PRIVACY POLICY

Last Updated: 12th Jan 2026

1. Introduction

Activated Assets Group Ltd ("we", "us", or "our") respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our websites, use our services, or enter into a leasing agreement with us. It also tells you about your privacy rights and how the law protects you.

This policy applies to all trading styles and brands falling under the Group structure, specifically:

Activated Assets (Digital Marketing & Infrastructure)

AI People (Digital Marketing Assistants)

The 19th Hole (Leisure Assets & Leasing)

2. Who We Are

Activated Assets Group Ltd is the controller and responsible for your personal data.

Contact Details:

Full name of legal entity: Activated Assets Group Ltd

Email address: [email protected]

Postal address: available upon request

ICO Registration Number: TBA

3. The Data We Collect About You

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

Identity Data: First name, last name, username, or similar identifier.

Contact Data: Billing address, delivery address, email address, and telephone numbers.

Financial Data: Bank account and payment card details (for billing). Note: For "The 19th Hole" leasing applications, we may collect business financial history to pass to our finance brokerage partners.

Transaction Data: Details about payments to and from you and other details of products/software you have purchased or leased from us.

Technical Data: Internet protocol (IP) address, browser type and version, time zone setting, and operating system (when you use our SaaS platform or website).

Profile Data: Your username and password, purchases or orders made by you, your interests, preferences, and feedback.

Marketing and Communications Data: Your preferences in receiving marketing from us and your communication preferences.

4. How We Use Your Personal Data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Performance of Contract: Where we need to perform the contract we are about to enter into or have entered into with you (e.g., providing the "Core Four" software or leasing a Simulator).

Legitimate Interest: Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests (e.g., B2B marketing to potential partners).

Legal Obligation: Where we need to comply with a legal or regulatory obligation (e.g., keeping records for HMRC).

5. Our Role as a Data Processor (Important for Agency Clients)

When you use our Activated Assets software services (SaaS) to manage your customers (e.g., uploading your growing database, sending SMS campaigns, or using our AI Voice Agents):

You (Child Account) are the Data Controller. You decide why and how that data is processed.

We (Activated Assets Group Ltd) are the Data Processor. We process that data only on your instructions to provide the software service.

We utilize third-party sub-processors to deliver these services, primarily HighLevel (GoHighLevel), Twilio, and LeadConnector. By using our services, you authorize us to use these sub-processors.

6. Disclosures of Your Personal Data

We may have to share your personal data with the parties set out below for the purposes set out in paragraph 4.

Technology Partners: Providers of our underlying SaaS infrastructure (GoHighLevel), AI platforms (OpenAI), and Telephony providers (Twilio).

Financial Partners: If you apply for asset finance or leasing, we will share your details with our regulated credit brokerage partners to secure your funding.

Professional Advisers: Acting as processors or joint controllers including lawyers, bankers, auditors, and insurers based in the UK.

HM Revenue & Customs: Regulators and other authorities acting as processors or joint controllers based in the United Kingdom.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law.

7. International Transfers

Many of our external third parties (specifically our SaaS technology providers) are based outside the UK and the European Economic Area (EEA), specifically in the United States. Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring specific contracts (Standard Contractual Clauses) approved by the UK Government are used which give personal data the same protection it has in the UK.

8. Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way. 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.

9. Data Retention

We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

Client Records: We are required by law to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

10. Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data, including the right to:

Request access to your personal data.

Request correction of your personal data.

Request erasure of your personal data.

Object to processing of your personal data.

Request restriction of processing your personal data.

Request transfer of your personal data.

Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us at [email protected].

11. Third-Party Links

Or websites and software may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements.