Inovat respects the privacy of the users of the App and/or Web and is committed to protecting the personal data and respecting your privacy. Inovat will always keep your information safe and private & never sell your information. We believe that you have a right to know our practices regarding the personal data that we may collect and use while you use App and/or Web.

• We want to explain how and why we gather, store, share and use your personal data - as well as help to better guide the controls and choices users have around when and how users choose to share personal data

• Alternatively, if you do not agree with the content of this Policy, then please remember it is your choice whether you want to use the service provided by Inovat

• If you have concerns about how we use your personal information, you can contact us at info@inovat.tax

Inovat is defined as the 'data controller' of user’s personal information under data protection law. Inovat develops and manages the App and/or Web and is the owner and provider of https://inovat.tax

• Inovat as a “data controller”- Inovat acts as a service provider towards you. Via the App and/or Web, we assist you with the filing of a digital VAT refund, any communication with a local tax authority and provide you with the refund once granted by the local tax authority. In this regard, Inovat is responsible for the processing of personal data collected via the App and/or Web

• Inovat as a “data processor” - Inovat acts as a service provider towards the local tax authorities which are the data controller. The personal data you provide to us via the App and/or Web will be included in databases to which the local tax authorities will have access to facilitate and support the exercise of their public tasks and authority. These databases will be managed in accordance with the instruction we receive from the local tax authorities as a data controller We are Inovat LTD. Our registered office is 9th Floor 107 Cheapside, London, United Kingdom, EC2V 6DN United Kingdom. Our company number is 12191517

Users agree to the Terms & Conditions set out in this Privacy Policy, including to the collection and procession of personal information, including to the collection and processing of your personal information (as defined below), by entering and/or connecting and/or using the website and/or installing the App and/or Web. If you disagree to any term provided herein, you may not enter into, connect to, access and/or use the website and/or may not install, access and/or use the App and/or Web and you are requested to promptly delete your profile from the Web and/or uninstall the App from your mobile device. For the avoidance of doubt, you hereby consent to the collection, processing, transfer and use of your personal information. You acknowledge and confirm that you are not required to provide us with your personal information and that such information is voluntarily provided to us.

We only collect the personal data you provide us with via the App and/or Web. This includes but not limited to:

• Personal data: Legal first name, Legal last name, Date of birth, Nationality, Country of residence, Home Address, City, Postcode

• Account data: Email and/or Phone number and (encrypted) password;

• Logs relating to access and use of the App and/or Web

• Photo of the passport (including full name, birth date and birthplace, nationality, passport number, national ID number, country and date of issuance/expiry of the passport and other information mentioned on the passport)

• Travel data: date and time of arrival and departure from EU, photo of the outbound boarding pass

• Information on the purchased product: photo of the receipt, price, VAT, type of product, store of purchase, date of purchase and other information possibly included on the purchase receipt

• Electronic localisation data: location at the time of taking the photograph of the receipt in order to verify whether the user of the mobile application is physically in the store, location at the time of confirmation of homecoming;

• IP-address and unique device identifier

• Financial specificities: bank account number, PayPal account information; WeChat, Alipay, card details. Your financial specificities are only collected to perform a refund payment. In order to have access to the location data and camera of your mobile device, specific authorisation is requested via the pop-up screen. Without the provision of the personal data outlined above, you cannot use the App and/or Web. In addition to the above categories of personal data, we may process any other type of personal data you voluntarily provide to us, as well as the information we deduce or generate in this context.

There are two main methods we use:

• We collect information through your entry, connection, installation, access and/or use of the App and/or Web. When you are using the App and/or Web we are aware of it and may gather, collect and store the information relating to such usage. For instance, when you are using the App and/or Web we collect data produced by your device, such as your geo-location

• We collect information which you provide us voluntarily. For instance, we collect Personal Information when you register, open an Account and when you fill out the refund request. We may gather, collect and store such information either independently or through the help of our authorised third-party service providers as described below. We collect such data in such manner, to achieve the purposes set out in this Privacy Policy

When a user interacts with Inovat service, we use a different variety of technologies. We use your information in the following ways, but not limited to:

• Provide and Personalise your Inovat service of getting VAT refund digitally and receive VAT refunds via our platform

• To fix, diagnose, troubleshoot and better understand any technical difficulties or issues with our services, making sure that the Website and/or App are as effective and relevant to give you the best experience they can

• To comply with the tax authority on submitting the VAT returns and ensure that we comply with the legal, tax and audit obligations

• To connect, evaluate, and develop new features, services, technologies and improvements to the Inovat service

• In case we need to connect with the user to send notifications to check we have carried out your instructions correctly or to resolve queries or issues after the User has agreed to accept push notifications

• To access if the customer is eligible to use our services and to geolocate the customer’s position in order to comply with the VAT regulations

• To prevent fraud, money laundering activities and provide security for our users

• To send marketing messages to the users with updates or relating to our retail partner’s services and/or products, monitor our user activity to measure, understand and improve the effectiveness of any functionality

• To process your payments with the provided bank details

• Sometimes we share your information with our partners, with those we do business with

• We share the anonymized data with our KYC and AML partners, with tax authorities and border force in order to assist them with fraud prevention and support the exercise of their KYC process

• We work with service providers that work on our behalf which may need access to certain personal data in order to provide their services to us. These companies include those we've hired to provide customer authentication, customer support, operate the technical infrastructure that we need to provide the Inovat service (e.g. cloud storage providers, IT service providers), assist in protecting and securing our systems and services, and help market Inovat’s own products and services as well as partner products, services, events, and co-branded promotions in which Inovat is involved

• We share personal data with our payment providers to enable payment processing or for anti-fraud purposes

• We work together with advertising parties to enable us to customize the advertising content you may receive on the Inovat Service. These include helping us delivering more relevant ads, recommendation items and our partner’s promotional messages. We may process some of your purchasing data to help Inovat understand your behaviour and preferences so that we can deliver a more personalized version to you

• Inovat may also need to transfer personal data, if estimated in good faith that it is necessary, to other parties such as public authorities

• Inovat keeps user data only as long as necessary to provide Inovat services and for reasonable and essential business purposes, such as maintaining platform service, providing audit details or complying with legal obligations

• You can object to the data processing (ask the processing to be restricted) and/or request for this data to be deleted or anonymized. You have a right to request a copy of the personal data you provided to us. These rights can be exercised by contacting us on info@inovat.tax

• If you have given us any consent that we need to use your personal data, you can withdraw your consent at any time by sending an email to info@inovat.tax

• If the user asks to terminate all personal data, Inovat would not be able to provide the user with Inovat services

• If you have consented thereto, Inovat can send direct marketing messages to you relating to third party services or products and monitor the behaviour of the Users for advertising purposes

• You may choose to share personal data (for example, your email address) with our partners who may want to directly send you news or promotional offers. You will always have the option to change your mind and withdraw your consent at any time

You agree that we may use your contact details you provided to us (including, without limitation, email address) to provide you commercial and/or non-commercial materials related to our current and/or future products and services. You can always withdraw your consent by following the instructions in the message sent to you or by sending us an email to info@inovat.tax

• We process the data through our secure servers in the UK and European Union and normally store it for several years

• Sometimes the information goes outside the UK and European Union, but we try and keep this to a minimum

• Inovat is committed to protecting users’ personal data. We use accepted industry standard technologies and organisational flows to help protect and ensure the security of your personal data. However, please note that there is an inherent risk of transmitting information over the internet and we cannot guarantee that use of our Personal information or unauthorised access will never occur. Inovat will not be liable for any loss or damage of any data or information, deletion, hacking, unauthorised access, theft or other security intrusions

• Users passwords protect your user accounts, so we strongly recommend using the password that is unique to your Inovat account and never share it and log out after using Inovat’s service. No Inovat employee will ask you for your password

Inovat reserves the right to change this policy from time to time, so please re-visit this page frequently.

• “data protection laws” means the General Data Protection Regulation (EU 2016/679) or any substantially equivalent law enacted in the UK, as applicable

• “your information” or “information about you” means personal data (as defined in the data protection laws) about you