Legal

I. Preamble and Scope

This consolidated legal notice (hereinafter, the "Notice") governs access to and use of the online platform operated under the name GoWira and made available at gowira.com (hereinafter, the "Service", the "Platform" or the "Website", used interchangeably unless the context requires otherwise). The Notice brings together the Privacy Policy, the Terms of Service, the Cookie Policy and the Imprint. For the avoidance of doubt, and without prejudice to any other provision expressed elsewhere, the four documents coexist within this single Notice and must be read as a coherent whole: where an apparent overlap, redundancy or cross-reference arises, the more specific or later provision prevails to the extent that such prevalence does not diminish any right that the law grants to the user.

The Notice is issued in the context of, and with due regard to, the obligations stemming from Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter, the "GDPR"); Directive 2002/58/EC as amended (hereinafter, the "ePrivacy Directive"); the California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act (together, the "CCPA"); Directive 2005/29/EC concerning unfair business-to-consumer commercial practices; Directive 2011/83/EU on consumer rights; Regulation (EU) 2019/1150 on promoting fairness and transparency for business users of online intermediation services; Directive (EU) 2019/2161 on the better enforcement and modernisation of Union consumer protection rules; Regulation (EU) 2022/2065 (the "Digital Services Act"); Regulation (EU) 2023/988 on general product safety; applicable federal and state computer-fraud statutes; and any other instrument of equivalent force and effect that may from time to time apply to the subject-matter covered herein.

Where the Notice refers to a statutory instrument, that reference is to be read as including any successor, amendment, consolidation or implementing measure, whether of direct effect or transposed into national law, unless the contrary is expressly stated. Nothing in the Notice shall be construed as limiting or excluding any mandatory statutory right that the user enjoys in the jurisdiction where the user has their habitual residence.

II. Definitions and Interpretation

In this Notice, unless the context otherwise requires, the following terms shall have the meanings ascribed to them below. Each definition is to be applied consistently across all sections (Privacy, Terms, Cookies, Imprint) of the Notice, without prejudice to any further clarifications that a particular section may introduce for its own internal purposes.

"Account"

means the authenticated user environment created upon successful verification of an email address, through which a user accesses saved results, preferences, and any features that require identification.

"Affiliate Link" / "Referral Link"

means a hyperlink placed within the Platform that, upon activation by the user, routes the user to a third-party service and that may cause GoWira to receive a referral fee contingent on subsequent actions taken by the user at that third-party service. The existence of such hyperlinks does not influence the order or substance of any comparison, ranking, calculation, or narrative produced by the Platform.

"Calculation" / "Result"

means an indicative estimate produced by the Platform on the basis of publicly available fiscal and cost-of-living data, reasonable assumptions relating to filing status, residency, employment category, and other parameters entered by the user or inferred from defaults. Calculations are not, and shall not be construed as, tax, financial, legal, immigration, medical, or professional advice of any kind.

"Consent"

means a freely given, specific, informed and unambiguous indication of the data subject's wishes by which the data subject, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to them (Article 4(11) GDPR).

"Controller"

means the natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data (Article 4(7) GDPR). For the purposes of the personal data collected through the Service, GoWira is the Controller.

"Cookies"

means small text files or equivalent tracking technologies (including, without limitation, local storage entries, session storage entries, fingerprints, pixels, beacons, tags, SDKs, and any other mechanism capable of storing information on or retrieving information from the user's terminal equipment) that may be deployed in connection with the provision of the Service, the analysis of aggregated usage, or the attribution of referrals, as further described in Section VI of this Notice.

"Data Subject"

means an identified or identifiable natural person whose personal data is processed through the Service.

"Essential Cookies"

means Cookies that are strictly necessary for the provision of a service explicitly requested by the user, such as authentication, session continuity, security and the storage of consent preferences, and that therefore do not require consent under the ePrivacy Directive.

"GoWira" / "we" / "us" / "our"

means the operator of the Platform and publisher of this Notice, acting as Controller in respect of the personal data collected through the Service. Correspondence may be addressed in all cases to [email protected].

