Privacy Policy

1. INTRODUCTION

1.1 Important information and who we are

Welcome to Vabble Ltd’s Privacy and Data Protection Policy (“Privacy Policy”).

At Vabble Ltd (“we”, “us”, or “our”) we are committed to protecting and respecting your privacy and Personal Data in compliance with the United Kingdom General Data Protection Regulation (“GDPR”), the Data Protection Act 2018 and all other mandatory laws and regulations of the United Kingdom.

This Privacy Policy explains how we collect, process and keep your data safe. The Privacy Policy will tell you about your privacy rights, how the law protects you, and inform our employees and staff members of all their obligations and protocols when processing data.

The individuals from which we may gather and use data can include:

• Customers
• Suppliers
• Business contacts
• Employees/Staff Members
• Third parties connected to your customers
• Directors, authorised signatories and ultimate beneficial owners of the businesses we deal with

and any other people that the organisation has a relationship with or may need to contact.

This Privacy Policy applies to all our employees and staff members and all Personal Data processed at any time by us.

1.2 Who is Your Data Controller and Data Protection Officer

Vabble Ltd is your Data Controller and responsible for your Personal Data.

We have appointed a data protection officer (“DPO”) who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights surrounding your Personal Data please contact the DPO using the details set out below:

Full name: Pablo Terpolilli

Email address: compliance@vabble.io

Postal address: 5 New Street Square, London, EC4A 3TW, United Kingdom

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

1.3 Processing Data on Behalf of a Controller and Processors’ responsibility to you

In discharging our responsibilities as a Data Controller we have employees who will deal with your data on our behalf (known as “Processors”). Therefore, the responsibilities described below may be assigned to an individual, or may be taken to apply to the organisation as a whole. The Data Controller and our Processors have the following responsibilities:

• Ensure that all processing of Personal Data is governed by one of the legal bases laid out in the GDPR (see 2.2 below for more information on those bases);
• Ensure that Processors authorised to process Personal Data have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality;
• Implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk associated with the processing of Personal Data;
• Obtain the prior specific or general authorisation of the Controller before engaging another Processor;
• Assist the Controller in the fulfilment of the Controller's obligation to respond to requests for exercising the data subject's rights;
• Make available to the Controller all information necessary to demonstrate compliance with the obligations laid down in the GDPR and allow for and contribute to audits, including inspections, conducted by the Controller or another auditor mandated by the Controller;
• Maintain a record of all categories of processing activities carried out on behalf of a Controller;
• Cooperate, on request, with the supervisory authority in the performance of its tasks;
• Ensure that any person acting under the authority of the Processor who has access to Personal Data does not process Personal Data except on instructions from the Controller;
• Notify the Controller without undue delay after becoming aware of a Personal Data Breach;
• Designate a data protection officer where required by the GDPR, publish their details and communicate them to the supervisory authority; and
• Support the data protection officer in performing their tasks by providing resources necessary to carry out those tasks and access to Personal Data and processing operations, and to maintain their expert knowledge;

2. LEGAL BASIS FOR DATA COLLECTION

2.1 Types of Data / Privacy Policy Scope

“Personal Data” means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of Personal Data about you which we have grouped together below. Not all of the following types of data will necessarily be collected from you but this is the full scope of data that we collect and when we collect it from you:

• Profile/Identity Data: This is data relating to your first name, last name, gender, date of birth.
• Contact Data: This is data relating to your phone number, addresses, email addresses, phone numbers.
• Marketing and Communications Data: This is your preferences in receiving marketing information and other information from us.
• Billing Data: This is information relating to your debit and credit card information such as the name attached to your payment details and your billing address.
• Financial Data: These are your banking details e.g. your account number and sort code.
• Transactional Data: This is information of details and records of all payments you have made for our services or products.
• Technical Data: This is your IP address, browser type and version, time zone setting and location, operating system and platform, and other technology on the devices you use to engage with us.
• Customer Support Data: This includes feedback and survey responses.
• Usage Data: information about how you use our website, products and services.
• Verification Data: for you, for your buyer, and for the directors, authorised signatories and ultimate beneficial owners of each — name, date of birth, nationality, country of residence, address, the nature and extent of any interest held, and the results of the identity, sanctions and financial-crime checks described in section 3.1.

