Privacy Policy

Last updated August 17, 2025

This Privacy Notice for Badfish Labs LTD ('we', 'us', or 'our'), describes how and why we might access, collect, store, use, and/or share ('process') your personal information when you use our services ('Services'), including when you:

Visit our website at https://www.badfishlabs.com or any website of ours that links to this Privacy Notice

Use Design Agency. Badfish Labs builds brands, websites, and design systems that actually work. We cut through agency fluff and deliver sharp, rebellious design built for startups, founders, and misfits who want results not pixel polishing.

Engage with us in other related ways, including any sales, marketing, or events

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at contact@badfishlabs.com.

SUMMARY OF KEY POINTS

This summary provides key points from our Privacy Notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use. Learn more about personal information you disclose to us.

Do we process any sensitive personal information? Some of the information may be considered 'special' or 'sensitive' in certain jurisdictions, for example your racial or ethnic origins, sexual orientation, and religious beliefs. We do not process sensitive personal information.

Do we collect any information from third parties? We do not collect any information from third parties.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Learn more about how we process your information.

In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties. Learn more about when and with whom we share your personal information.

How do we keep your information safe? We have adequate organisational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Learn more about how we keep your information safe.

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Learn more about your privacy rights.

How do you exercise your rights? The easiest way to exercise your rights is by submitting a data subject access request, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.

Want to learn more about what we do with any information we collect? Review the Privacy Notice in full.

TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT?

2. HOW DO WE PROCESS YOUR INFORMATION?

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

6. HOW LONG DO WE KEEP YOUR INFORMATION?

7. HOW DO WE KEEP YOUR INFORMATION SAFE?

8. DO WE COLLECT INFORMATION FROM MINORS?

9. WHAT ARE YOUR PRIVACY RIGHTS?

10. CONTROLS FOR DO-NOT-TRACK FEATURES

11. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

12. DO WE MAKE UPDATES TO THIS NOTICE?

13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

• names

• phone numbers

• email addresses

• job titles

• mailing addresses

Sensitive Information. We do not process sensitive information.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies.

The information we collect includes:

Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called 'crash dumps'), and hardware settings).

Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.

Location Data. We collect location data such as information about your device's location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Services.

Behavioural Analytics Data. We partner with Microsoft Clarity to capture how you use and interact with our website through behavioural metrics, heatmaps, and session replay to improve and market our products and services. Website usage data is captured using first and third-party cookies and other tracking technologies to determine the popularity of products and services and online activity. Additionally, we use this information for site optimisation, fraud/security purposes, and advertising. Microsoft Clarity does not collect personally identifiable information such as names or email addresses, but it does collect behavioural and technical data — including mouse movements, clicks, scrolls, and navigation patterns — that may constitute personal data under applicable data protection laws when combined with other information. For more information about how Microsoft collects and uses your data, visit the Microsoft Privacy Statement.

Google API

Our use of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We process the personal information for the following purposes listed below. We may also process your information for other purposes only with your prior explicit consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.

• To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.

• To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.

• To fulfil and manage your orders. We may process your information to fulfil and manage your orders, payments, returns, and exchanges made through the Services.

• To enable user-to-user communications. We may process your information if you choose to use any of our offerings that allow for communication with another user.

• To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.

• To analyse user behaviour through session recordings and heatmaps. We use Microsoft Clarity to record and analyse how visitors interact with our website, including mouse movements, clicks, scrolls, and page navigation. This helps us identify usability issues, understand content engagement, and improve the overall user experience. Session recordings are anonymised and do not capture keystrokes or personally identifiable input fields.

• To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual's vital interest, such as to prevent harm.

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e. legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfil our contractual obligations, to protect your rights, or to fulfil our legitimate business interests.

If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

Consent. We may process your information if you have given us permission (i.e. consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. Learn more about withdrawing your consent. In particular, we rely on your consent to use analytics cookies and tracking technologies from Google Analytics and Microsoft Clarity. These tools will not be activated until you have provided explicit consent through our Cookie Consent Manager.

Performance of a Contract. We may process your personal information when we believe it is necessary to fulfil our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.

Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:

• Analyse how our Services are used so we can improve them to engage and retain users

Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.

Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

In legal terms, we are generally the 'data controller' under European data protection laws of the personal information described in this Privacy Notice, since we determine the means and/or purposes of the data processing we perform. This Privacy Notice does not apply to the personal information we process as a 'data processor' on behalf of our customers. In those situations, the customer that we provide services to and with whom we have entered into a data processing agreement is the 'data controller' responsible for your personal information, and we merely process your information on their behalf in accordance with your instructions. If you want to know more about our customers' privacy practices, you should read their privacy policies and direct any questions you have to them.

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission (i.e. express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e. implied consent). You can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

• If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way

• For investigations and fraud detection and prevention

• For business transactions provided certain conditions are met

• If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim

• For identifying injured, ill, or deceased persons and communicating with next of kin

• If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse

• If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province

• If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records

• If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced

• If the collection is solely for journalistic, artistic, or literary purposes

• If the information is publicly available and is specified by the regulations

We may disclose de-identified information for approved research or statistics projects, subject to ethics oversight and confidentiality commitments

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations described in this section and/or with the following third parties.

We may need to share your personal information in the following situations:

Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

Analytics Providers. We share information with the following third-party analytics providers to help us understand how our Services are used:

• Google Analytics (operated by Google LLC / Google Ireland Limited) — We share browsing and usage data to analyse website traffic and usage patterns. Google Analytics uses cookies to collect information about your interactions with our Services. Google may also use this data for its own purposes. For more information, see the Google Privacy & Terms page. You can opt out of Google Analytics by installing the Google Analytics Opt-out Browser Add-on.

• Microsoft Clarity (operated by Microsoft Corporation / Microsoft Ireland Operations Ltd.) — We share behavioural and interaction data including mouse movements, clicks, scrolls, and page navigation to generate heatmaps and session recordings. Microsoft may use this data for site optimisation and advertising purposes. Microsoft Clarity data is processed and stored in the United States under the EU–US Data Privacy Framework. For more information, see the Microsoft Privacy Statement. You can opt out of Microsoft's use of your data by visiting Microsoft's opt-out page.

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to gather information when you interact with our Services. Some online tracking technologies help us maintain the security of our Services, prevent crashes, fix bugs, save your preferences, and assist with basic site functions.

We also permit third parties and service providers to use online tracking technologies on our Services for analytics and advertising, including to help manage and display advertisements, to tailor advertisements to your interests, or to send abandoned shopping cart reminders (depending on your communication preferences). The third parties and service providers use their technology to provide advertising about products and services tailored to your interests which may appear either on our Services or on other websites.

To the extent these online tracking technologies are deemed to be a 'sale'/'sharing' (which includes targeted advertising, as defined under the applicable laws) under applicable US state laws, you can opt out of these online tracking technologies by submitting a request as described below under section 'DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?'

Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice.

Consent for Analytics Cookies (EEA, UK, and Switzerland)

If you are located in the European Economic Area (EEA), United Kingdom (UK), or Switzerland, we are required to obtain your explicit consent before setting any non-essential cookies, including analytics cookies from Google Analytics and Microsoft Clarity. These tools will not activate or set cookies until you provide consent through our Cookie Consent Manager. If you decline consent, these analytics tools will either not function or will operate in a limited mode without setting cookies on your device. You may withdraw your consent at any time via the Cookie Consent Manager, accessible through the cookie settings link on our website.

Google Analytics

We may share your information with Google Analytics to track and analyse the use of the Services. Google Analytics uses cookies (such as _ga and _ga_#) to collect data about website traffic and user interactions. The data collected may include your IP address, browser type, pages visited, time spent on pages, and referral sources. To opt out of being tracked by Google Analytics across the Services, visit https://tools.google.com/dlpage/gaoptout. For more information on the privacy practices of Google, please visit the Google Privacy & Terms page.

Microsoft Clarity

We use Microsoft Clarity, a behavioural analytics tool provided by Microsoft, to understand how users interact with our website. Clarity uses cookies and other tracking technologies to capture data such as mouse movements, clicks, scrolls, and page navigation, which are used to generate heatmaps and session recordings.

