mySabura

Escrow Platform for Small Businesses

PRIVACY POLICY

Effective Date: March 19, 2026

Last Updated: March 19, 2026

Welcome to mySabura. We are committed to protecting your personal and business information with the highest standards of privacy and security. This Privacy Policy explains how mySabura ("we", "our", or "the Platform") collects, uses, stores, shares, and safeguards your data when you use our escrow services designed for small businesses and independent entrepreneurs.

By accessing or using mySabura, you agree to the practices described in this Privacy Policy. If you do not agree, please discontinue use of the Platform.

1. Who We Are

mySabura is a digital escrow platform that facilitates secure financial transactions between buyers and sellers, with a focus on small business commerce, freelance services, and peer-to-peer trade. Our services include holding funds in trust, milestone-based payment release, dispute mediation, and transaction verification.

For questions about this policy or your data, you may contact our Privacy Team at:

• Email: privacy@mysabura.com
• Address: [Registered Business Address]
• Support Portal: support.mysabura.com

2. Information We Collect

We collect information to provide, secure, and improve the mySabura escrow service. The categories of data we collect include:

2.1 Account & Identity Information

• Full legal name and business name (if applicable)
• Email address and phone number
• Username and password (stored in encrypted form)
• Date of birth (for age verification and KYC compliance)
• Government-issued identification documents (e.g., passport, national ID, trade license)

2.2 Business & Financial Information

• Business registration number and jurisdiction
• Bank account details or payment method information
• Tax identification numbers where required by law
• Transaction history, amounts held, and payment records

2.3 Transaction Data

• Details of escrow agreements created between parties
• Milestone descriptions, terms, and completion status
• Dispute records, communications, and resolution outcomes
• Timestamps and activity logs associated with transactions

2.4 Technical & Usage Data

• IP address, browser type, and device identifiers
• Pages visited, features used, and session duration
• Cookies and similar tracking technologies
• Crash reports and diagnostic data

2.5 Communications

• Messages exchanged through the mySabura in-platform messaging system
• Support tickets, feedback submissions, and survey responses
• Email correspondence with our team

3. How We Use Your Information

We use your information for the following purposes:

3.1 Providing Escrow Services

• To verify the identity of users and businesses before funds are held or released
• To create, manage, and enforce escrow agreements between parties
• To process payments, hold funds in trust, and release them upon agreed conditions
• To facilitate milestone tracking and verification

3.2 Compliance & Legal Obligations

• To comply with Anti-Money Laundering (AML) and Know Your Customer (KYC) regulations
• To meet financial reporting obligations and respond to regulatory inquiries
• To detect and prevent fraud, unauthorized transactions, and platform abuse
• To retain records as required by applicable law

3.3 Platform Operations & Improvement

• To maintain platform security, performance, and reliability
• To analyze usage patterns and improve our features
• To conduct internal audits and quality assurance

3.4 Communication & Support

• To send transaction confirmations, alerts, and status updates
• To notify you of changes to policies, terms, or platform features
• To respond to support requests and resolve disputes
• To send marketing communications, where you have opted in

4. Legal Basis for Processing

We process your personal data on the following legal grounds:

• Contractual necessity: To provide the escrow services you have signed up for and to fulfil our obligations under our Terms of Service.
• Legal obligation: To comply with financial regulations, anti-fraud laws, and government requirements applicable to escrow service providers.
• Legitimate interests: To protect the security of the platform, detect misuse, and improve our services in a way that does not override your rights.
• Consent: Where we ask for your explicit consent, such as for marketing communications or optional data sharing with third parties.

5. How We Share Your Information

mySabura does not sell your personal data. We share information only in the following circumstances:

5.1 With Other Parties in a Transaction

To enable an escrow transaction, limited information — such as your name, business name, and transaction reference — may be shared with the other party in the agreement. This is necessary for the escrow to function.

5.2 With Service Providers

We may share data with trusted third-party vendors who assist in operating the platform, including:

• Payment processors and banking partners for fund management
• Identity verification and KYC/AML compliance providers
• Cloud infrastructure and data hosting providers
• Customer support and communication platforms

All service providers are bound by data processing agreements and are prohibited from using your data for their own purposes.

5.3 Legal & Regulatory Disclosure

We may disclose your information when required by law, court order, or regulatory authority, including financial intelligence units, law enforcement agencies, or dispute resolution bodies with jurisdiction over escrow services.

5.4 Business Transfers

In the event of a merger, acquisition, or sale of all or part of the mySabura business, your data may be transferred to the acquiring entity, subject to the same privacy protections described in this policy.

6. Data Retention

We retain your personal and transaction data for as long as your account is active and for a period thereafter as required by law. Specifically:

• Account data is retained for the duration of your account and for a minimum of 5 years after account closure, in line with financial recordkeeping obligations.
• Transaction records are retained for a minimum of 7 years to satisfy anti-money laundering regulations.
• Identity verification documents are retained as required by applicable KYC regulations.
• Technical logs and cookies data are retained for a shorter period unless otherwise required.