"Marketing Cookies"

means Cookies used to attribute outgoing clicks to third-party partners and, where applicable, to display advertisements; these cookies are disabled by default and only activate upon the user's explicit opt-in consent.

"Personal Data"

means any information relating to an identified or identifiable natural person within the meaning of Article 4(1) GDPR, irrespective of whether such information is stored in structured or unstructured form and irrespective of the medium in which it is processed.

"Processor" / "Sub-processor"

means a natural or legal person, public authority, agency, or other body that processes Personal Data on behalf of the Controller pursuant to a data processing agreement that satisfies Article 28 GDPR. A sub-processor is a further processor engaged by a processor.

"Service"

means the Platform together with any related content, features, tools, APIs, automated communications, and supporting materials made available by GoWira from time to time, whether accessed through the Website or through any other access channel that GoWira may lawfully authorise.

"Terms"

means Section IV of this Notice (Terms of Service), together with any document incorporated by reference, each as modified from time to time in accordance with the procedures set out herein.

"User" / "you"

means any natural person accessing or using the Service, whether anonymously or through an authenticated Account, and includes, for the avoidance of doubt, casual visitors, registered users, and consumers within the meaning of applicable consumer protection legislation.

Interpretation

References to the singular include the plural and vice versa. References to a person include a natural person or a legal entity. The headings in this Notice are included for convenience of reference only and shall not affect its construction. Unless the contrary intention appears, a reference to a clause or section is to a clause or section of this Notice. The word "including" (and its cognates) is to be read as meaning "including without limitation". Any reference to a statute, rule, directive or regulation is to that instrument as amended, re-enacted, consolidated or replaced from time to time.

III. Privacy Policy

III.1 Controller

GoWira is the Controller of the Personal Data processed through gowira.com. Enquiries, requests to exercise rights, and any other communication relating to the processing of Personal Data may be directed to [email protected]. Where a data protection officer is appointed, correspondence addressed to the same email address shall be deemed to reach the data protection officer.

III.2 Categories of Personal Data Collected

The Service collects Personal Data in two principal manners: directly, through information that the User actively supplies in the ordinary course of interacting with the Service; and indirectly, by means of technical telemetry generated as a necessary or ancillary consequence of the User's interaction with the Service. The categories listed below are illustrative and not exhaustive; any category of Personal Data not expressly mentioned shall be deemed to be covered by the general principles of transparency and minimisation enshrined in Articles 5 and 6 GDPR and shall be processed in accordance with those principles.

III.2.1 Personal Data You Provide Directly

• Email address — provided when you sign in, create an Account, or request a report.
• Profession and salary range — provided when you use the salary benchmark or tax comparison tools.
• Calculation inputs — including, without limitation, origin and destination cities, salary figures, family status, preferences and other parameters entered into the tools.
• Calculation history — the records of comparisons that you have run, stored within your Account for your later reference.
• Any additional information that you elect to provide in connection with a request to exercise a right, a bug report, a feature suggestion, or any communication addressed to the contact email above.

III.2.2 Personal Data Collected Automatically

• Click events — interactions with links, buttons, and recommendations on the Platform (tracked only with marketing cookie consent).
• Pseudonymised identifiers — derived technical tokens used exclusively for rate limiting, abuse prevention, and service stability. Raw network identifiers are not stored.
• Approximate location — country-level indication derived from network headers for geolocation features such as currency and default city suggestion.
• Browser language — to assist in suggesting relevant destinations and to render interface text in a language understood by the User.
• Usage data — pages visited, modules used and similar aggregated metrics, collected only with analytics consent.
• Cookies and similar technologies — as further described in Section VI below.

III.2.3 Categories of Personal Data We Do Not Collect

• Passwords.
• Payment or banking information.
• Biometric Personal Data.
• Social media profiles or address-book contacts.
• Special categories of Personal Data within the meaning of Article 9 GDPR (data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership; genetic or biometric data; health data; or data concerning sex life or sexual orientation), save to the strictly limited extent that a User voluntarily enters such information while using a tool that solicits it, in which case the data is processed solely to generate the indicative estimate requested and is not used for any other purpose.

