13
THIS AGREEMENT
Parties
FE Tech a company incorporated in England and Wales under number 13801551 whose registered office is at Greygables, old park road, leeds, LS8 1JX (“Supplier”); and
The orgainisation named within the online quotation agreement (“Customer”)
each of the Supplier and the Customer being a party and together the Supplier and the Customer are the parties.
Background
The Supplier provides learning solutions through a variety of online platforms that it operates through developing and delivering effective and skills training and published educational content.
The Customer wishes to advertise its own [goods/services] through the platforms operated by the Supplier in accordance with the terms of this Agreement.
AGREED TERMS:
Definitions and interpretation
In this Agreement:
“Advertising” means the Customer advertising to be displayed on the Website or otherwise arising in connection with this Agreement the details of which are set out in the quotation particulars;
“Advertising Regulations” means any present or future applicable code of practice or adjudication of the Committee of Advertising Practice (including the Broadcast and Non-Broadcast Codes where applicable), Broadcast Committee of Advertising Practice or the Advertising Standards Authority and includes any applicable modification, extension or replacement thereof in force from time to time, together with other UK laws, statutes and regulations which are directly applicable to the Services;
“Associate” means in relation to a party, any other entity which directly or indirectly Controls, is Controlled by, or is under direct or indirect common Control with that party from time to time;
“Business Day” means a day other than a Saturday, Sunday or bank or public holiday in England;
“Commencement Date” means the date of this Agreement;
“Confidential Information” means all information (whether in oral, written or electronic form) relating to a party’s business which may reasonably be considered to be confidential in nature including information relating to that party’s finances, technology, know-how, intellectual property, assets, strategy, products and customers;
“Control” means that a person owns directly or indirectly more than 50% of the shares or securities of the other person representing the right to vote on all or substantially all matters including the election of directors and Controls and Controlled shall be interpreted accordingly;
“Fees” means the fees and other amounts payable under clause 7 and the quotation particulars;
“Force Majeure” means an event or sequence of events beyond a party’s reasonable control (which could not reasonably have been anticipated and avoided by a party) preventing or delaying it from performing its obligations hereunder, including without limitation—war, revolution, terrorism, riot or civil commotion, or reasonable precautions against any such; strikes, lock outs or other industrial action, whether of the affected party’s own employees or others; blockage or embargo; acts of or restrictions imposed by government or public authority; explosion, fire, corrosion, flood, natural disaster, or adverse weather conditions. Force Majeure does not include, without limitation, inability to pay, mechanical difficulties, shortage or increase of price of raw materials, over-commitment or market or other circumstances which may make the terms of this Agreement unattractive to a party;
“Intellectual Property Rights”
means copyright, rights in inventions, patents, know-how, trade secrets, trade marks and trade names, service marks, design rights, rights in get-up, database rights and rights in data, semiconductor chip topography rights, the right to sue for passing off, domain names and all similar rights and, in each case:
(a) whether registered or not;
(b) including any applications to protect or register such rights;
(c) including all renewals and extensions of such rights or applications;
(d) whether vested, contingent or future; and
(e) wherever existing;
“Payment Schedule” means quotation particulars of this Agreement;
“Services” means the services described in this Agreement to be provided by the Supplier for the Customer in the performance of this Agreement;
“Supplier Personnel” means the people providing the Services or otherwise performing the Supplier’s obligations or exercising its rights under this Agreement;
“VAT” means United Kingdom Value Added Tax;
“Website” means www.fetech.co.uk
In this Agreement:
a reference to this Agreement includes its schedules;
the table of contents, background section and the clause, paragraph, schedule or other headings in this Agreement are included for convenience only and shall have no effect on interpretation;
a reference to a ‘party’ includes that party’s successors and permitted assigns;
words in the singular include the plural and vice versa;
any words that follow ‘include’, ‘includes’, ‘including’, ‘in particular’ or any similar words and expressions shall be construed as illustrative only and shall not limit the sense of any word, phrase, term, definition or description preceding those words;
a reference to legislation is a reference to that legislation as amended, extended, re-enacted or consolidated from time to time; and
a reference to legislation includes all subordinate legislation made from time to time under that legislation.