Microsoft Clarity collects the following types of data:

• Session-level behavioural data (clicks, scrolls, mouse movements, page navigation)

• Device and browser information (browser type, operating system, screen resolution)

• Approximate location data (based on IP address)

• Referral source and pages visited

• Unique pseudonymous user and session identifiers

Microsoft Clarity uses the following cookies:

Cookie Purpose Duration _clck Stores a unique user ID and preferences for Clarity 1 year _clsk Connects multiple page views into a single session recording 1 day CLID Identifies the first time Clarity saw a user on any Clarity-enabled site 1 year ANONCHK Indicates whether the browser ID (MUID) is synced with Microsoft cookies 10 minutes MR Used to determine whether to refresh the MUID cookie 7 days MUID Microsoft user identifier used across Microsoft services for analytics and advertising 1 year SM Used for synchronising the MUID across Microsoft domains Session

Some of these cookies (such as MUID) may be shared across Microsoft services and may be considered third-party cookies. Microsoft Clarity does not record keystrokes or capture personally identifiable input fields. Sensitive data is masked by default.

Microsoft Clarity data is processed and stored in the United States. For transfers of personal data from the EEA, UK, and Switzerland, Microsoft relies on the EU–US Data Privacy Framework and other appropriate transfer mechanisms. For more information on how Microsoft collects and uses your data, visit the Microsoft Privacy Statement.

You can opt out of Microsoft Clarity telemetry by visiting Microsoft's opt-out page. Microsoft Clarity also supports Global Privacy Control (GPC).

6. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfil the purposes outlined in this Privacy Notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than 2 years.

Microsoft Clarity retains data for between 30 days and 13 months, depending on the data type. After this period, data on Clarity servers (including backups) is deleted and cannot be recovered. Google Analytics retains data in accordance with Google's data retention settings, which we have configured in line with our overall retention policy.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

7. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organisational and technical security measures.

We have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

8. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of age or the equivalent age as specified by law in your jurisdiction.

We do not knowingly collect, solicit data from, or market to children under 18 years of age or the equivalent age as specified by law in your jurisdiction, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18 or the equivalent age as specified by law in your jurisdiction or that you are the parent or guardian of such a minor and consent to such minor dependent's use of the Services. If we learn that personal information from users less than 18 years of age or the equivalent age as specified by law in your jurisdiction has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18 or the equivalent age as specified by law in your jurisdiction, please contact us at contact@badfishlabs.com.

Microsoft Clarity should not be used on websites or applications targeting users under the age of 18.

9. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: Depending on your state of residence in the US or in some regions, such as the European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time, depending on your country, province, or state of residence.

In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. If a decision that produces legal or similarly significant effects is made solely by automated means, we will inform you, explain the main factors, and offer a simple way to request human review. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section 'HOW CAN YOU CONTACT US ABOUT THIS NOTICE?' below.

We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.

If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section 'HOW CAN YOU CONTACT US ABOUT THIS NOTICE?' below. You may also withdraw your consent for analytics cookies (including Google Analytics and Microsoft Clarity) at any time through our Cookie Consent Manager or by adjusting your browser settings.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. You may also opt out of specific analytics tracking:

• Google Analytics: Install the Google Analytics Opt-out Browser Add-on

• Microsoft Clarity: Visit Microsoft's opt-out page or enable Global Privacy Control (GPC) in your browser

If you have questions or comments about your privacy rights, you may email us at contact@badfishlabs.com.

10. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ('DNT') feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognising and implementing DNT signals has been finalised. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice.

California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognising or honouring DNT signals, we do not respond to them at this time.

Microsoft Clarity supports Global Privacy Control (GPC). If your browser sends a GPC signal, Clarity will respect this signal and restrict data collection accordingly.

11. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. More information is provided below.

Categories of Personal Information We Collect

The table below shows the categories of personal information we have collected in the past twelve (12) months. The table includes illustrative examples of each category and does not reflect the personal information we collect from you. For a comprehensive inventory of all personal information we process, please refer to the section 'WHAT INFORMATION DO WE COLLECT?'

