This Privacy Policy explains how Stables collects, uses, discloses and otherwise processes personal data in connection with any product, service or application that references or links to this Privacy Policy.

This Privacy Policy does not address our privacy practices relating to Stables job applicants, employees and other employment-related individuals, nor data that is not subject to applicable data protection laws (such as deidentified or publicly available information in certain jurisdictions). This Privacy Policy is not a contract and does not create any legal rights or obligations not otherwise provided by law.

In this Privacy Policy, "Stables", "we" and "us" mean the Stables Group company that provides services to you or operates the website you are using. That company is the controller of your personal data. You can contact us about privacy at team@stables.money.

Data protection laws sometimes differentiate between "controllers" and "processors" of personal data. A "controller" determines the purposes and means (the why and how) of processing personal data. A "processor", sometimes referred to as a "service provider", processes personal data on behalf of a controller subject to the controller's instructions.

This Privacy Policy describes our privacy practices where we act as a controller. That includes when you use Stables through a business that integrates our services: we hold the information we need to onboard you and process your payments as a controller in our own right. Where we process personal data on a customer's behalf and on its instructions, as its processor, that customer's privacy notice applies instead.

The categories of personal data we collect depend on how you interact with us and our services. For example, you may provide us your personal data directly when you sign up for our mailing list, register for an account, make a payment or otherwise contact or interact with us. We also collect personal data automatically when you interact with our websites and other services, and may collect personal data from other sources and third parties.

We collect the following categories of personal data individuals provide to us:

- Contact Information, including first and last name, phone number, email address, mailing address and communication preferences. We use this information primarily to fulfil your request or transaction, to communicate with you directly, and to send you marketing communications in accordance with your preferences.
- Professional Information, including job title, company name, professional background and the nature of your relationship with us. We use this information primarily to fulfil your request or transaction, to determine how we communicate with you, to administer your account, to provide you with our services, and for customer support purposes.
- Account Information, including first and last name, email address, phone number, account credentials or one-time passcodes, and the products or services you are interested in, have purchased or have otherwise used. We use this information primarily to administer your account, provide you with our products and services, and for customer support purposes.
- Payment Information, including payment card information, billing address and other financial information (such as routing and account numbers).
- Identity and Verification Information, including the information we need to verify identity, carry out due diligence and meet our legal and regulatory obligations, such as identity documents, photographs, and information about the businesses and people you represent or pay. We, and providers acting for us, use it to prevent fraud and financial crime and to comply with applicable law, and we may share it with authorities where the law requires.
- Security-Related Information, including electronic login records and access details. We use this information primarily to protect the security of our services, our customers and our company.
- Event and Survey Information, including information provided when you sign up for an event, complete a survey or submit a testimonial. We use this information primarily to administer our products and services, respond to your submission and communicate with you.
- Feedback and Support Information, including the contents of messages sent through forms, chat platforms, email or other contact methods we make available, and recordings of calls with us where permitted by law. We use this information primarily to investigate and respond to your inquiries and to improve our products and services.

We, and our third-party partners, automatically collect information about how you access and use our products and services. We typically collect this information through automatic data collection technologies, including (i) cookies or small data files stored on your device and (ii) related technologies such as web beacons, pixels, embedded scripts, mobile SDKs, location-identifying technologies and logging technologies. We use these technologies to collect:

- Information About Your Device and Network, including the device type, manufacturer and model, operating system, IP address, browser type, internet service provider, and unique identifiers associated with you, your device or your network.
- Information About How You Use Our Services, including the site from which you came, how often you access our services, whether you open our emails or click the links in them, and other actions you take on our services (such as the pages you visit and the content you view).
- Information About Your Location, including general geographic location that we or our providers may derive from your IP address, and precise geolocation when you grant us access through your device settings.

We use this information to operate, secure and improve our products and services and to personalise your experience.

We may receive the same categories of personal data described above from the following sources:

- Employers: if you interact with our services in connection with your employment, we may obtain personal data about you from your employer or another company for which you work.
- Platforms that integrate Stables: if you use Stables through a business that integrates our services, that business shares your identity and transaction information with us so we can onboard you and process your payments.
- Business Partners: we may receive your information from business partners, such as companies that offer their products or services as part of or in connection with our services.
- Service Providers: our service providers that perform services on our behalf, such as identity verification and analytics providers, collect personal data and may share some or all of it with us.
- Other Sources: we may also collect personal data about you from other sources, including publicly available sources, third-party data providers, or through transactions such as mergers and acquisitions.
- Inferences: we may generate inferences or predictions about you and your interests and preferences based on the other personal data we collect and our interactions with you.

