Privacy Notice - LTx Platform

SPACE AYE PRIVACY POLICY (LTx PLATFORM)

This privacy policy sets out how Space Aye Limited uses and protects your personal data in connection with your use of our LTx Platform (Platform) and any products and services which are accessible through the Platform.

1. IMPORTANT INFORMATION AND WHO WE ARE

Who we are

SPACE AYE LIMITED is a company incorporated and registered in Scotland with company number SC422229 and having its registered office at 8th Floor, 80 St Vincent Street, Glasgow G2 5UB, Scotland, United Kingdom (referred to as “Space Aye”, "we", "us" or "our" in this privacy policy).

This privacy policy gives you information about how Space Aye collects and uses your personal data through your use of the Platform, including any data you may provide when you register with us and purchase any Services.

This Platform is not intended for children and we do not knowingly collect data relating to children.

Controller

Space Aye is the controller and responsible for your personal data.

Data Protection Officer

We are not required to appoint a data protection officer (DPO). If you have any questions about this privacy policy, including any requests to exercise your legal rights (paragraph 9), please contact us using the information set out in the contact details sections (paragraph 10).

EU Data Protection Representative

We have a data protection representative in the European Economic Area (Prighter EU Rep GmbH, Schellinggasse 3/10, 1010 Vienna, Austria) in respect of EU GDPR which can be contacted at: https://gdpr-rep.eu/q/17948166872

1. The types of personal data we collect about you

Personal data means any information about an individual from which that person can be identified.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data includes first name, last name, any previous names, username or similar identifier, title, date of birth, place of birth and citizenship and nationality details.
Contact Data includes billing address, email address and telephone numbers.
Transaction Data includes details about payments from you and other details of products and services you have purchased from us.
Technical Data includes GPS and other sensor data from your device, location data, internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access the Platform and use the products and services.
Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
Usage Data includes information about how you interact with and use the Platform, products and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

Sanctions and Restricted Party Lists Data includes information such as name, date of birth, place of birth, occupation, nationality, address and reason why the person is on the list.

The types of location data collected by us and how long we store it will depend on your device and account settings.

We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific feature of the Platform in order to analyse general trends in how users are interacting with the Platform to help improve the Platform and our service offering.

In certain, circumstances we may process the personal data of other persons connected to you, such as your dependents and family members. The personal data regarding third parties that you provide to us will be processed for compliance purposes to establish and meet regulatory requirements and identify any conflicts of interest. Before you provide data relating to third parties to us, you should ensure that you are permitted to do so and provide them with the information contained in this privacy policy.

3. How is your personal data collected

We use different methods to collect data from and about you including through:

Your interactions with us. You may give us your personal data by filling in online forms or by corresponding with us by phone, email or otherwise. This includes personal data you provide when you:
- apply for our products or services;
- create an account on our Platform;
- subscribe to or pay for products and services available through the Platform;
- request marketing to be sent to you;
- enter a survey; or
- give us feedback or contact us.

Automated technologies or interactions. As you interact with the Platform, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using Google Analytics and other similar technologies. Please see our cookie policy for further details.
Third parties or publicly available sources. We will receive personal data about you (including Sanctions and Restricted Party Lists Data) from various third parties and public sources as set out below:
- UK Companies House
- lists published by the US Departments of Commerce, State and Treasury (including the Consolidated Screening List) in respect of restricted parties, sanctions and export controls
- lists published by the European Union and/or the UK Government in respect of restricted parties, sanctions and export controls
- OpenSanctions Datenbanken GmbH
Technical Data is collected from the following parties:
- analytics providers such as Google based outside the UK
Transaction Data is collected from providers of technical, payment and delivery services such as Xero (our third party payment processor).

Information

Any payments made will be processed by third party payment processors. Space Aye does not directly collect or store payment card information.

4. How we use your personal data

Legal basis

The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

Performance of a contract with you: Where we need to peform the contract we are about to enter into or have entered into with you.
Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to (such as carrying out due diligence on officers, employees, shareholders and/or users of the products and services provided by us through the Platform). This may involve checking against restricted party lists published by the US Departments of Commerce, State and Treasury.
Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use the various categories of your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Purpose/Use	Type of Data	Legal basis [and retention period]

Direct marketing

During the registration process on the Platform when your personal data is collected, you will be asked to indicate your preferences for receiving direct marketing communications from Space Aye.

We may also analyse your Identity, Contact, Technical, Usage and Profile Data to form a view which products, services and offers may be of interest to you so that we can then send you relevant marketing communications.

Third-party marketing

We will get your express consent before we share your personal data with any third party for their own direct marketing purposes.

Opting out of marketing

You can ask to stop sending you marketing communications at any time by following the opt-out links within any marketing communication sent to you or by contacting us (see paragraph 10).

If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes (for example relating to order confirmations, updates to our Terms and Conditions and checking that your contact details are correct).

AI search tools

We use AI-powered search and analysis tools (“Agentic AI Services”) to help you locate and retrieve information about the availability of satellite imagery. These Agentic AI Services enable faster and more accurate access to data that we hold in our internal systems.