Category Examples Collected A. Identifiers Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name NO B. Personal information as defined in the California Customer Records statute Name, contact information, education, employment, employment history, and financial information NO C. Protected classification characteristics under state or federal law Gender, age, date of birth, race and ethnicity, national origin, marital status, and other demographic data NO D. Commercial information Transaction information, purchase history, financial details, and payment information NO E. Biometric information Fingerprints and voiceprints NO F. Internet or other similar network activity Browsing history, search history, online behaviour, interest data, and interactions with our and other websites, applications, systems, and advertisements. This includes data collected via Google Analytics (page views, session duration, traffic sources) and Microsoft Clarity (mouse movements, clicks, scrolls, heatmaps, and session recordings). YES G. Geolocation data Device location (including approximate location derived from IP address by Google Analytics and Microsoft Clarity) YES H. Audio, electronic, sensory, or similar information Images and audio, video or call recordings created in connection with our business activities NO I. Professional or employment-related information Business contact details in order to provide you our Services at a business level or job title, work history, and professional qualifications if you apply for a job with us NO J. Education Information Student records and directory information NO K. Inferences drawn from collected personal information Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual's preferences and characteristics NO L. Sensitive personal Information NO

We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:

• Receiving help through our customer support channels;

• Participation in customer surveys or contests; and

• Facilitation in the delivery of our Services and to respond to your inquiries.

We will use and retain the collected personal information as needed to provide the Services or for:

• Category F - 1 year

• Category G - 1 year

Sources of Personal Information

Learn more about the sources of personal information we collect in 'WHAT INFORMATION DO WE COLLECT?'

How We Use and Share Personal Information

Learn more about how we use your personal information in the section, 'HOW DO WE PROCESS YOUR INFORMATION?'

Will your information be shared with anyone else?

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Learn more about how we disclose personal information to in the section, 'WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?'

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be 'selling' of your personal information.

We have not disclosed, sold, or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. We will not sell or share personal information in the future belonging to website visitors, users, and other consumers.

Your Rights

You have rights under certain US state data protection laws. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights include:

• Right to know whether or not we are processing your personal data

• Right to access your personal data

• Right to correct inaccuracies in your personal data

• Right to request the deletion of your personal data

• Right to obtain a copy of the personal data you previously shared with us

• Right to non-discrimination for exercising your rights

• Right to opt out of the processing of your personal data if it is used for targeted advertising (or sharing as defined under California's privacy law), the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ('profiling')

Depending upon the state where you live, you may also have the following rights:

• Right to access the categories of personal data being processed (as permitted by applicable law, including the privacy law in Minnesota)

• Right to obtain a list of the categories of third parties to which we have disclosed personal data (as permitted by applicable law, including the privacy law in California, Delaware, and Maryland)

• Right to obtain a list of specific third parties to which we have disclosed personal data (as permitted by applicable law, including the privacy law in Minnesota and Oregon)

• Right to review, understand, question, and correct how personal data has been profiled (as permitted by applicable law, including the privacy law in Minnesota)

• Right to limit use and disclosure of sensitive personal data (as permitted by applicable law, including the privacy law in California)

• Right to opt out of the collection of sensitive data and personal data collected through the operation of a voice or facial recognition feature (as permitted by applicable law, including the privacy law in Florida)

How to Exercise Your Rights

To exercise these rights, you can contact us by submitting a data subject access request, by emailing us at contact@badfishlabs.com, or by referring to the contact details at the bottom of this document.

Under certain US state data protection laws, you can designate an authorised agent to make a request on your behalf. We may deny a request from an authorised agent that does not submit proof that they have been validly authorised to act on your behalf in accordance with applicable laws.

Request Verification

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes.

If you submit the request through an authorised agent, we may need to collect additional information to verify your identity before processing your request and the agent will need to provide a written and signed permission from you to submit such request on your behalf.

Appeals

Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at contact@badfishlabs.com. We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may submit a complaint to your state attorney general.

California 'Shine The Light' Law

California Civil Code Section 1798.83, also known as the 'Shine The Light' law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us by using the contact details provided in the section 'HOW CAN YOU CONTACT US ABOUT THIS NOTICE?'

12. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated 'Revised' date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.

13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may email us at contact@badfishlabs.com or contact us by post at:

Badfish Labs LTD 47 Cavell Walk, Stevenage, Hertfordshire, SG2 0QD

If you are a resident in the United Kingdom, we are the 'data controller' of your personal information. We have appointed Owen to be our representative in the UK. You can contact them directly regarding our processing of your information, by email at contact@badfishlabs.com, or by post to:

Badfish Labs LTD 47 Cavell Walk, Stevenage, Hertfordshire, SG2 0QD United Kingdom

14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country or state of residence in the US, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. To request to review, update, or delete your personal information, please fill out and submit a data subject access request.