III.3 Purposes of Processing

Personal Data is processed solely for purposes specified, explicit and legitimate, and is not further processed in a manner that is incompatible with those purposes, in accordance with the purpose-limitation principle set out in Article 5(1)(b) GDPR. The principal purposes are as follows:

• To provide the Service — running tax calculations, salary benchmarks, cost-of-living comparisons and any other tool that forms part of the Service.
• To improve the experience — understanding usage patterns, diagnosing errors, and developing additional features.
• To maintain security — preventing abuse, fraud, scraping, and unauthorised access.
• Referral attribution — measuring the outcomes of recommendations shown to the User, and solely where the User has granted marketing cookie consent.
• To communicate with the User — sending reports that the User has requested, service-related notifications, and marketing communications where the User has opted in.

III.4 Legal Basis (GDPR Article 6)

The legal bases upon which GoWira processes Personal Data are summarised in the table that follows. The enumeration is meant to be exhaustive of the principal legal bases relied upon; where multiple legal bases may support a given activity, the strongest applicable basis governs.

Where the legal basis relied upon is legitimate interest, GoWira has carried out the three-step balancing test required by Recital 47 GDPR and, for each such activity, the Controller has determined that the legitimate interest pursued is not overridden by the interests or fundamental rights and freedoms of the data subject. The balancing documentation is maintained internally and may be made available to a competent supervisory authority upon reasoned request.

III.5 Third-Party Service Providers (Processors)

GoWira does not sell Personal Data. GoWira relies on a limited number of service providers to operate the Service. Such providers act as Processors on behalf of the Controller under data processing agreements that satisfy Article 28 GDPR and only handle the minimum Personal Data required for each specified purpose. Providers are described by category below; a current list of the individual providers engaged at any given time is available upon written request to [email protected].

III.6 International Data Transfers

Personal Data may be processed within the European Economic Area and, in certain cases, in third countries where GoWira's Processors are established. Where Personal Data is transferred outside the European Economic Area, GoWira ensures that the transfer is subject to appropriate safeguards within the meaning of Chapter V GDPR, including but not limited to the Standard Contractual Clauses adopted by the European Commission, supplementary technical and organisational measures where those are required under the Schrems II jurisprudence, adequacy decisions, or any other lawful mechanism available under Article 46 or Article 49 GDPR.

III.7 Retention

III.8 Your Rights

Under the GDPR (Articles 15–22) and the CCPA, you have the following rights with respect to your Personal Data:

• Right of access (Article 15 GDPR).
• Right to rectification (Article 16 GDPR).
• Right to erasure, also known as the right to be forgotten (Article 17 GDPR).
• Right to data portability (Article 20 GDPR), including the right to receive your Personal Data in a structured, commonly used and machine-readable format.
• Right to restrict processing (Article 18 GDPR).
• Right to object to processing based on legitimate interest (Article 21 GDPR).
• Right to withdraw consent at any time (Article 7(3) GDPR) without affecting the lawfulness of processing that took place before withdrawal.
• Right to non-discrimination for exercising your rights (CCPA).
• Right to know the categories of Personal Data we collect, use and disclose (CCPA).
• Right to opt-out of the sale or sharing of Personal Data (CCPA). Note: GoWira does not sell Personal Data.

Rights may be exercised by writing to [email protected], or, where self-service tooling exists, via the relevant controls in /settings. GoWira will respond to valid requests within 30 days of receipt, extendable by up to two further months where the request is complex or where multiple requests are received from the same individual. Identity verification may be requested before a substantive response is issued, to the extent that such verification is proportionate.

III.9 CCPA — Additional Rights for California Residents

• Right to know — what Personal Information we collect, use, and disclose.
• Right to delete — request deletion of your Personal Information.
• Right to correct — inaccurate Personal Information.
• Right to opt-out of sale or sharing — although we do not sell your Personal Information.
• Right to non-discrimination — for exercising your CCPA rights.
• Right to limit the use of sensitive Personal Information — to the extent any such category is inferred from user-provided content.

To exercise CCPA rights, email [email protected] with the subject line "CCPA Request".