When data is no longer required, we securely delete or anonymize it in accordance with our data destruction policy.

7. Data Security

mySabura applies industry-standard security measures to protect your data at rest and in transit. Our security practices include:

• AES-256 encryption for all stored sensitive data
• TLS encryption for all data transmitted over the internet
• Multi-factor authentication (MFA) for account access
• Role-based access controls limiting internal data access on a need-to-know basis
• Regular security audits, penetration testing, and vulnerability assessments
• Incident response procedures in the event of a data breach

In the unlikely event of a data breach affecting your rights and freedoms, we will notify affected users and the relevant supervisory authority within the timeframe required by applicable law.

8. Cookies & Tracking Technologies

mySabura uses cookies and similar technologies to operate and improve the platform. You can control cookie settings through your browser. The types of cookies we use include:

• Essential cookies: Required for core platform functions such as login sessions and security.
• Analytics cookies: Used to understand how users interact with the platform so we can improve it.
• Preference cookies: Used to remember your settings and language preferences.
• Marketing cookies: Used where you have consented to receive relevant advertising.

You may withdraw consent for non-essential cookies at any time through our Cookie Preferences Centre.

9. Your Privacy Rights

Depending on your jurisdiction, you may have the following rights regarding your personal data:

• Right of Access: To request a copy of the personal data we hold about you.
• Right to Rectification: To request correction of inaccurate or incomplete information.
• Right to Erasure: To request deletion of your data, subject to legal retention requirements.
• Right to Restriction: To request that we limit how we process your data in certain circumstances.
• Right to Data Portability: To receive your data in a structured, machine-readable format.
• Right to Object: To object to processing based on legitimate interests or for direct marketing purposes.
• Right to Withdraw Consent: To withdraw consent at any time where processing is based on consent.

To exercise any of these rights, please contact us at privacy@mysabura.com. We will respond to all verifiable requests within 30 days. We may require identity verification before processing your request.

10. International Data Transfers

mySabura may process or store your data in countries outside your country of residence. Where data is transferred internationally, we ensure appropriate safeguards are in place, such as standard contractual clauses approved by relevant regulatory authorities, or transfers to countries recognized as providing adequate data protection.

11. Users Under the Age of 18

mySabura is a financial services platform designed exclusively for use by adults and registered businesses. We do not knowingly collect personal data from anyone under the age of 18. If you believe a minor has created an account on mySabura, please contact us immediately at privacy@mysabura.com and we will take appropriate action.

12. Third-Party Links & Integrations

The mySabura platform may contain links to third-party websites or integrate with external services (such as banking portals or accounting tools). This Privacy Policy does not cover those third-party services. We encourage you to review the privacy policies of any third-party platforms you interact with through or alongside mySabura.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in the law, our services, or our data practices. When we make material changes, we will notify you via email or a prominent notice on the platform at least 14 days before the changes take effect. Your continued use of mySabura after the effective date of the updated policy constitutes your acceptance of the revised terms.

14. Governing Law & Jurisdiction

This Privacy Policy is governed by the laws of [Jurisdiction], without regard to conflict of law principles. Any disputes arising from or related to this Privacy Policy shall be subject to the exclusive jurisdiction of the courts of [Jurisdiction].

15. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or your personal data, please contact:

mySabura Privacy Team

• Email: privacy@mysabura.com
• Support: support.mysabura.com
• Address: [Registered Business Address]

© 2026 mySabura. All rights reserved. This document is for informational purposes and does not constitute legal advice.

Escrow Platform for Small Businesses

PRIVACY POLICY

Effective Date: March 19, 2026

Last Updated: March 19, 2026

Welcome to mySabura. We are committed to protecting your personal and business information with the highest standards of privacy and security. This Privacy Policy explains how mySabura ("we", "our", or "the Platform") collects, uses, stores, shares, and safeguards your data when you use our escrow services designed for small businesses and independent entrepreneurs.

By accessing or using mySabura, you agree to the practices described in this Privacy Policy. If you do not agree, please discontinue use of the Platform.

1. Who We Are

mySabura is a digital escrow platform that facilitates secure financial transactions between buyers and sellers, with a focus on small business commerce, freelance services, and peer-to-peer trade. Our services include holding funds in trust, milestone-based payment release, dispute mediation, and transaction verification.