Commencement date and duration
This Agreement commences and takes effect from the Commencement Date.
This Agreement shall continue from the Commencement Date for twelve months at which point it shall be renewed for successive periods of twelve months unless terminated earlier:
by either party for convenience on not less than 60 days prior written notice to the other; or
in accordance with clause 12.
Services
The Supplier shall provide Services relating to the Advertising on the Website as set out below:
the Customer shall provide a copy of the Advertising to the Supplier on or before the Commencement Date. The Supplier shall adapt and configure the Advertising as appropriate so that it can be uploaded on the Website and submit a copy of this to the Customer for its approval. The Supplier shall not issue, publish, distribute or otherwise pass to any third party or allow, suffer or permit to be issued, published, distributed or so passed any Advertising or promotional material without the Customer’s prior written approval, such approval not to be unreasonably withheld or delayed; and
subject to clause 4.2.1, all Advertising shall be required to comply with and shall be subject to the Website technical requirements or specifications as notified by the Supplier to the Customer from time to time. The Supplier has the absolute and unqualified right to refuse any Advertising relating to tobacco or alcohol or other advertising that it reasonably determines is illegal, offensive, contravenes its business aims, or is inappropriate to be featured on the Website.
[The Supplier shall use commercially reasonable efforts to make the Website and the Services available 24 hours a day, seven days a week, except for:
scheduled maintenance carried out during the maintenance window of 17:00 pm -8.00 am; and
unscheduled maintenance performed outside the window of time at clause 3.2.1 provided that the Supplier has used reasonable endeavours to give the Customer 1 Business Days’ notice in advance of the maintenance commencing.]
Once the Advertising has been duly approved by both parties, the Supplier shall upload the Advertising to and maintain it on the Website for the duration specified in Schedule 1, subject to payment by the Customer of applicable Fees in accordance with this Agreement. The Supplier shall not make any representations or warranties on the Customer’s behalf other than displaying the Advertising on the Website in the agreed form.
The Customer’s right to display the Advertising on the Website is non-exclusive and the Supplier shall be entitled to display any third-party promotional material on the Website, which may relate to direct competitors of the Customer.
Customer’s obligations
The Customer shall co-operate with the Supplier and shall promptly provide to the Supplier, at the Supplier’s request, such information concerning the Customer, the Customer’s requirements in respect of the Services and the Advertising to which the Services relate as is reasonably necessary to enable the Supplier to perform the Services.
The Customer shall ensure that the Advertising and their broadcast, publication or otherwise making the Advertising available to the public through the Website, in all material respects as delivered by the Supplier shall:
comply with all Advertising Regulations, applicable laws and any other applicable regulations, regulatory policies, guidelines or codes in each case from time to time in force, including all such guidelines and codes issued by statutory, regulatory and industry bodies;
not infringe the Intellectual Property Rights or proprietary rights of any third party;
not be defamatory, libellous, obscene or otherwise offensive; and
does not contain viruses or other computer programs intended to damage, interfere with or unlawfully process personal or other data.
The Customer shall ensure that the Supplier’s possession and use of any Intellectual Property Rights in the Advertising in the exercise of the Supplier’s obligations under this Agreement shall not infringe the Intellectual Property Rights or proprietary rights of any third party.
The Customer shall indemnify the Supplier, the Supplier’s Associates and their respective Personnel (together the “Supplier Indemnified Parties”) against all liabilities, costs, expenses, damages and losses (including but not limited to any direct, indirect or consequential losses, loss of profit, loss of reputation and all interest, penalties and legal costs (calculated on a full indemnity basis) and all other professional costs and expenses) suffered or incurred by the Supplier Indemnified Parties (“Losses”) arising out of or in connection with any third-party claims or any action, adjudication or decision taken against the Supplier Indemnified Parties by any regulatory body, in each case directly or indirectly arising (in whole or in part) out of any breach by the Customer of clause 4.2 and/or 3.
The Customer shall, at its own cost, take any legal and other advice as it considers necessary to ensure its compliance with clause 2. The Customer shall provide a copy of all legal and other advice obtained to the Supplier on request, always provided that the provision of such advice shall not reduce the Customer’s liability under clause 4.3.