III.10 Supervisory Authority

If you believe that your data protection rights have been violated, you may lodge a complaint with the data protection authority of your EU/EEA country of residence. A directory of national authorities is maintained at edpb.europa.eu. The exercise of the right to lodge a complaint does not affect the availability of any other administrative or judicial remedy.

III.11 Data Security

GoWira applies appropriate technical and organisational measures to protect Personal Data, including encryption in transit and at rest, strict access controls so that each Account can only read its own data, input validation, abuse prevention mechanisms, and periodic security reviews. Notwithstanding the foregoing, no system can be considered perfectly secure, and the User acknowledges that GoWira cannot guarantee absolute protection against all conceivable threats. In the event of a Personal Data breach within the meaning of Article 4(12) GDPR, GoWira will act in accordance with Articles 33 and 34 GDPR.

III.12 Children

The Service is not intended for users under the age of 16. GoWira does not knowingly collect Personal Data from children. If GoWira becomes aware that Personal Data of a child has been collected, that data will be deleted without undue delay. Parents or guardians who believe their child has provided Personal Data may contact [email protected].

IV. Terms of Service

IV.1 Acceptance

By accessing or using GoWira (the "Service"), the User agrees to be bound by these Terms. If the User does not agree to all of these Terms, the User must not access or use the Service. These Terms, together with the other sections of this Notice incorporated by reference, constitute a legally binding agreement between the User and GoWira.

IV.2 Description of Service

GoWira is an online comparison platform for international relocation planning. The Service includes tools that help the User compare tax, cost of living, salary, visa, health and lifestyle factors across a wide set of cities worldwide. The Service is made available on an "as is" basis and the User accepts that features may evolve, be modified, or be retired at the discretion of GoWira.

IV.3 Important Disclaimer — Not Professional Advice

IV.4 Data Accuracy

While GoWira strives for accuracy, tax laws and cost-of-living data change frequently across jurisdictions. Calculations are based on publicly available data and may not reflect recent legislative changes, local variations, or the User's specific personal circumstances. Data is updated periodically but GoWira cannot guarantee real-time accuracy. The User is responsible for verifying any information before making decisions.

IV.5 User Accounts

• Creation: the User may create an Account using the User's email address.
• Responsibility: the User is responsible for maintaining the security of the Account and for all activity that occurs under it.
• Accuracy: the User must provide accurate information and keep it up to date.
• Termination by the User: the User may delete the Account at any time via Settings or by writing to [email protected]. Upon deletion, all Personal Data is removed within 30 days.
• Termination by GoWira: GoWira reserves the right to suspend or terminate Accounts that violate these Terms, engage in abusive behaviour, or compromise the security of the Service.

IV.6 Acceptable Use

The User agrees to provide accurate inputs when using the tools, to use the Service only for lawful purposes, and not to attempt to access data belonging to other users. The User further agrees not to:

• Use automated tools, bots, scrapers, or crawlers to access the Service.
• Reverse engineer, decompile, disassemble, or otherwise attempt to derive the source code of any part of the Service.
• Circumvent rate limits, authentication mechanisms, or security measures.
• Reproduce, copy, sell, or redistribute GoWira's proprietary data, algorithms, or calculations.
• Use the Service to train any automated or statistical model without explicit written permission.
• Attempt to overload, disrupt, or interfere with the Service's infrastructure.
• Use the Service for any activity that violates applicable laws or regulations.

IV.7 Intellectual Property

The Platform, including its software, algorithms, data compilations, designs, text, graphics, logos, and brand elements, is the intellectual property of GoWira and is protected by copyright, database rights, and trademark laws. The compilation, organisation, and presentation of fiscal data on GoWira constitutes an original work within the meaning of Directive 96/9/EC on the legal protection of databases. The User may share individual comparison results for personal, non-commercial use but may not systematically copy, redistribute, or commercially exploit any content from the Service.