COOKIE POLICY

Last updated August 17, 2025

This Cookie Policy explains how Badfish Labs LTD ("Company," "we," "us," and "our") uses cookies and similar technologies to recognize you when you visit our website at https://www.badfishlabs.com ("Website"). It explains what these technologies are and why we use them, as well as your rights to control our use of them.

In some cases we may use cookies to collect personal information, or that becomes personal information if we combine it with other information.

What are cookies?

Cookies are small data files that are placed on your computer or mobile device when you visit a website. Cookies are widely used by website owners in order to make their websites work, or to work more efficiently, as well as to provide reporting information.

Cookies set by the website owner (in this case, Badfish Labs LTD) are called "first-party cookies." Cookies set by parties other than the website owner are called "third-party cookies." Third-party cookies enable third-party features or functionality to be provided on or through the website (e.g., advertising, interactive content, and analytics). The parties that set these third-party cookies can recognize your computer both when it visits the website in question and also when it visits certain other websites.

Why do we use cookies?

We use first- and third-party cookies for several reasons. Some cookies are required for technical reasons in order for our Website to operate, and we refer to these as "essential" or "strictly necessary" cookies. Other cookies also enable us to track and target the interests of our users to enhance the experience on our Online Properties. Third parties serve cookies through our Website for advertising, analytics, and other purposes. This is described in more detail below.

How can I control cookies?

You have the right to decide whether to accept or reject cookies. You can exercise your cookie rights by setting your preferences in the Cookie Consent Manager. The Cookie Consent Manager allows you to select which categories of cookies you accept or reject. Essential cookies cannot be rejected as they are strictly necessary to provide you with services.

The Cookie Consent Manager can be found in the notification banner and on our Website. If you choose to reject cookies, you may still use our Website though your access to some functionality and areas of our Website may be restricted. You may also set or amend your web browser controls to accept or refuse cookies.

For visitors from the EEA, UK, and Switzerland: In compliance with the GDPR, UK GDPR, and Swiss FADP, non-essential analytics cookies from Google Analytics and Microsoft Clarity will not be set until you provide explicit consent through our Cookie Consent Manager. If you decline consent, these analytics tools will either not function or will operate in a limited capacity. You may withdraw your consent at any time via the persistent "Cookie Settings" link available on our Website.

The specific types of first- and third-party cookies served through our Website and the purposes they perform are described in the tables below (please note that the specific cookies served may vary depending on the specific Online Properties you visit):

Analytics and customisation cookies

These cookies collect information that is used either in aggregate form to help us understand how our Website is being used or how effective our marketing campaigns are, or to help us customize our Website for you.

Google Analytics cookies:

Name Purpose Provider Type Expires in _ga_# Used to distinguish individual users by means of designation of a randomly generated number as client identifier, which allows calculation of visits and sessions .badfishlabs.com http_cookie 1 year 1 month 4 days _ga Records a particular ID used to come up with data about website usage by the user .badfishlabs.com http_cookie 1 year 1 month 4 days

Service: Google Analytics — View Service Privacy Policy

Microsoft Clarity cookies:

Name Purpose Provider Type Expires in _clck Stores a unique Microsoft Clarity user ID and preferences, allowing Clarity to recognise returning visitors and maintain consistent settings .badfishlabs.com http_cookie 1 year _clsk Connects multiple page views by a single user into one Clarity session recording for comprehensive visit analysis .badfishlabs.com http_cookie 1 day CLID Identifies the first time Clarity observed this user on any Clarity-enabled site .clarity.ms http_cookie 1 year ANONCHK Indicates whether the browser ID (MUID) has been transferred to another Microsoft cookie; always set to 0 for Clarity .c.clarity.ms http_cookie 10 minutes MR Used to determine whether to refresh the MUID cookie, used by Microsoft for analytics and advertising .c.bing.com http_cookie 7 days MUID Microsoft user identifier used to identify unique web browsers visiting Microsoft sites; used for advertising, site analytics, and other operational purposes. This is a third-party cookie shared across Microsoft services. .bing.com http_cookie 1 year SM Used for synchronising the MUID across Microsoft domains .c.bing.com http_cookie Session

Service: Microsoft Clarity — View Service Privacy Policy

Important note on Microsoft Clarity third-party cookies: Some cookies set by Microsoft Clarity (such as MUID, MR, ANONCHK, and SM) are third-party cookies originating from Microsoft domains (e.g., bing.com, clarity.ms). These cookies may be used by Microsoft across its services for analytics and advertising purposes. By consenting to analytics cookies, you also consent to the setting of these third-party cookies. You can opt out of Microsoft's broader use of this data by visiting Microsoft's opt-out page.