The Supplier shall be entitled to remove Advertising from the Website if any Advertising:
infringes (or in the Supplier’s reasonable opinion is likely to infringe) any Intellectual Property Rights of any third party; or
breaches clause 2 or is otherwise illegal.
If either of the parties becomes aware that there is risk that any Advertising is not in compliance with clause 2, each shall promptly notify the other, and, without prejudice to any other right or remedy of the Supplier, the Customer shall make any modifications which may be necessary to remedy that defect in the Advertising. Any modifications shall be at the Customer’s cost unless the problem was due to the Supplier’s amending the Advertising without the Customer’s consent.
All Intellectual Property Rights in the Advertising belong to the Customer and the Customer grants to the Supplier a non-exclusive, non-transferable, royalty-free licence to use the Intellectual Property Rights to the extent necessary to allow the Supplier to provide the Services.
Supplier obligations
The Supplier shall procure that all Services delivered by the Supplier Personnel shall be carried out in good faith and upon the basis of information provided by the Customer.
The Supplier shall make all commercially reasonable efforts to provide the Customer with prior email notification of all scheduled and emergency interruptions to the availability of the Advertising on the Website and shall use al commercially reasonable endeavours to keep such interruptions to a minimum.
Services shall for the duration of this Agreement be delivered with reasonable due diligence and skill.
Time for performance
Except as otherwise expressly stated, time shall not be of essence in respect of the Supplier’s obligations under this Agreement.
Fees and expenses
The Customer shall pay the Supplier the Fees in respect of the Services provided under this Agreement.
The Supplier shall invoice the Customer for all sums due under this Agreement as specified in the Payment Schedule. The Customer shall pay such sums to the bank account specified on the relevant invoice in full without set-off or counterclaim within 14 days from the date of the invoice or on the due date for payment specified in the Payment Schedule (where such date is specified).
Where sums due under this Agreement are not paid in full by the due date, the Supplier may, without limiting its other rights, charge interest on such sums at 4% a year above the base rate of the Bank of England from time to time in force.
Interest shall apply from the due date for payment until actual payment in full, whether before or after judgment.
All amounts due under this Agreement are inclusive of VAT, sales or other tax applicable for the time being prescribed by law.
Data protection
Each party shall comply with its respective obligations, and may exercise its respective rights and remedies, under Schedule 3.
Limitation of liability
The extent of the parties’ liability under or in connection with this Agreement (regardless of whether such liability arises in tort, contract or in any other way and whether or not caused by negligence or misrepresentation) shall be as set out in this clause 9.
Subject to clauses 5, the Supplier’s total liability shall not exceed a sum equal to the value of the Fees paid by the Customer under this Agreement.
Subject to clauses 5, neither party shall be liable for any of the following (whether direct or indirect):
consequential, indirect or special losses;
loss of profit;
loss of or corruption to data;
loss of use;
loss of production;
loss of contract;
loss of opportunity;
loss of savings, discount or rebate (whether actual or anticipated);
harm to reputation or loss of goodwill.
Except as expressly stated in this Agreement, and subject to clause 5, all warranties and conditions whether express or implied by statute, common law or otherwise are excluded to the extent permitted by law.
Notwithstanding any other provision of this Agreement, the liability of the parties shall not be limited in any way in respect of the following:
death or personal injury caused by negligence;
fraud or fraudulent misrepresentation; and
any other losses which cannot be excluded or limited by applicable law.
Costs
Except for the payments specifically agreed in this Agreement, each party is responsible for its legal and other costs in relation to the preparation and performance of this Agreement.
Confidential Information
Each party shall maintain the confidentiality of the other party’s Confidential Information and shall not without the prior written consent of the other use, disclose, copy or modify the other party’s Confidential Information (or permit others to do so) other than as necessary for the exercise of its rights and performance of its obligations under this Agreement.
Each party undertakes to:
disclose the other party’s Confidential Information only to those of its officers, employees, agents and contractors (including Supplier Personnel) to whom and to the extent to which such disclosure is necessary for the purposes contemplated under this Agreement; and
procure that such persons are made aware of and agree in writing to observe the obligations in this clause.