IV.8 Referral and Advertising Disclosure

IV.9 Limitation of Liability

To the maximum extent permitted by applicable law:

• The Service is provided "as is" and "as available" without warranties of any kind, express or implied, including but not limited to warranties of merchantability, fitness for a particular purpose, and non-infringement.
• GoWira shall not be liable for any direct, indirect, incidental, special, consequential, or punitive damages arising from the use of or inability to use the Service.
• GoWira is not liable for any decisions made based on its estimates, calculations, or recommendations, including financial losses, tax penalties, visa denials, or relocation outcomes.
• GoWira does not guarantee the availability, accuracy, completeness, or timeliness of the Service or its data.

Nothing in this Section IV.9 limits or excludes any liability that cannot be limited or excluded under applicable mandatory law, including liability for death or personal injury caused by negligence, fraud, or fraudulent misrepresentation.

IV.10 Indemnification

The User agrees to indemnify, defend, and hold harmless GoWira, its operators, and affiliates from any claims, damages, losses, or expenses (including reasonable legal fees) arising from the User's use of the Service, the User's violation of these Terms, or the User's violation of any third-party rights.

IV.11 Third-Party Links and Services

The Service contains links to third-party websites and services. GoWira is not responsible for the content, privacy practices, or terms of any third-party sites. Use of third-party services is governed by their respective terms and privacy policies. The User is encouraged to review them before engaging.

IV.12 Data Protection

The User's use of the Service is also governed by Section III (Privacy) of this Notice, which describes how Personal Data is collected, used, and protected in compliance with the GDPR, CCPA, and other applicable data protection laws. By using the Service, the User acknowledges having read and understood Section III.

IV.13 Anti-Scraping

Automated access, scraping, crawling, or data extraction of GoWira's data, calculations, or proprietary algorithms is strictly prohibited without prior written consent. Circumventing any technical measure implemented to protect GoWira's systems or data is prohibited under applicable computer fraud and abuse laws.

IV.14 Governing Law and Jurisdiction

These Terms are governed by the laws applicable at the publisher's place of establishment, without prejudice to mandatory consumer protection rights in the User's country of residence. For EU/EEA consumers, nothing in these Terms limits statutory rights or the ability to bring claims before the courts of the User's country of residence to the extent provided by mandatory law. Any remaining disputes shall be submitted to the competent courts at the publisher's place of establishment. Details are available upon request at [email protected].

IV.15 Changes to Terms

GoWira may update these Terms at any time. Users will be notified of significant changes via email or in-app notification at least 30 days before the changes take effect. The "last updated" date at the top of this Notice reflects the most recent revision. Continued use of the Service after changes take effect constitutes acceptance of the updated Terms. If the User does not agree to the updated Terms, the User must stop using the Service.

IV.16 Severability

If any provision of these Terms is found to be unenforceable or invalid by a court of competent jurisdiction, that provision shall be limited or eliminated to the minimum extent necessary, and the remaining provisions shall remain in full force and effect.

V. Cookie Policy

V.1 What are Cookies?

Cookies and similar technologies are small pieces of data stored on, or retrieved from, the User's terminal equipment. They may be used to keep a session open, remember preferences, measure aggregated audience, or — in limited cases and only with consent — attribute outgoing clicks to third-party partners. The deployment of Cookies on the Service is consent-gated, with the exception of those Cookies that are strictly necessary to provide a service explicitly requested by the User.

V.2 Categories

• Essential Cookies — required for the Service to function: authentication, security, and the storage of consent choices. These Cookies cannot be disabled because the Service cannot be provided without them.
• Analytics Cookies — aggregated usage statistics that help GoWira improve the Service. Set only with the User's explicit opt-in consent; disabled by default.
• Marketing Cookies — click attribution for partner referrals and, where applicable, advertising frequency capping. Set only with the User's explicit opt-in consent; disabled by default.

V.3 User Controls

• Manage consent at any time via the cookie banner (Accept / Reject / Customize).
• Delete Cookies via the browser settings. Modern browsers support per-site cookie deletion.
• Certain operating systems and browsers expose ad-personalisation opt-outs; consult the relevant device settings.
• California residents may exercise CCPA rights by contacting us.

