INTRODUCTION 

Cambridge Animal Technologies Ltd is committed to protecting the privacy and security of your Personal  Data. 

This privacy notice describes how we collect and use information about you that could be used to identify you (“Personal Data”), in accordance with the General  Data Protection Regulation (“GDPR”). 

We  may update this notice at any time. It is important that you read this notice  so that you are aware of how and why we are collecting or processing Personal Data  about you and what your rights are under the data protection legislation. 

Cambridge Animal Technologies Ltd is a “data controller”. This means we are responsible for deciding how we hold and use Personal Data about you. We are required under data protection legislation to notify you  of the information contained in this privacy notice. 

DATA PROTECTION PRINCIPLES 

We will comply with data protection law. This says that the Personal Data we hold about you must be:

1. Used lawfully and in a transparent way;
2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is  incompatible with those purposes;
3. Relevant to the purposes we have told you about and limited only to those purposes;
4. Accurate and kept up to date;
5. Kept only as long as necessary for the purposes we have told you about; and
6. Kept securely 

HOW WILL WE USE PERSONAL DATA ABOUT YOU?

We will only use your Personal Data when the law allows us to. The GDPR explains what legal bases data  controllers can rely on to legally process Personal Data. Most commonly, the bases we will rely on to use  your Personal Data are as follows:

1. Where you have consented to us using your Personal Data, 
2. Where we need to comply with a legal obligation, such as reporting fraudulent activity or other illegal  actions (“Legal Compliance”); and
3. Where it is necessary for legitimate interests pursued by us or a third party and your interests and  fundamental rights do not override those interests, such as providing a list of our customers to  investors as part of a due diligence process; (“Legitimate Interest”). 

WHAT CATEGORIES OF YOUR PERSONAL DATA DO WE COLLECT, STORE AND USE? 

Below we list all of the categories of Personal Data we collect, store and use. Not all of the following types of  data will necessarily be collected from you, but this is the full scope of Personal Data that we may collect: 

• Personal contact details such as name, title, addresses, telephone numbers, and personal email  addresses; 
• Bank account details, payroll records and tax status information

WHEN DO WE COLLECT YOUR PERSONAL DATA AND WHAT IS OUR LEGAL BASIS FOR COLLECTING IT? 

Under the GDPR you are entitled to understand exactly when we collect different categories of your  Personal Data and what legal justification we rely on in order to use that Personal Data. 

Set out below is a table containing the different categories of Personal Data we collect, when we collect it (e. g. the activity that gives rise to the Personal Data collection) and the lawful basis for collecting, processing  and using that Personal Data. Please refer to the section entitled “How Will We Use Personal Data About  You?” to understand more about the legal basis we rely on. 

Examples provided in the table below are indicative in nature and the purposes for which we use your data  may be broader than described, but we will never process your data without a legal bases for doing so and  it is for a related purpose. For further inquiries please contact your manager. 

Change of purpose 

We will only use your Personal Data for the purposes for which we collected it, unless we reasonably  consider that we need to use it for another reason and that reason is compatible with the original purpose.  

Please note that we may process your Personal Data without your knowledge or consent, in compliance  with the above rules, where this is required or permitted by law. 

SHARING PERSONAL DATA WITH THIRD PARTIES 

We may have to share your data with third parties, including third-party service providers and other entities  in the group. We require third parties to respect the security of your data and to treat it in accordance with  the law. 

We may transfer your Personal Data outside the EU. If we do, you can expect a similar degree of protection  in respect of your Personal Data. 

We will only share your Personal Data with third parties in accordance with the GDPR and as outlined in the  legal justification table above. 

”Third parties” include: 

• Third-party service providers (including contractors and designated agents) and other entities within our group. 
• Other entities in our group structure (if applicable); 

Third parties in the context of a possible sale or restructure. In this situation we will so far as possible share anonymised data with the other parties before the transaction completes. Once the transaction is completed, we will share your Personal Data with the other parties if and to the extent required under the terms of the transaction; and 

We may need to share your Personal Data with a regulator or to otherwise comply with the law. 

If you would like to know exactly which third parties have been given access to your Personal Data by us,  please contact us at wellcalf@smartbell.io

DATA SECURITY 

We have put in place appropriate security measures to prevent your Personal Data from being accidentally  lost, used or accessed in an unauthorised way, altered or disclosed. 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. They will only process your Personal Data on our instructions and they are subject to a duty of  confidentiality. Details of these measures may be obtained from your manager. If any data is shared to  third parties they will only process your Personal Data on our instructions and they are subject to a duty of  confidentiality. 

DATA RETENTION 

We will only retain your Personal Data for as long as necessary to fulfil the purposes we collected it for,  including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the  appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the  Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the  purposes for which we process your Personal Data and whether we can achieve those purposes through  other means, and the applicable legal requirements. 

In some circumstances we may anonymise your Personal Data so that it can no longer be associated with  you, in which case we may use such information without further notice to you. 

RIGHTS OF ACCESS, CORRECTION, ERASURE AND RESTRICTION 

Your duty to inform us of changes 

It is important that the Personal Data we hold about you is accurate and current. Please keep us informed if  your Personal Data changes during your working relationship with us. 