The provisions of this clause shall not apply to information which:
is or comes into the public domain through no fault of the recipient, its officers, employees, agents or contractors;
is lawfully received by the recipient from a third party free of any obligation of confidence at the time of its disclosure;
is independently developed by the recipient, without access to or use of such Confidential Information; or
is required by law, by court or governmental or regulatory order to be disclosed provided that the relevant party, where possible, notifies the other party at the earliest opportunity before making any disclosure.
The obligations under this clause shall survive the variation, expiry or termination of this Agreement for a period of one year thereafter.
Termination
Either party may without prejudice to its other rights and remedies by notice in writing to the other party immediately terminate this Agreement if the other:
is in material or persistent breach of any of its obligations under this Agreement (where non-payment of any Fees constitutes a material breach) and if that breach is capable of remedy and the other has failed to remedy that breach within 30 days after receiving written notice requiring it to remedy that breach; or
is unable to pay its debts (within the meaning of section 123 of the Insolvency Act 1986) or becomes subject to a moratorium under Part A1 of the Insolvency Act 1986 or becomes insolvent or an order is made or a resolution passed for the administration, winding-up or dissolution of the other (otherwise than for the purposes of a solvent amalgamation or reconstruction) or an administrative or other receiver, manager, liquidator, administrator, trustee or similar officer is appointed over all or any substantial part of the assets of the other or the other enters into or proposes any composition or arrangement with its creditors generally or becomes subject to a restructuring plan under Part 26A of the Companies Act 2006 or a scheme of arrangement under Part 26 of the Companies Act or any analogous event occurs in any applicable jurisdiction;
ceases or threatens to cease carrying on business; or
undergoes a change of Control.
The Supplier may terminate this Agreement by immediate notice where the Customer breaches any of the provisions of clause 4.
In the event of termination of this Agreement for any reason:
all Fees due at the point the agreement is terminated shall become due for immediate payment by the Customer; and
each party shall (without prejudice to any additional obligations under Schedule 3) within 5 Business Days of such termination return (or, at the other party’s option, destroy) all Confidential Information in its possession or under its control and all copies of such information.
Termination of this Agreement for whatever reason shall not operate to affect any provisions that expressly or by implication survive termination.
Dispute resolution
If either party believes in good faith that the other party has breached any term of this Agreement, then the first party shall notify the other party, in writing setting out in reasonable detail the nature of the alleged breach (“Notice of Breach”). If the other party does not dispute the validity of the Notice of Breach, then it shall promptly undertake to cure the breach. If however, the other party disputes the validity of the Notice of Breach, then the parties shall comply with the following provision in order to expedite the review, verification, cure and remedy of any such breach.
Any dispute to be resolved pursuant to this Agreement shall first be submitted for resolution to the Authorised Contacts of each party. If such Authorised Contacts are unable to resolve the dispute within ten Working Days after the date on which the Notice of Breach is received by the other party (or such longer time as is mutually agreed in writing), then each party shall be free to pursue whatever remedies under this Agreement, at law or in equity may be available to it in respect of the subject matter of the dispute.
Entire agreement
This Agreement constitutes the entire agreement between them and supersedes all previous agreements, understandings and arrangements between them, whether in writing or oral in respect of its subject matter.
Each party acknowledges that it has not entered into this Agreement in reliance on, and shall have no remedies in respect of, any representation or warranty that is not expressly set out in this Agreement.
Notices
Any notice given by a party under this Agreement shall be in writing and sent to the relevant party at the address set out in clause 3.
Notices may be given, and are deemed received:
by hand: on receipt of a signature at the time of delivery;
by pre-paid or tracked post: on the second Business Day after posting;
by email: at the time of transmission.
Notices shall be sent to:
FE Tech Limited and marked for the attention
Any change to the contact details of a party as set out in clause 3 shall be notified to the other party in accordance with clause 15.1.
This clause does not apply to notices given in legal proceedings or arbitration.
Force majeure
In this clause inability to pay is not Force Majeure.
A party shall not be liable if delayed in or prevented from performing its obligations under this Agreement due to Force Majeure, provided that it promptly notifies the other of the Force Majeure event and its expected duration and uses reasonable endeavours to minimise the effects of that event.
If, due to Force Majeure, a party:
is unable to perform a material obligation; or
is delayed in or prevented from performing its obligations for a continuous period of 30 days during the term of this Agreement,
the other party may terminate this Agreement on not less than 2 weeks’ written notice.