V.4 Third Parties

Certain Cookies may be set by Processors engaged to provide infrastructure, security, analytics (with consent), or advertising (with consent). Such Processors act on the Controller's behalf under data processing agreements. A current list of Processors is available upon request at [email protected].

V.5 Do Not Track

GoWira honours the browser's Do Not Track signal. Where Do Not Track is enabled, Analytics and Marketing Cookies are not set regardless of banner interaction.

V.6 Changes

If new cookie categories or Processors are introduced, this Notice will be updated and the consent banner re-triggered so that the User may review and re-consent. Material changes will be announced to registered users by email.

VI. Imprint / Legal Notice

VI.1 Publisher

The Service is published by an independent operator (the "Operator") established in the European Economic Area, trading under the GoWira brand. The Operator is the Controller of Personal Data processed through this Service within the meaning of Article 4(7) GDPR.

Detailed legal identification (full legal name of the Operator, postal address, and any tax registration number applicable on the date of the request) is provided in writing through the contact address above on reasoned request from a competent supervisory authority, regulator, court of competent jurisdiction, payment processor performing know-your-customer review, or merchant or affiliate network performing standard publisher due diligence. The Operator commits to respond within the timeframe required by the requesting party or, in any event, within fifteen (15) calendar days. The Operator complies with the information requirements of Article 5 of Directive 2000/31/EC and the equivalent national transpositions in the European Economic Area; nothing in this Notice derogates from those obligations.

VI.2 Nature of Service

GoWira operates an online platform offering comparison tools for international relocation planning, covering taxation, salary, cost of living, healthcare, mobility, and visa criteria across a wide set of jurisdictions. GoWira does not provide regulated financial, tax, legal, or immigration advisory services. All calculations and estimates are for informational purposes only and are derived from publicly available fiscal and statistical data sources.

VI.3 Regulatory Information

The Operator is not a licensed financial institution, tax advisory firm, immigration consultancy, or law practice. No regulatory licences or permits are held in relation to the provision of financial, tax, immigration, or legal services. Tools provide indicative estimates based on publicly available data and should not be relied upon as professional advice. Where the User requires professional advice on a specific personal situation, the User should consult a qualified professional licensed in the relevant jurisdiction before acting.

VI.4 Editorial Responsibility

Editorial responsibility for content published on gowira.com lies with the Operator. Articles are produced from publicly available primary sources (official statistical agencies, tax administrations of the relevant jurisdictions, supranational organisations such as the OECD, Eurostat, the World Bank, and IMF) and are reviewed prior to publication. The Operator does not accept paid placements that influence editorial conclusions; commercial relationships, where they exist, are disclosed at the section dedicated to affiliate disclosure (see II.7). Editorial corrections may be requested by writing to [email protected] with the subject line "Editorial Correction"; substantiated corrections are issued within seven (7) calendar days where applicable. Further detail on the methodology and the editorial standards is available at /about.

VI.5 Dispute Resolution

The European Commission provides an Online Dispute Resolution platform at ec.europa.eu/consumers/odr. GoWira is neither obligated nor willing to participate in dispute resolution proceedings before a consumer arbitration board, but is willing to address concerns directly via the contact address above.

VI.6 Liability for Content

The content on the pages of the Service has been produced with due care. Nonetheless, its accuracy, completeness, or timeliness cannot be guaranteed. As a service provider, GoWira is responsible for its own content on these pages under general law but is not obliged to monitor transmitted or stored third-party information or to investigate circumstances that may indicate illegal activity.

VI.7 Liability for Links

The Service contains links to external third-party websites whose content GoWira does not control. No liability can therefore be accepted for third-party content. The operator of the linked page is always responsible for the content of that page. At the time of linking, no illegal content was apparent.

VII. Summary of User Rights (for reference)

For ease of reference only, the following table restates the principal rights available to Users in respect of their Personal Data. The table is not a substitute for Sections III.8 and III.9 above and, in the event of inconsistency, the full provisions prevail.

VIII. Cross-References

Provisions of the Notice are, where applicable, to be read in conjunction with one another. The following cross-references are provided for the convenience of the reader and do not create substantive obligations beyond those already set out in the referenced sections.

