This Privacy Policy describes how USB International Limited ("we", "us", or "our") collects, uses, and discloses your Personal Information when you visit or make a purchase from our website.

We are committed to protecting your privacy and handling your data in an open and transparent manner in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. The data controller for this website is USB International Limited.

1. How We Collect and Use Your Personal Information

To provide our products and services, we collect personal information about you from a variety of sources.

Information We Collect Directly from You

When you make a purchase or attempt to make a purchase through the Site, we collect certain information from you, including:

• Contact details: Name, billing address, shipping address, email address, and phone number.

• Financial information: Payment details (including credit card numbers). Note: Payments are processed securely via third-party gateways; we do not store full credit card numbers on our servers.

• Account information: Username and password if you choose to register an account with us.

• Communications: Any messages you send us via email, social media, contact forms, or customer support channels.

Information We Collect Automatically

When you visit the Site, we automatically collect certain information about your device and interaction with the Site using cookies, log files, web beacons, and pixels. This includes:

• Device Data: Version of web browser, IP address, time zone, and cookie identifier information.

• Usage Data: Specific products or legal pages you view, search terms, and how you interact with the Site's checkout flow.

2. Why We Process Your Data (Lawful Basis)

Under the UK GDPR, we must have a valid legal basis to process your personal data. We rely on the following bases:

• Contract: To fulfill our contract with you (e.g., processing your payment, arranging shipping, and providing order and shipping confirmations).

• Consent: When you explicitly opt-in to receive email/SMS marketing communications or consent to non-essential cookies. You can withdraw this consent at any time.

• Legitimate Interests: For our legitimate business interests, such as preventing fraudulent transactions, improving our website interface, and optimizing our performance marketing.

• Legal Obligation: To comply with UK tax, customs, accounting, and consumer protection laws.

3. Sharing Your Personal Information

We share your Personal Information with trusted service providers to help us provide our services and fulfill our contracts with you:

• Shopify: Our store is hosted on Shopify. You can read more about how Shopify uses your Personal Information here: Shopify Privacy Policy.

• Payment Processors: Such as Shop Pay, PayPal, or Stripe, to securely handle transactional data.

• Shipping & Fulfillment Partners: Third-party couriers and logistics providers to deliver your Aqua Spirit orders.

• Marketing & Analytics Providers: We share specific data with partners like Google and Meta (Facebook) to measure website performance and deliver relevant advertising (see Section 4).

• Legal Compliance: We may share information to comply with applicable laws and regulations, to respond to a subpoena, search warrant, or other lawful requests, or to protect our legal rights.

4. Behavioural Advertising (Meta & Google)

We use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you.

• Google Analytics & Google Ads: We use Google to help us understand how our customers use the Site and to serve ads across Google's network. You can read how Google uses your data here.

• Meta (Facebook/Instagram) Pixel: We use Meta's tracking infrastructure to measure sales, optimize lookalike audiences, and show relevant Aqua Spirit advertisements on Meta platforms.

How to Opt-Out of Targeted Advertising:

You can opt out of targeted advertising at any time by visiting the following links:

• Meta (Facebook): https://www.facebook.com/settings/?tab=ads

• Google: https://www.google.com/settings/ads/anonymous

• General Opt-Out: You can also opt out of many third-party advertising networks via the Digital Advertising Alliance's portal at: http://optout.aboutads.info/.

5. Data Retention

When you place an order through the Site, we will retain your Personal Information for our records unless and until you ask us to erase this information. We retain basic customer and transactional data for a standard period of 6 years to satisfy statutory UK corporate tax and accounting compliance.

6. Your Rights Under UK GDPR

If you are a resident of the United Kingdom, you have specific statutory rights regarding the Personal Information we hold about you. You have the right to:

• Access: Request a copy of the personal data we hold about you.

• Correction: Request that we correct inaccurate or incomplete data.

• Erasure: Request that we delete your data (the "right to be forgotten"), subject to specific legal exceptions.

• Restriction: Request that we restrict the processing of your data under certain conditions.

• Objection: Object to processing based on legitimate interests or direct marketing campaigns.

If you would like to exercise any of these rights, please contact our support team using the information in Section 10.

7. Cookies

A cookie is a small piece of data that is downloaded to your computer or device when you visit our Site. We use a range of functional, performance, and advertising cookies to make your browsing experience smoother (by remembering cart contents and preferences) and to track advertising ROI.

When you first visit our site, you will be prompted to accept or decline non-essential cookies via our cookie consent banner. You can also control and manage cookies in your local browser settings.

8. International Data Transfers

Your Personal Information will be initially processed in the UK and Ireland and then transferred outside of Europe for storage and further processing, including to Canada and the United States (by our platform provider, Shopify, and advertising networks like Google/Meta). We ensure that any such transfers comply with UK GDPR by relying on adequacy decisions or implementing Standard Contractual Clauses (SCCs).

9. Changes to this Policy

We may update this Privacy Policy from time to time in order to reflect, for example, changes to our data collection practices or for other operational, legal, or regulatory reasons.

10. Contact Us

For more information about our privacy practices, if you have questions, or if you would like to exercise your data rights, please contact us by email at support@aquaspiritisup.com

USB International Limited

Unit 5, Russel House Hornsby Way,

Southfields Business Park,

Basildon, England,

SS15 6TF

United Kingdom

If you are not satisfied with our response to a data request, you have the right to lodge a complaint with the relevant data protection authority. In the UK, this is the Information Commissioner's Office (ICO): https://ico.org.uk/.