In addition to the purposes described above, we may use personal data we collect to:

- Fulfil the reason the information was provided, such as to meet our contractual obligations, to facilitate payment for our products and services, or to deliver the services requested;
- Manage our organisation and its day-to-day operations;
- Communicate with you, including by email, text message, chat, social media and telephone;
- Facilitate our relationship with you and, where applicable, the company you represent;
- Address inquiries or complaints made by or about an individual in connection with our products or services;
- Create and maintain accounts for our users;
- Verify your identity and your entitlement to our products and services;
- Market our products and services to you, including through email, phone, text message, push notification and social media;
- Administer, improve and personalise our products and services, including by recognising you and remembering your information when you return;
- Develop, operate, improve, maintain, protect, and provide the features and functionality of our products and services, including through automated tools and machine learning;
- Identify and analyse how you use our products and services;
- Conduct research and analytics on our user base and our products and services;
- Test, enhance, update and monitor our products and services, or diagnose or fix technology problems;
- Maintain and enhance the safety, security and integrity of our property, products, services, technology, assets and business;
- Defend, protect or enforce our rights or applicable contracts and agreements (including our General Terms of Use);
- Detect, prevent, investigate or provide notice of security incidents or other malicious, deceptive, fraudulent or illegal activity;
- Facilitate business transactions and reorganisations affecting the structure of our business; and
- Comply with contractual and legal obligations and requirements.

We process personal data to perform our contract with you or the business you represent; to meet legal obligations, including anti-money laundering, sanctions and tax laws; for our legitimate interests in preventing fraud, keeping our services secure and marketing to business customers; and, where the law requires it, with your consent.

We disclose or otherwise make available personal data in the following ways:

- To Marketing Providers: we share personal data with providers that help us communicate with you about our products and services.
- To Business Partners: we may share personal data with our business partners, or allow them to collect personal data directly from you, in connection with our services.
- To Service Providers: we engage third parties to perform services on our behalf in connection with the uses described above.
- To Other Businesses as Needed to Provide Services: we may share personal data with third parties you engage with through our services, or as needed to fulfil a request or transaction, including payment processing services.
- In Connection with a Business Transaction or Reorganisation: we may take part in or be involved with a business transaction or reorganisation, such as a merger, acquisition, joint venture, or financing or sale of company assets.
- To Facilitate Legal Obligations and Rights: we may disclose personal data to third parties, such as legal advisers, regulators and law enforcement, to establish, exercise or defend legal claims; to comply with laws or respond to lawful requests and legal process; to protect our rights and property; or to protect the health and safety of us, our customers or any person.
- With Your Consent or Direction: we may disclose your personal data to other third parties, or publicly, with your consent or at your direction, including to AI agents and assistants you or your organisation connect to Stables.

Email preferences. You can stop receiving promotional emails from us by clicking the "unsubscribe" link in any of them. You cannot opt out of service-related emails, such as account verification, transaction confirmations or service updates.

Withdrawing your consent. Where we rely on your consent, for example to send certain marketing communications, you may withdraw it by following the instructions given when your consent was requested or by contacting us.

Cookies. Our website uses essential cookies that it needs to work and, if you allow them, analytics cookies (Google Analytics) that help us understand how the site is used. You can change your choice at any time in the cookie settings. You can learn about Google Analytics' opt-outs, including the Google Analytics Browser Add-On, at tools.google.com/dlpage/gaoptout, and about how Google processes data at www.google.com/policies/privacy/partners.

Device and platform settings. The device or platform you use to interact with us may offer additional choices about the data you share with us, such as device permissions. Please refer to your device or platform provider's guidance.

We keep identity verification, due diligence and transaction records for as long as applicable law requires after our relationship ends. We keep other personal data only for as long as we need it for the purposes in this Privacy Policy.

We operate in several countries and use service providers in others, so your personal data may be processed outside the country where you live. Where the law requires it, we protect those transfers with appropriate safeguards, such as standard contractual clauses.

Depending on where you live, you may have the right to access, correct, delete or move your personal data, to object to or restrict how we use it, and to withdraw consent. Contact us at team@stables.money and we will respond within 30 days. We may not be able to delete records we are legally required to keep. You may also complain to your local data protection authority.

Our services are for businesses and adults. They are not directed to, and we do not knowingly collect personal data from, anyone under the age of 18. If we learn that we have collected personal data from someone under 18, we will promptly delete it. If you believe a person under 18 has provided us with personal data, please contact us.

We have implemented reasonable physical, technical and organisational safeguards designed to protect your personal data, and we take steps designed to ensure that third parties with whom we share personal data provide a similar level of protection. However, we cannot completely ensure or warrant the security of your personal data.

Our websites and services may link to or redirect you to third-party websites, plug-ins, applications or other services, and third parties may link to ours. This Privacy Policy does not apply to the personal data practices of those third parties. Please read their own privacy notices.

We may update this Privacy Policy at any time. Changes take effect when we publish the updated version on our website, and we will change the date at the top. Where the law requires it, we will also notify you.

If you have any questions or requests about this Privacy Policy or other privacy matters, please contact us at team@stables.money.