How can I control cookies on my browser?

As the means by which you can refuse cookies through your web browser controls vary from browser to browser, you should visit your browser's help menu for more information. The following is information about how to manage cookies on the most popular browsers:

• Chrome

• Internet Explorer

• Firefox

• Safari

• Edge

• Opera

In addition, most advertising networks offer you a way to opt out of targeted advertising. If you would like to find out more information, please visit:

• Digital Advertising Alliance

• Digital Advertising Alliance of Canada

• European Interactive Digital Advertising Alliance

Opting out of specific analytics services

• Google Analytics: You can opt out of Google Analytics by installing the Google Analytics Opt-out Browser Add-on.

• Microsoft Clarity: You can opt out of Clarity telemetry by visiting Microsoft's opt-out page. Microsoft Clarity also supports Global Privacy Control (GPC) — if your browser sends a GPC signal, Clarity will respect it and restrict data collection.

What about other tracking technologies, like web beacons?

Cookies are not the only way to recognize or track visitors to a website. We may use other, similar technologies from time to time, like web beacons (sometimes called "tracking pixels" or "clear gifs"). These are tiny graphics files that contain a unique identifier that enables us to recognize when someone has visited our Website or opened an email including them. This allows us, for example, to monitor the traffic patterns of users from one page within a website to another, to deliver or communicate with cookies, to understand whether you have come to the website from an online advertisement displayed on a third-party website, to improve site performance, and to measure the success of email marketing campaigns. In many instances, these technologies are reliant on cookies to function properly, and so declining cookies will impair their functioning.

Do you use Flash cookies or Local Shared Objects?

Websites may also use so-called "Flash Cookies" (also known as Local Shared Objects or "LSOs") to, among other things, collect and store information about your use of our services, fraud prevention, and for other site operations.

If you do not want Flash Cookies stored on your computer, you can adjust the settings of your Flash player to block Flash Cookies storage using the tools contained in the Website Storage Settings Panel. You can also control Flash Cookies by going to the Global Storage Settings Panel and following the instructions (which may include instructions that explain, for example, how to delete existing Flash Cookies (referred to "information" on the Macromedia site), how to prevent Flash LSOs from being placed on your computer without your being asked, and (for Flash Player 8 and later) how to block Flash Cookies that are not being delivered by the operator of the page you are on at the time).

Please note that setting the Flash Player to restrict or limit acceptance of Flash Cookies may reduce or impede the functionality of some Flash applications, including, potentially, Flash applications used in connection with our services or online content.

Do you serve targeted advertising?

Third parties may serve cookies on your computer or mobile device to serve advertising through our Website. These companies may use information about your visits to this and other websites in order to provide relevant advertisements about goods and services that you may be interested in. They may also employ technology that is used to measure the effectiveness of advertisements. They can accomplish this by using cookies or web beacons to collect information about your visits to this and other sites in order to provide relevant advertisements about goods and services of potential interest to you. The information collected through this process does not enable us or them to identify your name, contact details, or other details that directly identify you unless you choose to provide these.

Microsoft Clarity and advertising: Microsoft may use data collected through Clarity cookies (particularly the MUID cookie) for advertising purposes across its network. This data may be used to serve personalised advertisements. You can manage your advertising preferences and opt out via Microsoft's opt-out page.

International data transfers

Data collected through Google Analytics is processed by Google in accordance with its privacy practices. Data collected through Microsoft Clarity is processed and stored in the United States. For transfers of personal data from the EEA, UK, and Switzerland to the United States, Microsoft relies on the EU–US Data Privacy Framework and other appropriate legal transfer mechanisms under applicable data protection laws.

How often will you update this Cookie Policy?

We may update this Cookie Policy from time to time in order to reflect, for example, changes to the cookies we use or for other operational, legal, or regulatory reasons. Please therefore revisit this Cookie Policy regularly to stay informed about our use of cookies and related technologies.

The date at the top of this Cookie Policy indicates when it was last updated.

Where can I get further information?

If you have any questions about our use of cookies or other technologies, please contact us at:

Badfish Labs LTD contact@badfishlabs.com