We also collect, use and share Aggregated Data such as to analyse, interpret and create new products or offerings to all our clients, protecting their identity as per these stated policies. Aggregated Data could be derived from your Personal Data but is not considered Personal Data in law as this data will not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this Privacy Policy.

We may also aggregate data to enable research or analysis so that we can better understand and serve you and others. For example, we may conduct research on your demographics and usage. Although this aggregated data may be based in part on Personal Data, it does not identify you personally. We may share this type of anonymous data with others, including service providers, our affiliates, agents and current and prospective business partners.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). We do not seek out information about criminal convictions and offences. Where a sanctions, politically exposed person or financial-crime screening check returns a match against a business or an individual connected to it, the record of that match is data relating to criminal convictions and offences within the meaning of Article 10 of the UK GDPR. We process it only for the prevention, investigation and detection of unlawful acts, in reliance on the substantial public interest condition at paragraph 10 of Part 2 of Schedule 1 to the Data Protection Act 2018, and we maintain an appropriate policy document covering that processing as that Schedule requires. Access to these records is limited to the staff who need to see them, and they are kept no longer than the purpose requires.

2.2 The Legal Basis for Collecting That Data

There are a number of justifiable reasons under the GDPR that allow collection and processing of Personal Data. The main avenues we rely on are:

• “Consent”: Certain situations allow us to collect your Personal Data, such as when you tick a box that confirms you are happy to receive email newsletters from us, or ‘opt in’ to a service.
• “Contractual Obligations”: We may require certain information from you in order to fulfil our contractual obligations and provide you with the promised service.
• “Legal Compliance”: We’re required by law to collect and process certain types of data, such as fraudulent activity or other illegal actions.
• “Legitimate Interest”: We might need to collect certain information from you to be able to meet our legitimate interests - this covers aspects that can be reasonably expected as part of running our business, that will not have a material impact on your rights, freedom or interests. Examples could be your address, so that we know where to deliver something to, or your name, so that we have a record of who to contact moving forwards.

3. HOW WE USE YOUR PERSONAL DATA

3.1 Our Uses

We will only use your Personal Data when the law allows us to. Set out below is a table containing the different types of Personal Data we collect and the lawful basis for processing that data. Please refer to section 2.2 for more information on the lawful basis listed in the table below.

Examples provided in the table below are indicative in nature and the purposes for which we use your data may be broader than described but we will never process your data without a legal basis for doing so and it is for a related purpose. For further inquiries please contact our Data Protection Officer.

Some of this processing exists because of what the Platform does. Before a receivable can be funded we verify the businesses involved and the people behind them. We carry out identity and business verification checks on you and, where relevant, on your buyer, and on their directors, authorised signatories and ultimate beneficial owners — for whom we collect name, date of birth, nationality, country of residence, address, and the nature and extent of the interest held. We screen those businesses and individuals against applicable sanctions, politically exposed person and financial-crime lists. We check the trade documents you submit against one another and against the record of previous dealings between the parties. And we obtain credit and business information about buyers, and about their beneficial owners, from third-party information providers. We also monitor the transactions that pass through the Platform on a continuing basis — the parties, the amounts, the corridors and the patterns they form — so that activity inconsistent with the trade it is said to represent can be identified.

We rely on Legitimate Interest for these checks — both our own and those of third parties, which Article 6(1)(f) of the UK GDPR expressly allows. Vabble Ltd is not itself an obliged entity under the Money Laundering Regulations 2017. We carry out these checks because the institutions that fund receivables through the Platform are subject to money-laundering and sanctions obligations of their own and rely on the verification we perform, and because a receivables market only functions if the parties to it are who they say they are. The information providers we use are themselves subject to those regimes. You may object to processing carried out on this basis — section 4.5 explains how — and we will stop unless we can demonstrate compelling legitimate grounds that override your interests, rights and freedoms, or that we need the data to establish, exercise or defend legal claims.

Software assists these checks. Documents you upload are read automatically, and the data taken from them is matched against the purchase order, the shipping and customs record, and the history between you and your buyer; anything that does not reconcile is flagged. These tools do not decide anything. A member of our staff reviews every flag, and no decision that produces a legal effect for you, or that similarly significantly affects you, is taken solely by automated means.

Not all of this data reaches us from you. We also receive Personal Data about individuals connected to a business — a director, an authorised signatory or an ultimate beneficial owner — from the business itself, from public registers such as the register of people with significant control, and from the information providers described above. Where we hold Personal Data about someone who has not dealt with us directly, we ask the business that provided it to bring this Privacy Policy to their attention, and we will provide it to them directly on request.

