Asora Privacy Notice

Introduction

We at Asora and our Affiliates are committed to protecting your privacy. This Privacy Notice applies to the information and data collected by Asora when you interact with us on our Website or through other channels (for example, by communicating with us or attending one of our events), and when you use our products and services. This Privacy Notice describes how we collect, receive, use, store, share, transfer, and process your personal data. It also describes your choices and rights with respect to your personal data, including your rights of access and correction. If you do not agree with this Privacy Notice, you should not use our Website or the Subscription Service.

Customers may collect and manage personal data when using the Subscription Service. Asora processes such data as a processor under the direction of our customers. Our customers, as controllers, are responsible for complying with regulations that require providing notice, disclosure, and/or consent prior to collecting their customers’ personal data using the Subscription Service. Please see the below Privacy Notice and our Customer Data Processing Agreement for more information.

We update this Privacy Notice from time to time and encourage you to review it periodically. We will post any changes on this page and, if material, will provide a more prominent notice via email or your Asora account. Terms not otherwise defined here will have the meaning set forth in the Master Terms.

If you have any questions about this Privacy Notice or our treatment of your personal data, please reach out via the Contact Us section below.

Who Does This Notice Apply To

The Website is intended for people who wish to learn about, purchase, and use our products and services. We provide businesses with tools and solutions to help them manage their financial assets (the “Service”).

This Website and the Service are not intended for children. We do not knowingly collect any personal data relating to children.

This Privacy Notice applies when you access, browse, and use our Website, create an account, subscribe to our Service, join our mailing lists, or interact with us via social media, email, or phone.

What Information We Collect About You

“Personal data” means information about an individual that can identify them. It does not include anonymous data. “Processing” refers to all activities involving personal data, including collecting, storing, and sharing it.

The data we collect depends on your interactions with us and whether your data is processed as part of our Service. We may process:

• Identity and Contact Data: name, email address, and any personal data provided when contacting us or ordering online.
• Profile Data: account details, preferences, subscriptions, feedback, and survey responses.
• Transaction Data: payment-related details (excluding payment card or bank information handled by secure providers).
• Technical Data: IP address, browser type/version, time zone, device information, and similar data.
• Usage Data: Website interaction, services viewed, page performance, and activity metrics.
• Marketing and Communications Data: preferences for newsletters and marketing messages.
• Voice Data: recordings or transcripts of phone calls.
• Customer Testimonial Data: name, business, title, and testimonial information.

We also collect aggregated, non-identifiable data for analytics. We do not collect special categories of personal data. Where required by law or contract, failure to provide personal data may affect your ability to use certain services.

How Your Personal Data is Received

We may receive your personal data through:

• Direct interactions: creating or managing your account, filling forms, contacting us, entering promotions, or providing feedback.
• Automated technologies: cookies, tracking codes, and logs. See our Cookie Policy for details.
• Third parties: such as Google Analytics (for usage data) and payment providers like GoCardless and Stripe.

Information We Process on Behalf of Customers

Our Subscription Service allows customers to collect and share financial information. Customers may collect personal data such as names, emails, addresses, or financial details. We act as a processor under our customers’ instructions and in compliance with our Customer Terms of Service. Customers are responsible for correcting, deleting, or updating this data and ensuring compliance with data protection laws.

How We Use Your Information

We have set out below a description of the ways we typically process your personal data and the legal reasons we rely on to do so.