• Retention of cookie consent preferences (Section III.7) is consistent with the 12-month re-prompt cycle described in Section V.2.
• The Referral and Advertising Disclosure in Section IV.8 is complemented by the Marketing Cookie description in Section V.2 and the consent requirement in Section III.4.
• The CCPA rights summarised in Section III.9 are consistent with the Right to know, Right to delete, and Right to opt-out categories set out in the California Civil Code §§ 1798.100 et seq.
• The description of Processors by category in Section III.5 is consistent with the category-based description in Section V.4.
• The choice-of-law and jurisdiction provisions in Section IV.14 operate without prejudice to the supervisory authority complaint mechanism in Section III.10.
• Users are reminded that the Anti-Scraping provisions of Section IV.13 apply in parallel with, and not as an alternative to, the technical measures referenced in Section III.11.

IX. Interpretive Notes and Boilerplate

The following general interpretive principles apply throughout the Notice. They are stated expressly to avoid ambiguity and are not intended to limit the ordinary meaning of any other provision.

Where a provision uses the phrase "without prejudice to", the provision is to be read as operating independently from, and without diminishing the effect of, the referenced instrument. Where a provision uses the phrase "subject to", the referenced instrument prevails to the extent of any conflict. Where a provision uses the phrase "for the avoidance of doubt", no substantive change to an existing obligation is intended; the clarification is offered only to forestall potential misinterpretation. Where a provision uses the phrase "mutatis mutandis", the referenced provision applies with such changes as are necessary to accommodate the subject-matter in hand. Where a provision uses the phrase "including but not limited to" or simply "including", the enumeration that follows is illustrative and not exhaustive, and the word "such as" is to be read in the same sense.

References to the masculine, the feminine, or the neuter include, as the context requires, each other. References to "person" include any legal entity. References to a statute include any subordinate legislation made under it and any successor or replacement instrument.

Time periods expressed in days are calculated in calendar days, not business days, unless the contrary is stated. Where a period is expressed as "within" a number of days, the period is inclusive of the day on which the triggering event occurs. Where a period expires on a day that is not a business day in the jurisdiction of the User's residence, the period is extended to the next following business day, save where such extension would be incompatible with an express statutory deadline.

Nothing in the Notice constitutes or is to be construed as an offer, solicitation, or recommendation to provide any regulated financial, investment, tax, legal, medical, or immigration service, nor as advice of any such kind. The Notice is provided solely in the context of the provision of the Service as defined herein.

X. Extended Glossary

The following additional terms are defined for the convenience of the reader. They supplement, and do not replace, the definitions in Section II. Where the same term is defined in both sections, Section II governs to the extent of any inconsistency.

"Adequate Third Country"

means a third country, a territory, or a specified sector within a third country in respect of which the European Commission has adopted an adequacy decision pursuant to Article 45 GDPR, with the effect that transfers of Personal Data to such country, territory, or sector may take place without the need for specific authorisation.

"Anonymisation"

means the irreversible process by which Personal Data is rendered no longer capable, by any means reasonably likely to be used, to identify a natural person, with the effect that the data ceases to constitute Personal Data within the meaning of the GDPR.

"Automated Decision-Making"

means a decision taken solely on the basis of automated processing, including profiling, which produces legal effects concerning the data subject or similarly significantly affects the data subject, as contemplated by Article 22 GDPR. GoWira does not engage in Automated Decision-Making that produces legal or similarly significant effects; calculations produced by the Service are indicative estimates only.

"Balancing Test"

means the three-step assessment required by Recital 47 GDPR to determine whether a legitimate interest pursued by the Controller is overridden by the interests or fundamental rights and freedoms of the data subject: (i) identification of the legitimate interest; (ii) assessment of the necessity of the processing for that interest; and (iii) balancing of that interest against the rights of the data subject.

"Consent Banner"

means the user interface element through which the User is informed about the categories of Cookies deployed on the Platform and through which the User may accept, reject, or customise non-essential Cookies.

"Data Minimisation"

means the principle set out in Article 5(1)(c) GDPR, pursuant to which Personal Data must be adequate, relevant, and limited to what is necessary in relation to the purposes for which it is processed.

