Privacy Notice

Effective date: 12 September 2026

1. Who is responsible for your data

The controller of personal data collected through netta.network (the "Site") is FiatRails Foundation Ltd, an exempted foundation company incorporated in the Cayman Islands (Registration No. 431901; LEI 894500RG1F2BKNE8P514), registered office Landmark Square, Camana Bay, Grand Cayman, Cayman Islands (the "Foundation", "we", "us"). NETTA — The Settlement Computer — is a product of FiatRails Foundation Ltd.

Privacy enquiries: privacy@netta.network

2. What we collect

Briefing requests. When you submit the briefing-request form we collect the details you enter: your name, institution, role, business email, primary jurisdiction, corridors or flows of interest, and any message you include.

Newsletter. When you subscribe to NETTA Insights we collect your email address.

Server logs. Our hosting provider records technical data when the Site is accessed: IP address, browser and device type, pages requested, referring page, and timestamps.

We do not collect financial account details, and the Site does not require you to create an account.

3. Why we use it and on what basis

• Responding to enquiries — to answer your briefing request and correspond with you about it. Basis: steps taken at your request prior to entering into an agreement, and our legitimate interest in responding to institutional enquiries.
• Pilot evaluation — to assess whether, and how, your institution might participate in a controlled pilot. Basis: legitimate interest.
• Newsletter — to send NETTA Insights to subscribers. Basis: your consent, which you may withdraw at any time using the unsubscribe link in every email.
• Site operation and security — to run, secure and monitor the Site using server logs. Basis: legitimate interest.
• Legal obligations — to comply with law and respond to lawful requests. Basis: legal obligation.

4. Who processes data on our behalf

We use the following service providers, each of which processes data only on our instructions and under its own security commitments:

• Our hosting and content-delivery provider — hosting, content delivery, security and server logs for the Site.
• A form-delivery service — delivery of briefing-request form submissions to our mailbox.
• A newsletter service — newsletter subscription and delivery. The subscription form embedded on Insights pages is provided by that service and may set its own cookies.

We may also share personal data with our professional advisers and, where required, with courts, regulators and law-enforcement authorities. We do not sell personal data and we do not share it for third-party marketing.

5. Cookies

The Site does not set analytics or advertising cookies. Our hosting provider may set strictly necessary cookies for security and performance. The newsletter subscription embed on Insights pages is delivered by our newsletter service and may set its own cookies; those are governed by that service's privacy notice. You can block or delete cookies through your browser settings.

6. How long we keep it

• Briefing requests and related correspondence: 24 months from our last contact with you, unless a written agreement follows, in which case the data is retained for the life of that agreement and any period required by law.
• Newsletter email addresses: until you unsubscribe.
• Server logs: for the period set by our hosting provider.

7. International transfers

The Foundation is established in the Cayman Islands and our service providers operate in the United States and other countries. Where personal data is transferred out of the jurisdiction in which it was collected, we rely on the safeguards available under applicable law, including the providers' standard contractual commitments.

8. Your rights

Depending on where you are, you may have rights under the EU General Data Protection Regulation, the UK GDPR, the UAE Personal Data Protection Law, the Cayman Islands Data Protection Act or other applicable law. These may include the right to access the personal data we hold about you, to have it corrected or erased, to restrict or object to its processing, to receive a copy in a portable form, and to withdraw consent where processing is based on consent.

To exercise any of these rights, email privacy@netta.network. We will respond within the period required by the applicable law. You also have the right to complain to the data protection authority in your jurisdiction.

9. Security

We apply appropriate technical and organisational measures to protect personal data, including access controls and transport encryption. No transmission over the internet can be guaranteed to be secure.

10. Changes to this notice

We may update this notice from time to time. The current version, with its effective date, is always available on this page.

11. Contact

FiatRails Foundation Ltd, Landmark Square, Camana Bay, Grand Cayman, Cayman Islands. privacy@netta.network