1. Our Commitment to Privacy

We are committed to protecting your privacy. For any personal data we collect or you submit to us, this Privacy Policy (“Policy”) explains why we collect the data, what we do with the data, and your rights and choices when it comes to your personal data.

When you access our website at UNETIX.AI (the “Website”), communicate with us via our online channels including email, or submit your personal data anywhere this Policy is posted, this Policy will apply to you.

So we can remain transparent about how we use your personal data, when there are significant updates to the Policy we will notify you if we have a means of contacting you, but you are invited to continually revisit the Policy to check for updates.

This Policy was last updated on [13^th October 2025].

2. Who is collecting your data

References to (“we”, “our”, or “us”) are to Unetix, an unincorporated company, operating under the laws of the Netherlands, that offers a business-to-business software-as-a-service payments data intelligence platform that provides data analytics and intelligence services to commercial clients (the “Unetix Service”) and that is currently managed and represented by NJD Consult Limited, a company registered in England and Wales under Company number 13756624.

We are the Data Controller and determine the purpose and manner in which your personal data is used.

The Website may contain links to other websites operated by other organisations. These third-party organisations will have their own privacy policies which you should read carefully before providing any of your personal data as we do not accept any responsibility or liability for the websites of other organisations.

1. The types of personal data we collect from you and the purpose

Usage Information:

When you use the Website, we collect: your responses to surveys so that we may understand your needs and that of the business you represent; information about the time you spend and the activities you engage with on the Website in order to better understand your interests; your IP address in order to know your general location so that we can manage the security of our web platform and the territorial scope of interest in the Unetix Service.

Communication and Marketing Information:

When you fill out our forms and questionnaires that we provide or request information, we collect: your name, name of the business you represent, role in the business you represent, phone number, email address, mailing address, and business location so that we so we may provide general updates about the progress of the development and release of the Unetix Service and so we can deliver (where we have your consent) offers and promotions that may be of interest to you.

Technology Information:

When you use the Website, we collect and store certain information via the use of technologies such as device identifiers, pixels and cookies (as further explained in our Section 11 below). These technologies track information about you and enable us to remember you when using your computer or device so that we can personalise your user journey. Where we require your consent for these activities, soliciting your consent will be included as part of the information provided in our cookie banner or notice that is displayed when you first access our Website.

1. Our lawful bases for the use of your personal data

We set out below the lawful basis for each category of information that we collect from you.

References to our “legitimate interests” are to those interests we have in running our business, developing our products and services, and delivering and improving our products and services in a way which may reasonably be expected and don’t infringe on your rights and freedoms.

1. Sharing personal data with Service Providers and other Organisations

We never sell your personal data to advertisers or other third parties. However, we share the personal data we collect about you in the ways described below.

Service Providers

We work with Service Providers that carry out certain functions on our behalf. These include, for example, companies that manage our business operations, help us with network and technology services, storing data, analysing data, managing mailing campaigns, and managing our list of prospective customers. We only share personal data that enable our Service Providers to provide their services.

Sharing personal data with other Organisations

We may share personal data with other organisations in the following circumstances:

• if the law or a public authority says we must share the personal data;
• if we need to share personal data in order to establish, exercise or defend our legal rights (this includes providing personal data to our professional advisors); or
• to an organisation we sell or transfer (or enter into negotiations to sell or transfer) any of our businesses or any of our rights or obligations under any agreement we may have with you. If the transfer or sale goes ahead, the organisation receiving your personal data can use your personal data in the same way as us.

6. Protecting your personal data

We have physical, electronic, and procedural safeguards that comply with regulations to protect personal information about you. We also ensure that all of our Service Providers have in place industry recognised safeguards. However, data transmissions over the internet cannot be guaranteed to be 100% secure. Consequently, we cannot ensure or warrant the security of information you transmit over the internet to us.

7. How long we use personal data for

Your personal data won’t be kept longer than necessary, giving due regard to: initial purpose of collection; age of data; any legal/regulatory reason for us to keep it; and whether needed to protect you or us. If requested, we will readily make information available about our data retention policy.

8. Your Data Protection Rights

Below, we set out the rights you have under the GDPR in relation to your personal data. Should you wish to exercise any of these rights, please write to us using the information provided under the “How to contact us” section of this Policy.

Subject Access Rights —You have a right to see the personal data we hold about you and the circumstances of our processing activities.

Right to have inaccurate information corrected — if you believe we hold inaccurate or missing information, please let us know and we will correct it.

Right to object to our use of your personal data — We will consider your objection to our use of your personal data. If on balance, your rights outweigh our interests in using your personal data, then we will at your request either restrict our use of it or delete it.

Right to object to direct marketing – where we engage in direct marketing activities (after getting your consent), if you make such an objection, we will stop using your personal data for direct marketing purposes.

Right to restrict our use of your personal data — you can restrict our use of your personal data, if you have successfully made a general objection, you are challenging the accuracy of the personal data we hold, or we have used your personal data unlawfully — but you do not want us to delete it.

Right to have your personal data deleted — you can have us delete your personal data when: we no longer need to keep your personal data; you have successfully made a general objection; you have withdrawn your consent to us using your personal data (where we have relied on consent as the lawful basis for doing so); or we have unlawfully processed your personal data

Right to complain to the data protection regulator

We’d like the chance to resolve any complaints you have, however you also have the right to complain to the data protection regulator in the Netherlands. The contact details for the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) is:

• Website: autoriteitpersoonsgegevens.nl
• Telephone: 088 – 1805 250
• Postal Address: Postbus 93374, 2509 AJ Den Haag, Netherlands This section is not applicable to a website privacy policy.

9. Children’s data

We do not knowingly collect personal data from children. Should we become aware that we are processing the personal data of any children, we will delete such personal data as soon as possible.

10. International Privacy Laws

This Policy complements and does not replace national data protection laws.  Any applicable national data protection law will supersede this Policy where such law imposes stronger requirements and this policy shall apply where there are no national data protection laws.

11. Our Use of Cookies and other tracking Technologies

Cookies Defined

Cookies are small text files that are placed on your device when you visit the Website to help us provide and improve our services.

Types of Cookies We Use

Essential Cookies: Necessary for the Website to function properly, including security features and basic navigation.

Functional Cookies: Remember your preferences and settings to enhance your user experience.

Analytics Cookies: Help us understand how visitors interact with the Website by collecting and reporting information anonymously.

Marketing Cookies: Used to deliver relevant advertisements and track the effectiveness of our marketing campaigns.

Legal Basis for Cookie Processing

• Essential cookies are processed based on our legitimate interest in providing a functional website.
• Non-essential cookies require your explicit consent before placement on your device.
• Third-Party Cookies

We may use third-party services such as Google Analytics, payment processors, and marketing platforms that place their own cookies. These third parties have their own privacy policies governing their use of cookies and tracking technologies.

Cookie Consent and Management

Upon your first visit, you will be presented with a cookie consent banner allowing you to accept or reject non-essential cookies. You can modify your cookie preferences at any time through our cookie settings panel accessible via the website footer. You may also manage cookies through your browser settings, though disabling essential cookies may affect website functionality.

Cookie Retention

Cookies are retained for varying periods depending on their purpose, from session cookies that expire when you close your browser to persistent cookies that may remain for up to 24 months.

Other Tracking Technologies

We may also use web beacons, pixel tags, and similar technologies for analytics and marketing purposes, subject to the same consent requirements as cookies.

1. How to contact us

If you have any questions about how we collect, store and use personal data please contact us at privacy@unetix.ai