Purpose / Activity	Type of Data	Grounds for Processing
To allow you to create and manage a user account on our Website; to subscribe to our Services; to facilitate your payments for our Services; to receive and manage your feedback and survey responses; to receive and manage referrals; and to conduct profiling based on the preferences you choose in your user account to ensure you receive relevant content.	Identity and Contact Data Profile Data Transaction Data	Necessary for the performance of a contract with you or in order to take steps at your request prior to entering into a contract. Necessary for our legitimate interests of enabling users to create and develop personalised accounts; to request and manage subscriptions; and for running and managing our Services.
To fulfil your subscription for our Services; to send you confirmations and updates relating to your orders; to manage cancellations in accordance with our Customer Terms of Service and other policies.	Identity and Contact Data Profile Data Transaction Data	Necessary for the performance of a contract with you. Necessary to comply with a legal obligation. Necessary for our legitimate interests of providing a good purchase and subscription experience.
To respond to queries submitted through the Website, telephone, social media or other means and to manage our relationship with you including: (i) notifying you of changes to our Services, policies, or terms; (ii) operating feedback and survey facilities; (iii) managing complaints and disputes; (iv) administering communication preferences; and (v) allowing you to exercise your data protection rights.	Identity and Contact Data Profile Data Transaction Data Technical Data Usage Data Marketing and Communications Data	Necessary for the performance of a contract with you or in order to take steps at your request prior to entering into a contract. Necessary to comply with a legal obligation. Necessary for our legitimate interests: responding to queries; managing customer relationships; developing business; handling disputes; protecting our interests; and measuring satisfaction.
To administer and protect our business, products, services, systems, and Website including implementing and monitoring security measures, access controls, troubleshooting, data analysis, testing, maintenance, user support, reporting, and hosting of data; to anonymise personal data for statistical purposes.	Identity and Contact Data Profile Data Transaction Data Technical Data Usage Data Marketing and Communications Data	Necessary for the performance of a contract with you. Necessary to comply with a legal obligation. Necessary for our legitimate interests in ensuring network and systems security; preventing unlawful activity; managing disputes; and enhancing services through statistical analysis.
To use data analytics and other technologies to monitor usage of the Website; measure its performance; optimise design and improve services, marketing, and user experience.	Technical Data Usage Data	Necessary for our legitimate interests to gain insights into how our services are used; identify and fix technical issues; improve services; and develop business strategies.
To record phone calls for training and quality purposes.	Voice Data	Your consent
To manage your attendance at Asora events and to contact you about event details.	Identity and Contact Data Marketing and Communications Data	Necessary for the performance of a contract with you. Necessary for our legitimate interests in running and improving events; attracting customers; and developing new business.
If you post comments about Asora, tag us, or post photos to our social media pages, we may process this information to highlight our products, services, and branding or to respond to you.	Identity and Contact Data Profile Data	Necessary for our legitimate interests in developing products and services and gauging customer sentiment.
To post testimonials about our Services on our Website and on social media platforms.	Customer Testimonial Data	Your consent

Marketing: We may send you information about our services, insights, and offers that may be of interest to you. Where we have your consent or a legitimate interest, we may do this by email, post, or telephone. You can unsubscribe at any time using the links in our communications or through your account settings.

Advertising: With your consent, we may use cookies and similar technologies to include ads for our products on other websites or apps, such as social media. See our Cookie Policy for details.

How We Share Information We Collect

We share your personal data only as necessary with:

• Service providers: for analytics, marketing, hosting, payments, or support — all under confidentiality agreements.
• Event partners: to manage attendance and improve events.
• Corporate entities: during mergers or acquisitions.
• Public authorities: when required by law or regulation.

Please note: No mobile data or text messaging opt-ins are shared with third parties for marketing purposes.

How We Transfer Data We Collect Internationally

We may process or transfer your personal data outside the EEA, ensuring compliance with Data Protection Laws through adequacy decisions or standard contractual clauses. Contact us for details.

How We Store and Secure Your Information

Data Storage and Security

We use security technologies and procedures to protect personal data from unauthorised access or disclosure. Data is hosted in secure environments. For details, see www.asora.com/security.

Retention of Personal Data

We retain your personal data as long as needed to fulfil contractual or legal obligations. You may delete your account at any time, though certain data may be retained for legal compliance, dispute resolution, or fraud prevention.

Updating Your Personal Data

Keep your personal data accurate and up to date through your Asora account settings or by contacting us via the Contact Us section below.

Your Legal Rights

You have the right to access, correct, delete, restrict, or object to the processing of your data, and to request data portability or withdraw consent. To exercise these rights, contact us as outlined below.

You can also file complaints with the Data Protection Commission, though we encourage you to contact us first.

Tips, Warnings and Third-Party Links

Our Website may include links to third-party sites and assets. We do not control these and are not responsible for their privacy practices.

We partner with Microsoft Clarity and Microsoft Advertising to capture behavioral metrics, heatmaps, and session replays to improve our services. Data is collected using cookies and tracking technologies. For more details, visit the Microsoft Privacy Statement.

When you leave our Website, we encourage you to read the privacy notices of every website you visit. Please see our Cookie Policy for details about cookies served by us and third parties.

Contact Us

If you have any questions about this Privacy Notice or our privacy practices, or need it in an alternative format, contact us at:

Email: dataprivacy@asora.com
Mail:
FAO Data Protection Officer
Asora Technologies Ltd
20 Hatch Street Lower
Dublin 2
Ireland