Your rights in connection with Personal Data 

Under certain circumstances, by law you have the right to: 

Request access to your Personal Data (commonly known as a “data subject access request”). This enables you to receive a copy of the Personal Data we hold about you and to check that we are  lawfully processing it.

Request correction of the Personal Data that we hold about you. This enables you to have any  incomplete or inaccurate information we hold about you corrected. 

Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal  Data where there is no good reason for us continuing to process it. You also have the right to ask us  to delete or remove your Personal Data where you have exercised your right to object to processing  (see below). 

Object to processing of your Personal Data where we are relying on a legitimate interest (or those  of a third party) and there is something about your particular situation which makes you want to  object to processing on this ground. You also have the right to object where we are processing your  Personal Data for direct marketing purposes. 

Request the restriction of processing of your Personal Data. This enables you to ask us to suspend  the processing of Personal Data about you, for example if you want us to establish its accuracy or the  reason for processing it. 

Request the transfer of your Personal Data to another party. 

If you want to review, verify, correct or request erasure of your Personal Data, object to the processing of  your Personal Data, or request that we transfer a copy of your Personal Data to another party, please  contact us via welcalf@smartbell.io

What we may need from you 

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security  measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. 

RIGHT TO WITHDRAW CONSENT 

In the limited circumstances where you may have provided your consent to the collection, processing and  transfer of your Personal Data for a specific purpose, you have the right to withdraw your consent for that  specific processing at any time. To withdraw your consent, please contact us at wellcalf@smartbell.io. Once we have  received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law. 

CHANGES TO THIS PRIVACY NOTICE 

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy  notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your Personal Data.

IF YOU HAVE ANY QUESTIONS ABOUT THIS PRIVACY NOTICE, PLEASE CONTACT US VIA WELLCALF@SMARTBELL.IO

Privacy Policy
Last Updated On 16-Sep-2025
Effective Date 16-Sep-2025

This Privacy Policy describes the policies of Cambridge Animal Technologies Limited, 47-51 Norfolk Street, Cambridgeshire CB1 2LD, United Kingdom of Great Britain and Northern Ireland (the), email: wellcalf@smartbell.io, phone: 07743674531 on the collection, use and disclosure of your information that we collect when you use our website ( https://wellcalf.com/ the “Service” of this website.

By accessing or using the Service, you are consenting to the collection, use and disclosure of your information in accordance with this Privacy Policy. If you do not consent to the same, please do not access or use the Service.

We may modify this Privacy Policy at any time without any prior notice to you and will post the revised Privacy Policy on the Service. The revised Policy will be effective 180 days from when the revised Policy is posted in the Service and your continued access or use of the Service after such time will constitute your acceptance of the revised Privacy Policy. We therefore recommend that you periodically review this page.

Information We Collect:

We will collect and process the following personal information about you:

• Name
• Email
• Mobile
• Work Address

How We Use Your Information:

We will use the information that we collect about you for the following purposes:

• Marketing/ Promotional
• Testimonials
• Customer feedback collection
• Support
• Administration info
• Targeted advertising
• Managing customer order

If we want to use your information for any other purpose, we will ask you for consent and will use your information only on receiving your consent and then, only for the purpose(s) for which grant consent unless we are required to do otherwise by law.

Retention Of Your Information:
We may retain your personal information with us after users terminate their account, for as long as we need it to fulfill the purposes for which it was collected as detailed in this Privacy Policy. We may need to retain certain information for longer periods such as record-keeping / reporting in accordance with applicable law or for other legitimate reasons like enforcement of legal rights, fraud prevention, etc. Residual anonymous information and aggregate information, neither of which identifies you (directly or indirectly), may be stored indefinitely. To request to have your data removed from our system, you can write to us at wellcalf@smartbell.io. 

Your Rights:
Depending on the law that applies, you may have a right to access and rectify or erase your personal data or receive a copy of your personal data, restrict or object to the active processing of your data, ask us to share (port) your personal information to another entity, withdraw any consent you provided to us to process your data, a right to lodge a complaint with a statutory authority and such other rights as may be relevant under applicable laws. To exercise these rights, you can write to us at wellcalf@smartbell.io. We will respond to your request in accordance with applicable law.

You may opt-out of direct marketing communications or the profiling we carry out for marketing purposes by unsubscribing – whereby we will remove you from our  mailing list but retain your details in our system – or writing to us at wellcalf@smartbell.io and requesting that we delete your records.

Do note that if you do not allow us to collect or process the required personal information or withdraw the consent to process the same for the required purposes, you may not be able to access or use the services for which your information was sought.

Security:
The security of your information is important to us and we will use reasonable security measures to prevent the loss, misuse or unauthorized alteration of your information under our control. However, given the inherent risks, we cannot guarantee absolute security and consequently, we cannot ensure or warrant the security of any information you transmit to us and you do so at your own risk.

Third Party Links & Use Of Your Information:
Our Service may contain links to other websites that are not operated by us. This Privacy Policy does not address the privacy policy and other practices of any third parties, including any third party operating any website or service that may be accessible via a link on the Service. We strongly advise you to review the privacy policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Grievance / Data Protection Officer:
If you have any queries or concerns about the processing of your information that is available with us, you may email our Grievance Officer at Cambridge Animal Technologies Limited, 47-51 Norfolk Street, email: wellcalf@smartbell.io.

We will address your concerns in accordance with applicable law.