3.2 Marketing and Content Updates

You will receive marketing and new content communications from us if you have created an account and chosen to opt into receiving those communications. From time to time we may make suggestions and recommendations to you about goods or services that may be of interest to you.

3.3 Change of Purpose

We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact our Data Protection Officer.

If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

4. YOUR RIGHTS AND HOW YOU ARE PROTECTED BY US

4.1 What Control Do I Have Over Vabble Ltd’s Use Of My Personal Data?

You may delete your account at any time – this will remove your account page from our systems and our related software.

We do not guarantee the ability to delete all stored data. If you would like us to delete/correct personally identifiable data, let us know and we will action your request as soon as practicable.

Your account information will be protected by a password for your privacy and security. You need to prevent unauthorized access to your account and personal information by selecting and protecting your password appropriately and limiting access to your computer or device and by signing off after you have finished accessing your account.

You can access information associated with your account by logging into your account you created with us.

California Privacy Rights: Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of personal customer information which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to compliance@vabble.io.

4.2 How Does Vabble Ltd Protect Customers' Personal Data?

We are concerned with keeping your data secure and protecting it from inappropriate disclosure. We implement a variety of security measures to protect your Personal Data. Documents and records are held in cloud infrastructure located in the European Union, in storage with public access disabled and reachable only through the Platform. Data is encrypted in transit. Access is limited to a small number of staff whose role requires it, each bound by obligations of confidentiality, and administrative access requires two-factor authentication. If and when we use subcontractors to store your data, we will not relinquish control of your Personal Data or expose it to security risks that would not have arisen had the data remained in our possession. However, unfortunately no transmission of data over the internet is guaranteed to be completely secure. It may be possible for third parties not under the control of Vabble Ltd to intercept or access transmissions or private communications unlawfully. While we strive to protect your Personal Data, we cannot ensure or warrant the security of any Personal Data you transmit to us. Any such transmission is done at your own risk. If you believe that your interaction with us is no longer secure, please contact us.

4.3 Opting Out Of Marketing Promotions

You can ask us to stop sending you marketing messages at any time by Communicating it on our platform, by email, or by opting out.

Where you opt out of receiving these marketing messages, we will continue to retain other Personal Data provided to us as a result of interactions with us not related to your marketing preferences.

4.4 How to Request your Data and the Process for Obtaining it

You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, if your request is clearly unfounded, we could refuse to comply with your request.

We may need to request specific information from you to help us confirm your identity and ensure you have the right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

4.5 Your Rights Under Data Protection Law

Separately from the sections above, data protection law gives you the following rights over your Personal Data. Some of them apply only in particular circumstances, and we will tell you if that is why we cannot act on a request.

• Access. The right to be told whether we are processing your Personal Data and, if we are, to receive a copy of it together with the information in this Privacy Policy.
• Rectification. The right to have inaccurate Personal Data corrected and incomplete Personal Data completed.
• Erasure. The right to ask us to delete your Personal Data where we no longer need it, where you withdraw a consent we were relying on, or where you object and we have no overriding ground to continue.
• Restriction. The right to ask us to suspend processing while a question about accuracy or about our grounds is resolved.
• Portability. The right to receive the Personal Data you gave us in a structured, commonly used, machine-readable format, and to have it sent to another controller where that is technically feasible.
• Objection. The right to object to processing we carry out on the basis of Legitimate Interest, and to object at any time, without needing a reason, to processing for direct marketing.
• Automated decisions. The right not to be subject to a decision producing legal effects for you, or similarly significantly affecting you, taken solely by automated means.
• Withdrawing consent. The right to withdraw a consent at any time, which does not affect the lawfulness of anything we did while it was in force.

To exercise any of these rights, contact our Data Protection Officer using the details in section 1.2. We will respond within one month. If your request is complex, or if you have made several, we may extend that by a further two months and will tell you why within the first month. If we have shared your Personal Data with others, we will tell them about a correction, erasure or restriction wherever that is possible, and will tell you who they were if you ask and it is lawful for us to do so.

If you are not satisfied with how we have handled your Personal Data you may complain to the Information Commissioner's Office, the UK supervisory authority for data protection, at ico.org.uk. We would be glad of the chance to put things right first.

