PRIVACY POLICY

Revision Date — 03/09/2026

1. General Provisions

1.1. This Policy describes how SMARTSUPPLY HUB LTD (hereinafter — the “Company”), operator of the SERVX Service Club, incorporated in England and Wales, processes the personal data of Clients in accordance with applicable data protection legislation. The Company independently determines the purposes and means of processing the Client’s personal data and is responsible for such processing.

This Policy forms an integral part of the Company’s Terms and Conditions of Membership and shall be read together with them.

1.2. By accessing the servx.ai website and providing any personal data through the SERVX Service Club, you accept and agree to our rules for the collection, use, and transfer of your personal information in accordance with this Privacy Policy. If you do not agree with the terms of this Privacy Policy, you may not access or use the SERVX Service Club.

2. Age Restrictions

The Service Club is intended exclusively for persons over the age of 18. The Company does not knowingly collect or process the personal data of minors. If the Company becomes aware that a minor’s data has been provided without proper authority to do so, such data will be deleted as soon as reasonably possible.

3. What Data We Collect

• Contact and identification data provided when submitting an application and registering for membership (name, contact details, other data necessary for entering into the Membership Agreement).
• Data necessary for the performance of specific Instructions (for example, passport details for bookings, delivery addresses).
• Information about the payment address issued to the Client for topping up the balance, as well as the history of top-ups and transactions on the Client’s balance within the Service Club.
• Technical information collected when using the Website (to the extent necessary for its operation).

4. Purposes of Processing

Data is processed for: entering into and performing the Membership Agreement; arranging Instructions through Suppliers; communicating with the Client; complying with applicable legal requirements.

5. Legal Bases for Processing

Processing is carried out on the basis of:

• performance of the Membership Agreement with the Client;
• the Company’s legitimate interests in providing a quality service;
• compliance with the Company’s legal obligations.

6. Disclosure of Data to Third Parties

The Client’s data is disclosed to Suppliers solely to the extent necessary for the performance of a specific Instruction. Suppliers are required to comply with confidentiality requirements in accordance with the SERVX Supplier Code of Conduct. The Company does not disclose data to third parties for other purposes without the Client’s consent, except as provided by law.

7. International Data Transfers

Due to the international nature of the services, data may be transferred to Suppliers located outside the United Kingdom. In such cases, the Company takes reasonable measures to ensure an adequate level of data protection.

8. Retention Period

Data is retained for the duration of membership and thereafter for the period necessary to comply with the Company’s legal obligations, after which it is deleted or anonymised.

9. Client’s Rights

9.1. In accordance with the UK GDPR, the Client has the right to:

• request access to their data;
• request rectification or erasure of their data;
• restrict or object to processing;
• receive their data in a structured format (the right to data portability);
• lodge a complaint with the Information Commissioner’s Office (ICO).

9.2. The Company shall make efforts to ensure a prompt response to Client requests — as a rule, within one month of receipt of the request. Where necessary, taking into account the complexity or number of requests, this period may be extended, of which the Client will be additionally notified.

10. Automated Decision-Making

The Company does not apply automated decision-making or profiling that would produce legal effects concerning the Client or otherwise significantly affect the Client’s interests.

11. Data Security

The Company applies reasonable technical and organisational measures to protect the Client’s data against unauthorised access, loss, or disclosure.

12. Cookies

The SERVX Website uses only technically necessary cookies for the proper functioning of the Website and the Personal Account.

13. Changes to the Policy

The Company may update this Policy. The current version shall be published on the Website and shall apply from the moment of publication.

14. Language Precedence

This document has been prepared in the English language. In the event of any discrepancy or inconsistency between language versions or translations, the English-language version shall prevail.

15. Contacts

For questions relating to the processing of personal data, the Client may contact:

Address: 124-128 City Road, London, England, EC1V 2NX, United Kingdom

Email: [email protected]