What personal data is processed?: When using Agentic AI Services, only personal data that exists within our internal systems may be processed. Other than checking the availability of satellite imagery from satellite operators, the AI tools do not access external sources or public data and do not conduct searches across the Internet.

Purpose of processing: We use Agentic AI Services to support you in locating relevant information quickly. These are only used as a support function and do not make solely automated decisions.

Our role: We act as the data controller for all personal data processed through the Agentic AI Services. The provider of the tools for the Agentic AI Services (being Microsoft) acts as our data processor.

Lawful basis: Our lawful basis is legitimate interests (to develop our products and services, and to enhance the user experience).

Transfer of data: The only data being transferred as part of the Agentic AI Services is the location for which the user wishes to obtain satellite imagery. We do not consider this to be personal data as no individual could be identified from this. Other than the foregoing, no other data processed as part of the Agentic AI Services will be transferred outside of the UK or the European Economic Area.

Storage: Personal data remains stored in our internal systems according to our retention policy. Microsoft may retain limited technical logs.

For more information about the cookies we use and how to change your cookie preferences, please see Cookie Policy.

5. DISCLOSURES OF YOUR PERSONAL DATA

We may share your personal data where necessary with the parties set out below for the purposes set out in the table above.

External Third Parties:
- Service providers acting as processors who provide data centre services, system administration services, IT services, hosting communications, marketing and sales services, IT systems maintenance, analytics and payment processing including, without limitation, the following:

Name	Service
Zendesk	Customer service solution
Google Analytics	Measuring and analytics
Mailchimp/Mandrill	Marketing and email communications
Microsoft Azure	Cloud computing platform (including databases and storage), AI tools

Service providers acting as controllers:

Name	Service	Privacy Policy (if applicable)
Satellite operators	Provide satellite imagery	various
UK Companies House	Provides company details	https://www.gov.uk/government/organisations/companies-house/about/personal-information-charter#searchers-of-the-public-register
OpenSanctions Datenbanken GmbH	Customer due diligence	https://www.opensanctions.org/docs/privacy/

Professional advisors acting as processors or joint controllers or controllers in common including lawyers, bankers, auditors, insurers and accountants providing legal, banking, consultancy, insurance and accounting services
HM Revenue & Customers, regulators and other authorities acting as processors or joint controllers or controllers in common who require reporting of processing activities in certain circumstances
Law enforcement agencies (if they ask for it)
Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. INTERNATIONAL TRANSFERS

We may transfer your personal data to service providers that carry out certain functions on our behalf. This may involve transferring personal data outside the UK to countries which have laws that do not provide the same level of data protection as the UK law.

Whenever we transfer your personal data out of the UK to service providers, we ensure a similar degree of protection is afforded to it by ensuring that the following safeguards are in place:

We will only transfer your personal data to countries that have been deemed by the UK to provide an adequate level of protection for personal data; or
We may use specific standard contractual terms approved for use in the UK which give the transferred personal data the same protection as it has in the UK, namely the International Data Transfer Agreement or The International Data Transfer Addendum to the European Commission’s standard contractual clauses for international data transfers. To obtain a copy of these contractual safeguards, please contact us (see paragraph 10).

In the case of the United States, we will be able to transfer personal data to certified US entities pursuant to the UK-US Data Bridge (established under section 17A of the UK Data Protection Act 2018) without requiring additional safeguards.

In the case of Google Analytics, we also refer you to How Google uses information from sites or apps that use our services – Privacy & Terms – Google and Safeguarding your data - Analytics Help in respect of how Google Analytics collects and processes personal data.

7. 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.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. DATA RETENTION
HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our customers (including Contact, Identity and Transaction Data) for six years after they cease being customers.

In some circumstances you can ask us to delete your data: see paragraph 9 below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9. YOUR LEGAL RIGHTS

You have a number of rights under data protection laws in relation to your personal data.

You have the right to:

Request access to your personal data (commonly known as a "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 data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data in certain circumstances. 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 successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes (see opting out of marketing in paragraph 4 for details of how to object to receiving direct marketing communications).
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data (see the table in section 4 for details of when we rely on your consent as the legal basis for using your data). However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:

If you want us to establish the data's accuracy;
Where our use of the data is unlawful but you do not want us to erase it;
Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

If you wish to exercise any of the rights set out above, please contact us (see Contact details (paragraph 10).

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

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 your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. CONTACT DETAILS

If you have any questions about this privacy policy or about the use of your personal data or you want to exercise your privacy rights, please contact us in the following ways:

Email address: privacy@spaceaye.com
Postal address: 8th Floor, 80 St Vincent Street, Glasgow G2 5UB, Scotland, UK

11. COMPLAINTS

You have the right to make a complaint to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). However, before doing so please make sure you have first made your complaint to us or asked us for clarification if there is something you do not understand.

12. CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

We keep our privacy policy under regular review.

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 relationship with us, for example a new address or email address.

13. THIRD-PARTY LINKS

This Platform may include links to third-party plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third parties and are not responsible for their privacy statements. When you leave our Platform, we encourage you to read the privacy policy of every third party.

Last Updated: March 2026