PRIVACY POLICY

Last updated: 5 August 2026

OVERVIEW

This Privacy Policy explains how Jolyon Group Ltd, trading as Muffle ("we", "us" and "our"), collects, uses, shares and protects your personal information when you visit muffleearmuffs.com, purchase from us, or otherwise interact with us (the "Services").

We are the data controller for the personal information described in this policy. Our contact details are set out in Section 14.

By using the Services, you acknowledge that you have read and understood this Privacy Policy. Where we rely on your consent to process your personal information, we will ask for it separately and you may withdraw it at any time.

Our registration with the Information Commissioner's Office is currently pending. We will publish our registration number in this policy once it has been issued.

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SECTION 1 - WHO WE ARE

Jolyon Group Ltd is a company registered in England and Wales under company number 17115599, with its registered office at 3a Bishops Court Gardens, Chelmsford, Essex, England, CM2 6AZ. We trade as Muffle.

We are responsible for deciding how and why your personal information is processed in connection with the Services. Where we use third-party providers to process personal information on our behalf, we remain responsible for that processing and we require those providers to act only on our instructions.

ICO registration: application pending.

SECTION 2 - INFORMATION YOU PROVIDE TO US

When you place an order, contact us, subscribe to our emails or otherwise interact with us, you may provide us with:

(a) your name, email address, postal address and telephone number; (b) payment information, which is processed by our payment providers — we do not store full payment card numbers; (c) your order history, delivery preferences and any instructions you give us; (d) the content of any correspondence you send us, including support emails, product reviews, survey responses and ambassador programme applications.

You are not obliged to provide this information, but we may be unable to fulfil your order or respond to your enquiry without it.

SECTION 3 - INFORMATION WE COLLECT AUTOMATICALLY

When you access the Services, we and our providers may automatically collect:

(a) device and browser information, including browser type, operating system and screen resolution; (b) your IP address and the approximate location derived from it; (c) information about how you use the Services, including pages viewed, links clicked, time spent on pages and the website that referred you; (d) session recordings and heatmaps showing how you scroll, move and click through our pages; (e) cookies and similar identifiers, as described in Section 8.

SECTION 4 - INFORMATION WE RECEIVE FROM THIRD PARTIES

We may receive personal information about you from:

(a) Shopify and our payment providers, including order, fulfilment and fraud-prevention data; (b) Meta, in the form of aggregated advertising and campaign performance data; (c) shipping carriers, in the form of delivery status information.

SECTION 5 - HOW AND WHY WE USE YOUR INFORMATION

We use your personal information for the purposes set out below. The legal basis on which we rely under the UK GDPR is stated alongside each purpose.

Purpose	Legal basis
Processing and delivering your order, taking payment, and handling returns and warranty claims	Performance of a contract with you
Sending order confirmations, dispatch notifications and other service messages	Performance of a contract with you
Responding to your enquiries and providing customer support	Performance of a contract, or our legitimate interest in operating our business
Preventing and detecting fraud, abuse and misuse of the Services	Our legitimate interests, and compliance with a legal obligation
Maintaining accounting and tax records	Compliance with a legal obligation
Sending marketing emails about our products and offers	Your consent, or our legitimate interest where you are an existing customer purchasing similar products. You may opt out at any time
Website analytics, session recordings and improving the Services	Your consent, given through our cookie banner
Advertising and measuring advertising performance	Your consent, given through our cookie banner
Publishing reviews, testimonials and other content you submit	Your consent

Where we rely on consent, you may withdraw it at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.

We do not use your personal information to make decisions producing legal or similarly significant effects about you by automated means alone.

SECTION 6 - WHO WE SHARE YOUR INFORMATION WITH

We do not sell your personal information. We share it with the following categories of recipient in order to operate the Services:

(a) Shopify, our e-commerce platform, which hosts our store and processes orders and payments; (b) Shopify Payments and Stripe, our payment providers, for processing payments and fraud screening; (c) Klaviyo, for sending marketing and transactional email; (d) Meta Platforms, for advertising and conversion measurement via the Meta Pixel; (e) Google, for website analytics; (f) Microsoft Clarity, for session recordings and heatmaps showing how visitors use the Services; (g) shipping carriers and fulfilment partners, in order to deliver your order.