5. YOUR DATA AND THIRD PARTIES

5.1 Will We Share Your Data With Third Parties?

We may share non-Personal Data with third parties. We may share your Personal Data with subcontractors or affiliates (subject to confidentiality obligations to use it only for the purposes for which we disclose it to them and pursuant to our instructions).

Those suppliers fall into a small number of categories: cloud hosting and document storage; transactional email and SMS delivery; error monitoring; identity, sanctions and credit information providers; document-processing services used to read and check the documents you upload; payment and banking partners; and our professional advisers. Each acts only on our instructions, under written terms that hold them to the standards set out in this Privacy Policy. We keep a current list of them and will provide it on request.

Separately from those suppliers, we disclose verification, screening and transaction monitoring records to the institutional investors who purchase receivables through the Platform, where they ask for them. They need those records to satisfy their own know-your-customer, know-your-business and know-your-transaction requirements before they can buy a receivable. Those investors are controllers of that data in their own right rather than suppliers acting on our instructions, and their own privacy notices govern what they then do with it. We disclose only what the request requires, and only to an investor with a live or prospective interest in the receivable concerned.

We may also share Personal Data with interested parties in the event that Vabble Ltd anticipates a change in control or the acquisition of all or part of our business or assets or with interested parties in connection with the licensing of our technology.

If Vabble Ltd is sold or makes a sale or transfer, we may, in our sole discretion, transfer, sell or assign your Personal Data to a third party as part of or in connection with that transaction. Upon such transfer, the Privacy Policy of the acquiring entity may govern the further use of your Personal Data. In all other situations your data will still remain protected in accordance with this Privacy Policy (as amended from time to time).

We may share your Personal Data at any time if required for legal reasons or in order to enforce our terms or this Privacy Policy.

5.2 Third-Party Links

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

6. HOW LONG WILL WE RETAIN YOUR DATA FOR?

We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for. We may retain your Personal Data for a longer period than usual in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

7. AGE LIMIT FOR OUR USERS

You must not use Vabble Ltd unless you are aged 21 or older. If you are under 21 and you access Vabble Ltd by lying about your age, you must immediately stop using Vabble Ltd.

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

8. INTERNATIONAL TRANSFER OF DATA

The Platform and its database run in the European Union, and the documents you upload are held in European Union storage. Two transfers routinely go outside the United Kingdom and the European Economic Area, and we name them here rather than describe our processing as wholly European. First, backup copies of our database are kept by our hosting provider in object storage that is not restricted to a European region. Second, where a document you upload is read automatically to extract the details of a transaction, its contents are processed by an artificial-intelligence provider in the United States.

Where such a transfer is necessary — because a supplier who processes data on our behalf operates from elsewhere, for example — we make it only where the destination is covered by UK adequacy regulations, or under the International Data Transfer Agreement or the UK Addendum to the Standard Contractual Clauses, together with any further measures the transfer requires. You may ask us for details of the safeguards that apply to a particular transfer, and for the current list of processors who receive your Personal Data outside the United Kingdom and the European Economic Area.

9. NOTIFICATION OF CHANGES AND ACCEPTANCE OF POLICY

We keep our Privacy Policy under review and will place any updates on this webpage. This version is dated 25 September 2026 and replaces the version dated 21 September 2026. By using Vabble Ltd, you consent to the collection and use of data by us as set out in this Privacy Policy. Continued access or use of Vabble Ltd will constitute your express acceptance of any modifications to this Privacy Policy.

10. INTERPRETATION

All uses of the word "including" mean "including but not limited to" and the enumerated examples are not intended to in any way limit the term which they serve to illustrate. Any email addresses set out in this policy may be used solely for the purpose for which they are stated to be provided, and any unrelated correspondence will be ignored. Unless otherwise required by law, we reserve the right to not respond to emails, even if they relate to a legitimate subject matter for which we have provided an email address. As a matter of common sense, you are more likely to get a reply if your request or question is polite, reasonable and there is no relatively obvious other way to deal with or answer your concern or question (e.g. FAQs, other areas of our website etc.).

Our staff are not authorised to contract on behalf of Vabble Ltd, waive rights or make representations (whether contractual or otherwise). If anything contained in an email from a Vabble Ltd address contradicts anything in this policy, our terms or any official public announcement on our website, or is inconsistent with or amounts to a waiver of any Vabble Ltd rights, the email content will be read down to grant precedence to the latter. The only exception to this is genuine correspondence expressed to be from the Vabble Ltd legal department.