"Data Protection Impact Assessment" / "DPIA"

means the assessment described in Article 35 GDPR, to be carried out prior to processing that is likely to result in a high risk to the rights and freedoms of natural persons.

"ePrivacy Consent"

means the specific form of consent required by Article 5(3) of the ePrivacy Directive for the storing of information, or the gaining of access to information already stored, in the terminal equipment of a subscriber or user, save where such storing or access is strictly necessary for the provision of a service explicitly requested by the User.

"Integrity and Confidentiality"

means the principle set out in Article 5(1)(f) GDPR, pursuant to which Personal Data must be processed in a manner that ensures appropriate security, including protection against unauthorised or unlawful processing and against accidental loss, destruction, or damage.

"Joint Controller"

means the arrangement described in Article 26 GDPR where two or more controllers jointly determine the purposes and means of processing. GoWira does not act as Joint Controller save where the contrary is expressly stated in writing with the counterparty concerned.

"Legitimate Interest"

means the legal basis set out in Article 6(1)(f) GDPR, permitting processing that is necessary for the purposes of the legitimate interests pursued by the Controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject.

"Profiling"

means any form of automated processing of Personal Data consisting of the use of Personal Data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements, within the meaning of Article 4(4) GDPR.

"Pseudonymisation"

means the processing of Personal Data in such a manner that the Personal Data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the Personal Data are not attributed to an identified or identifiable natural person.

"Recital"

means a non-operative paragraph appearing at the head of a piece of European Union legislation that serves as an aid to the interpretation of the operative provisions that follow.

"Schrems II"

means the judgment of the Court of Justice of the European Union of 16 July 2020 in Case C-311/18, together with any subsequent guidance issued by the European Data Protection Board concerning international transfers of Personal Data.

"Standard Contractual Clauses" / "SCCs"

means the standard data protection clauses adopted by the European Commission pursuant to Article 46(2)(c) and (d) GDPR, as amended from time to time.

"Sub-processor"

means a further Processor engaged by a Processor to process Personal Data on behalf of the Controller, subject to the conditions set out in Article 28(2), (3) and (4) GDPR.

"Supervisory Authority"

means the independent public authority established by a Member State pursuant to Article 51 GDPR.

"Terminal Equipment"

means, within the meaning of the ePrivacy Directive, any equipment used by the User to access the Service, including desktop computers, laptops, tablets, mobile phones, and any other device capable of establishing a network connection for that purpose.

XI. Changes to this Notice

This Notice may be updated to reflect changes in practice or legal requirements. Significant changes will be communicated by email, in-app notification, or both. The "last updated" date at the top of the Notice reflects the most recent revision. Continued use of the Service after changes constitutes acceptance of the updated Notice. Where a change has a material adverse effect on the User, GoWira will, where practicable, provide the User with not less than 30 days' prior notice before the change takes effect, during which period the User may cease to use the Service without penalty.

XII. Contact

For all legal, data protection, and commercial enquiries, including the exercise of rights and requests for the current list of Processors:

• Email: [email protected]
• Subject-line conventions: "Privacy Request" for rights exercise, "CCPA Request" for CCPA matters, "Legal" for any other legal enquiry.

XIII. Final Disclaimers

The Service is an informational tool. Nothing within the Service or within this Notice constitutes tax, financial, legal, immigration, medical, or any other form of professional advice. The User is solely responsible for any decision taken on the basis of outputs produced by the Service, and is encouraged, in every material case, to consult a qualified professional before acting. GoWira disclaims all liability, to the maximum extent permitted by applicable law, for decisions taken in reliance on the Service, and reserves the right, without prior notice, to revise, suspend, or discontinue any feature, tool, or element of the Service at its sole discretion.

For ease of reference: this Notice, taken as a whole, is an integrated legal document. Reading it in parts without regard to the interpretive principles set out in Section IX is liable to produce a partial or inaccurate view of the User's rights and of the Controller's obligations. The User is therefore encouraged to consult the full text, and, where clarification is required, to direct enquiries to the contact address above.