We may also disclose personal information where we are required to do so by law, where necessary to establish, exercise or defend legal claims, or in connection with a sale, merger or restructuring of our business.

SECTION 7 - INTERNATIONAL TRANSFERS

Some of our providers are located outside the United Kingdom, including in the United States. Where we transfer personal information outside the UK, we rely on appropriate safeguards, including UK adequacy regulations where they apply, or the International Data Transfer Addendum to the EU Standard Contractual Clauses. You may request further detail about these safeguards by contacting us.

SECTION 8 - COOKIES AND SIMILAR TECHNOLOGIES

We use cookies and similar technologies that are strictly necessary to operate the Services, and — where you consent — cookies for analytics, session recording and advertising.

You may accept, reject or change your preferences at any time through the cookie banner on our website. You may also block or delete cookies through your browser settings, although doing so may affect how the Services function.

SECTION 9 - HOW LONG WE KEEP YOUR INFORMATION

We retain personal information only for as long as necessary for the purposes set out in this policy:

(a) order and transaction records: six years following the end of the relevant tax year, in order to meet UK accounting and tax requirements; (b) marketing contact details: until you unsubscribe, or following two years of no engagement; (c) support correspondence: three years; (d) analytics and session recording data: as determined by each provider, typically up to twelve months. Microsoft Clarity retains session recordings for a limited period, currently around thirty days.

SECTION 10 - YOUR RIGHTS

If you are in the United Kingdom or the European Economic Area, you have the right to:

(a) request access to the personal information we hold about you; (b) request that we correct inaccurate or incomplete information; (c) request erasure of your personal information in certain circumstances; (d) request that we restrict our processing, or object to it, including objecting to direct marketing at any time; (e) request a portable copy of information you have provided to us; (f) withdraw your consent where we rely on consent; (g) lodge a complaint with the Information Commissioner's Office (ico.org.uk, telephone 0303 123 1113). We would ask that you contact us first so that we have the opportunity to address your concerns.

To exercise any of these rights, email support@muffleearmuffs.com. We will respond within one month. We may ask you to verify your identity before acting on a request.

SECTION 11 - ADDITIONAL RIGHTS FOR UNITED STATES RESIDENTS

Depending on the state in which you reside, you may have the right to know what personal information we collect, to access, correct or delete it, to obtain a portable copy, and to opt out of targeted advertising or the "sharing" of personal information for cross-context behavioural advertising.

We do not sell personal information for monetary consideration. Our use of the Meta Pixel and similar advertising technologies may constitute "sharing" or "targeted advertising" under certain state laws. You may opt out by rejecting advertising cookies in our cookie banner, or by contacting us.

We will not discriminate against you for exercising any of these rights. To make a request, email support@muffleearmuffs.com.

SECTION 12 - MARKETING

If you have opted in to marketing emails, you may unsubscribe at any time using the link at the foot of any marketing email, or by contacting us. You will continue to receive transactional messages relating to orders you have placed.

SECTION 13 - CHILDREN

The Services are not directed at children, and we do not knowingly collect personal information from anyone under the age of 16. If you believe a child has provided us with personal information, please contact us and we will delete it.

SECTION 14 - SECURITY

We use appropriate technical and organisational measures to protect your personal information, including encryption in transit and access controls on our systems and those of our providers. No method of transmission or storage is entirely secure, and we cannot guarantee absolute security.

SECTION 15 - CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in our practices or in applicable law. We will post the updated version on this page with a revised date, and will notify you of material changes where required to do so.

SECTION 16 - CONTACT INFORMATION

Questions about this Privacy Policy, or requests relating to your personal information, should be sent to us at support@muffleearmuffs.com.

Our contact information is posted below:

Jolyon Group Ltd, trading as Muffle support@muffleearmuffs.com 3a Bishops Court Gardens, Chelmsford, Essex, England, CM2 6AZ +44 7507 707695 Company registration number: 17115599 VAT number: not VAT registered ICO registration number: application pending