=============================================================================== INCHARGEO LIMITED PRIVACY NOTICE =============================================================================== Last updated: 2 June 2026 Version 1.0 This notice explains how Inchargeo Limited collects, uses, shares and protects personal data, and the rights you have over your information under UK data protection law. A web version of this notice is available at: https://inchargeo.com/privacy-notice.html If you need this notice in a different format - for example large print, easy-read, or another language - please contact privacy@inchargeo.com. ------------------------------------------------------------------------------- CONTENTS ------------------------------------------------------------------------------- 1. Who we are 2. Scope of this notice 3. Our roles: controller and processor 4. What data we collect (as controller) 5. The Inchargeo application 6. Our lawful bases (as controller) 7. Who we share data with 8. International transfers 9. How long we keep data 10. How we protect data 11. Your rights 12. Cookies 13. Changes to this notice 14. How to complain 15. Alternative formats ------------------------------------------------------------------------------- 1. WHO WE ARE ------------------------------------------------------------------------------- Inchargeo Limited ("Inchargeo", "we", "us", "our") provides an infrastructure, operations and energy management platform for healthcare organisations. We are committed to protecting personal data and handling it responsibly, lawfully and transparently. For the purposes of UK data protection law - the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018 - our details and contact point for privacy matters are: Organisation Inchargeo Limited Company number 12759920 Registered address Belmont Suite, Paragon Business Park, Chorley New Road, Horwich, Bolton, England, BL6 6HG ICO registration ZA923193 Privacy contact privacy@inchargeo.com If you have any questions about this notice or about how we handle personal data, please contact us at privacy@inchargeo.com. ------------------------------------------------------------------------------- 2. SCOPE OF THIS NOTICE ------------------------------------------------------------------------------- This notice covers personal data we process in connection with: - Our website at inchargeo.com - for example, when you contact us, make an enquiry, or browse the site; and - The Inchargeo application - the software platform we provide to healthcare organisations, which is described in section 5. It does not cover third-party websites that we may link to. Those sites have their own privacy notices, and we are not responsible for their practices. ------------------------------------------------------------------------------- 3. OUR ROLES: CONTROLLER AND PROCESSOR ------------------------------------------------------------------------------- Data protection law distinguishes between a "controller" (who decides why and how data is processed) and a "processor" (who processes data on a controller's behalf). Inchargeo acts in both roles, depending on the activity: - As a controller - for personal data collected through our website and through direct enquiries, marketing and supplier/customer relationship management. This notice tells you how we use that data. - As a processor - for data processed within the Inchargeo application that we deploy for a customer. In that case the customer (for example, an NHS organisation) is the controller and decides how the data is used. Our processing is governed by a written data processing agreement with that customer, and their own privacy information will apply to individuals. ------------------------------------------------------------------------------- 4. WHAT DATA WE COLLECT (AS CONTROLLER) ------------------------------------------------------------------------------- Through our website and business relationships, we may collect and use: Information you give us - Contact and identity details - such as your name, job title, organisation, email address and phone number when you contact us, request a demonstration, or enter into a contract with us. - Correspondence - the content of emails and messages you send us. Information we collect automatically - Technical and usage data - such as your IP address, browser type, device information, and pages visited, collected through server logs and any cookies (see section 12). We use this data to respond to enquiries, provide and administer our services, manage our relationship with you, meet legal and contractual obligations, and - where permitted - send relevant information about our services. We do not sell personal data. ------------------------------------------------------------------------------- 5. THE INCHARGEO APPLICATION ------------------------------------------------------------------------------- The Inchargeo application is typically deployed on the customer's own premises and is not exposed to the public internet. It is an infrastructure-management tool: it collects and presents network and operational statistics, such as information about connected network devices and the users associated with them, to help the organisation manage and optimise its estate. >> The application does NOT process patient data, clinical records, or other special-category (sensitive) personal data. It is designed for managing network and infrastructure operations, not for handling health information. Any personal data processed within the application (for example, identifiers relating to network devices or to the staff who use the system) is processed on behalf of, and under the instructions of, the customer organisation, which is the controller of that data. Because the deployment sits within the customer's environment, the customer retains control over that data. If you are a member of staff or user of an organisation that has deployed Inchargeo and you have questions about how your data is used in the application, please contact that organisation, which can also direct any request to us as its processor. ------------------------------------------------------------------------------- 6. OUR LAWFUL BASES (AS CONTROLLER) ------------------------------------------------------------------------------- We only process personal