Further assurance
Each party shall at the request of the other, and at the cost of the requesting party, do all acts and execute all documents which are necessary to give full effect to this Agreement.
Variation
No variation of this Agreement shall be valid or effective unless it is in writing, refers to this Agreement and is duly signed or executed by, or on behalf of, each party.
Assignment
The Customer shall not assign, subcontract or encumber any right or obligation under this Agreement, in whole or in part, without the Supplier’s prior written consent.
No partnership or agency
The parties are independent businesses and are not partners, principal and agent or employer and employee and this Agreement does not establish any joint venture, trust, fiduciary or other relationship between them, other than the contractual relationship expressly provided for in it. None of the parties shall have, nor shall represent that they have, any authority to make any commitments on the other party’s behalf.
Equitable relief
Each party recognises that any breach or threatened breach of this Agreement may cause the other party irreparable harm for which damages may not be an adequate remedy. Accordingly, in addition to any other remedies and damages available to the other party, each party acknowledges and agrees that the other party is entitled to the remedies of specific performance, injunction and other equitable relief without proof of special damages.
Severance
If any provision of this Agreement (or part of any provision) is or becomes illegal, invalid or unenforceable, the legality, validity and enforceability of any other provision of this Agreement shall not be affected.
If any provision of this Agreement (or part of any provision) is or becomes illegal, invalid or unenforceable but would be legal, valid and enforceable if some part of it was deleted or modified, the provision or part-provision in question shall apply with such deletions or modifications as may be necessary to make the provision legal, valid and enforceable. In the event of such deletion or modification, the parties shall negotiate in good faith in order to agree the terms of a mutually acceptable alternative provision.
Waiver
No failure, delay or omission by either party in exercising any right, power or remedy provided by law or under this Agreement shall operate as a waiver of that right, power or remedy, nor shall it preclude or restrict any future exercise of that or any other right, power or remedy.
No single or partial exercise of any right, power or remedy provided by law or under this Agreement shall prevent any future exercise of it or the exercise of any other right, power or remedy.
A waiver of any term, provision, condition or breach of this Agreement shall only be effective if given in writing and signed by the waiving party, and then only in the instance and for the purpose for which it is given.
Counterparts
This Agreement may be signed in any number of separate counterparts, each of which when signed and dated shall be an original, and such counterparts taken together shall constitute one and the same agreement.
Third party rights
Except as expressly provided for in this Agreement, a person who is not a party to this Agreement shall not have any rights under the Contracts (Rights of Third Parties) Act 1999 to enforce any of the provisions of this Agreement.
Governing law and jurisdiction
This Agreement and any dispute or claim arising out of, or in connection with, it, its subject matter or formation (including non-contractual disputes or claims) shall be governed by, and construed in accordance with, the laws of England and Wales.
the parties irrevocably agree that the courts of England and Wales shall have {exclusive OR non-exclusive} jurisdiction to settle any dispute or claim arising out of, or in connection with, this Agreement, its subject matter or formation (including non-contractual disputes or claims).
– Advertising Particulars
Detail within the particular customer quotation.
– Payment Schedule
– detail within the customer quotation.
– Data protection
DEFINITIONS
Controller, Processor, Data Subject, Personal Data, Personal Data Breach, processing and appropriate technical and organisational measures: as defined in the Data Protection Legislation.
Data Protection Legislation:
To the extent the UK GDPR applies, the law of the United Kingdom or of a part of the United Kingdom which relates to the protection of Personal Data.
To the extent the EU GDPR applies, the law of the European Union or any member state of the European Union to which the Customer or Supplier is subject, which relates to the protection of personal data.
EU GDPR: the General Data Protection Regulation ((EU) 2016/679).
UK GDPR: has the meaning given to it in section 3(10) (as supplemented by section 205(4)) of the Data Protection Act 2018.
DATA PROTECTION
Both parties will comply with all applicable requirements of the Data Protection Legislation. This paragraph 1 is in addition to, and does not relieve, remove or replace, a party’s obligations or rights under the Data Protection Legislation.
The parties acknowledge that for the purposes of the Data Protection Legislation, the Customer is the Controller and the Supplier is the Processor. Annex A to this Schedule sets out the scope, nature and purpose of processing by the Supplier, the duration of the processing and the types of Personal Data and categories of Data Subject.
Without prejudice to the generality of paragraph 1, the Customer will ensure that it has all necessary appropriate consents and notices in place to enable lawful transfer of the Personal Data to the Supplier and/or lawful collection of the Personal Data by the Supplier on behalf of the Customer for the duration and purposes of this Agreement.
Without prejudice to the generality of paragraph 1, the Supplier shall, in relation to any Personal Data processed in connection with the performance by the Supplier of its obligations under this Agreement:
process that Personal Data only on the documented written instructions of the Customer unless the Supplier is required by any applicable law to otherwise process that Personal Data. Where the Supplier is relying on an applicable law as the basis for processing Personal Data, the Supplier shall promptly notify the Customer of this before performing the processing required by applicable unless the applicable law prohibits the Supplier from so notifying the Customer;
ensure that it has in place appropriate technical and organisational measures, reviewed and approved by the Customer, to protect against unauthorised or unlawful processing of Personal Data and against accidental loss or destruction of, or damage to, Personal Data, appropriate to the harm that might result from the unauthorised or unlawful processing or accidental loss, destruction or damage and the nature of the data to be protected, having regard to the state of technological development and the cost of implementing any measures (those measures may include, where appropriate, pseudonymising and encrypting Personal Data, ensuring confidentiality, integrity, availability and resilience of its systems and services, ensuring that availability of and access to Personal Data can be restored in a timely manner after an incident, and regularly assessing and evaluating the effectiveness of the technical and organisational measures adopted by it);
ensure that all personnel who have access to and/or process Personal Data are obliged to keep the Personal Data confidential; and
not transfer any Personal Data outside of the EEA unless the prior written consent of the Customer has been obtained and the following conditions are fulfilled:
the Customer or the Supplier has provided appropriate safeguards in relation to the transfer;
the data subject has enforceable rights and effective legal remedies;
the Supplier complies with its obligations under the Data Protection Legislation by providing an adequate level of protection to any Personal Data that is transferred; and
the Supplier complies with reasonable instructions notified to it in advance by the Customer with respect to the processing of the Personal Data;
assist the Customer, at the Customer’s cost, in responding to any request from a Data Subject and in ensuring compliance with its obligations under the Data Protection Legislation with respect to security, breach notifications, impact assessments and consultations with supervisory authorities or regulators;
notify the Customer without undue delay on becoming aware of a Personal Data Breach;
at the written direction of the Customer, delete or return Personal Data and copies thereof to the Customer on termination of the agreement unless required by an applicable law to store the Personal Data; and
maintain complete and accurate records and information to demonstrate its compliance with this paragraph 1 and allow for audits by the Customer or the Customer’s designated auditor and immediately inform the Customer if, in the opinion of the Supplier, an instruction infringes the Data Protection Legislation.
The Customer consents to the Supplier appointing third-party processors of Personal Data under this Agreement. The Supplier confirms that it has entered or (as the case may be) will enter with a third-party processor into a written agreement incorporating terms which are substantially similar to those set out in this paragraph 1 and in either case which the Supplier confirms will reflect the requirements of the Data Protection Legislation. As between the Customer and the Supplier, the Supplier shall remain fully liable for all acts or omissions of any third-party processor appointed by it pursuant to this paragraph 1.5.
Annex A – Processing, Personal Data and Data Subjects
Processing by the Supplier
Scope
Nature
Purpose of processing
Duration of the processing
Types of Personal Data
Categories of Data Subject
Third Party Processors
Our carefully selected partners and service providers may process personal information about you on our behalf as described below:
“Digital Marketing Service Providers
We periodically appoint digital marketing agents to conduct marketing activity on our behalf, such activity may result in the compliant processing of personal information. Our appointed data processors include:
(i)Prospect Global Ltd (trading as Sopro) Reg. UK Co. 09648733. You can contact Sopro and view their privacy policy here: http://sopro.io. Sopro are registered with the ICO Reg: ZA346877 their Data Protection Officer can be emailed at: dpo@sopro.io.”