data where we have a lawful basis under Article 6 of the UK GDPR. Depending on the situation, we rely on: - Legitimate interests - to respond to enquiries, run and promote our business, and keep our website secure, where this is not overridden by your interests or rights. - Performance of a contract - to provide services to, or receive services from, you or your organisation. - Legal obligation - where we must process data to comply with the law. - Consent - for certain activities such as optional cookies or marketing, where required. You can withdraw consent at any time. ------------------------------------------------------------------------------- 7. WHO WE SHARE DATA WITH ------------------------------------------------------------------------------- We do not sell personal data. We may share it with: - Service providers who help us operate our business and website - for example, our website hosting provider (DigitalOcean) and email/communication providers - acting as our processors under contract. - Professional advisers such as legal, accounting and IT advisers, where necessary. - Authorities and regulators where we are required to do so by law. Where Inchargeo acts as a processor (section 5), data sharing is governed by our agreement with the customer controller. ------------------------------------------------------------------------------- 8. INTERNATIONAL TRANSFERS ------------------------------------------------------------------------------- We keep personal data within the United Kingdom. Where Inchargeo acts as a processor, customer data resides on a server hosted within the customer's own data centre. Our public website is hosted on infrastructure located in the UK. We do not transfer personal data outside the UK. If this ever changes - for example, if we engage a service provider that stores data overseas - we will ensure appropriate safeguards are in place as required by UK data protection law (such as adequacy regulations or the International Data Transfer Agreement / Addendum) and update this notice. ------------------------------------------------------------------------------- 9. HOW LONG WE KEEP DATA ------------------------------------------------------------------------------- We keep personal data only for as long as necessary for the purposes for which it was collected, including to meet legal, accounting or reporting requirements. Enquiry and contact data is generally kept for no longer than is needed to manage our relationship with you, after which it is securely deleted or anonymised. Where we act as a processor, retention is determined by our agreement with the customer controller. ------------------------------------------------------------------------------- 10. HOW WE PROTECT DATA ------------------------------------------------------------------------------- We use appropriate technical and organisational measures to protect personal data against unauthorised access, loss, misuse or alteration. These include access controls, role-based permissions, and secure, containerised deployment. The Inchargeo application is designed to run within the customer's own environment and is not exposed to the public internet. ------------------------------------------------------------------------------- 11. YOUR RIGHTS ------------------------------------------------------------------------------- Under UK data protection law you have rights over your personal data, including the right to: - be informed about how your data is used (this notice); - request access to the personal data we hold about you; - request correction of inaccurate or incomplete data; - request erasure of your data in certain circumstances; - restrict or object to our processing in certain circumstances; - data portability in certain circumstances; and - withdraw consent at any time where we rely on consent. To exercise any of these rights, contact us at privacy@inchargeo.com. We will respond within one month, as required by law. There is normally no charge. If your request relates to data we process on behalf of a customer organisation (as a processor), we will direct you to, or work with, that organisation as the controller. ------------------------------------------------------------------------------- 12. COOKIES ------------------------------------------------------------------------------- Our website uses only the cookies necessary for it to function and to keep it secure. We do not use analytics, advertising or third-party tracking cookies. If we introduce optional or analytics cookies in future, we will ask for your consent first and update this notice. ------------------------------------------------------------------------------- 13. CHANGES TO THIS NOTICE ------------------------------------------------------------------------------- We may update this notice from time to time to reflect changes in our practices or legal requirements. The "last updated" date at the top shows when it was last revised. Significant changes will be made clear on the web version of this page. ------------------------------------------------------------------------------- 14. HOW TO COMPLAIN ------------------------------------------------------------------------------- If you have a concern about how we handle your personal data, please contact us first at privacy@inchargeo.com so we can try to resolve it. You also have the right to lodge a complaint with the UK's supervisory authority for data protection, the Information Commissioner's Office (ICO): Authority Information Commissioner's Office Website https://ico.org.uk/make-a-complaint/ Helpline 0303 123 1113 Post Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF ------------------------------------------------------------------------------- 15. ALTERNATIVE FORMATS ------------------------------------------------------------------------------- We want this information to be accessible to everyone. If you need this notice in a different format - for example, large print, plain text, easy-read, or another language - please contact us at privacy@inchargeo.com and we will do our best to provide it. =============================================================================== (c) 2026 Inchargeo Limited. All rights reserved. ICO registration ZA923193. ===============================================================================