For questions about this policy or your data, you may contact our Privacy Team at:

• Email: privacy@mysabura.com
• Address: [Registered Business Address]
• Support Portal: support.mysabura.com

2. Information We Collect

We collect information to provide, secure, and improve the mySabura escrow service. The categories of data we collect include:

2.1 Account & Identity Information

• Full legal name and business name (if applicable)
• Email address and phone number
• Username and password (stored in encrypted form)
• Date of birth (for age verification and KYC compliance)
• Government-issued identification documents (e.g., passport, national ID, trade license)

2.2 Business & Financial Information

• Business registration number and jurisdiction
• Bank account details or payment method information
• Tax identification numbers where required by law
• Transaction history, amounts held, and payment records

2.3 Transaction Data

• Details of escrow agreements created between parties
• Milestone descriptions, terms, and completion status
• Dispute records, communications, and resolution outcomes
• Timestamps and activity logs associated with transactions

2.4 Technical & Usage Data

• IP address, browser type, and device identifiers
• Pages visited, features used, and session duration
• Cookies and similar tracking technologies
• Crash reports and diagnostic data

2.5 Communications

• Messages exchanged through the mySabura in-platform messaging system
• Support tickets, feedback submissions, and survey responses
• Email correspondence with our team

3. How We Use Your Information

We use your information for the following purposes:

3.1 Providing Escrow Services

• To verify the identity of users and businesses before funds are held or released
• To create, manage, and enforce escrow agreements between parties
• To process payments, hold funds in trust, and release them upon agreed conditions
• To facilitate milestone tracking and verification

3.2 Compliance & Legal Obligations

• To comply with Anti-Money Laundering (AML) and Know Your Customer (KYC) regulations
• To meet financial reporting obligations and respond to regulatory inquiries
• To detect and prevent fraud, unauthorized transactions, and platform abuse
• To retain records as required by applicable law

3.3 Platform Operations & Improvement

• To maintain platform security, performance, and reliability
• To analyze usage patterns and improve our features
• To conduct internal audits and quality assurance

3.4 Communication & Support

• To send transaction confirmations, alerts, and status updates
• To notify you of changes to policies, terms, or platform features
• To respond to support requests and resolve disputes
• To send marketing communications, where you have opted in

4. Legal Basis for Processing

We process your personal data on the following legal grounds:

• Contractual necessity: To provide the escrow services you have signed up for and to fulfil our obligations under our Terms of Service.
• Legal obligation: To comply with financial regulations, anti-fraud laws, and government requirements applicable to escrow service providers.
• Legitimate interests: To protect the security of the platform, detect misuse, and improve our services in a way that does not override your rights.
• Consent: Where we ask for your explicit consent, such as for marketing communications or optional data sharing with third parties.

5. How We Share Your Information

mySabura does not sell your personal data. We share information only in the following circumstances:

5.1 With Other Parties in a Transaction

To enable an escrow transaction, limited information — such as your name, business name, and transaction reference — may be shared with the other party in the agreement. This is necessary for the escrow to function.

5.2 With Service Providers

We may share data with trusted third-party vendors who assist in operating the platform, including:

• Payment processors and banking partners for fund management
• Identity verification and KYC/AML compliance providers
• Cloud infrastructure and data hosting providers
• Customer support and communication platforms

All service providers are bound by data processing agreements and are prohibited from using your data for their own purposes.

5.3 Legal & Regulatory Disclosure

We may disclose your information when required by law, court order, or regulatory authority, including financial intelligence units, law enforcement agencies, or dispute resolution bodies with jurisdiction over escrow services.

5.4 Business Transfers

In the event of a merger, acquisition, or sale of all or part of the mySabura business, your data may be transferred to the acquiring entity, subject to the same privacy protections described in this policy.

6. Data Retention

We retain your personal and transaction data for as long as your account is active and for a period thereafter as required by law. Specifically:

• Account data is retained for the duration of your account and for a minimum of 5 years after account closure, in line with financial recordkeeping obligations.
• Transaction records are retained for a minimum of 7 years to satisfy anti-money laundering regulations.
• Identity verification documents are retained as required by applicable KYC regulations.
• Technical logs and cookies data are retained for a shorter period unless otherwise required.

When data is no longer required, we securely delete or anonymize it in accordance with our data destruction policy.

7. Data Security

mySabura applies industry-standard security measures to protect your data at rest and in transit. Our security practices include:

• AES-256 encryption for all stored sensitive data
• TLS encryption for all data transmitted over the internet
• Multi-factor authentication (MFA) for account access
• Role-based access controls limiting internal data access on a need-to-know basis
• Regular security audits, penetration testing, and vulnerability assessments
• Incident response procedures in the event of a data breach

In the unlikely event of a data breach affecting your rights and freedoms, we will notify affected users and the relevant supervisory authority within the timeframe required by applicable law.

8. Cookies & Tracking Technologies

mySabura uses cookies and similar technologies to operate and improve the platform. You can control cookie settings through your browser. The types of cookies we use include:

• Essential cookies: Required for core platform functions such as login sessions and security.
• Analytics cookies: Used to understand how users interact with the platform so we can improve it.
• Preference cookies: Used to remember your settings and language preferences.
• Marketing cookies: Used where you have consented to receive relevant advertising.

You may withdraw consent for non-essential cookies at any time through our Cookie Preferences Centre.

9. Your Privacy Rights

Depending on your jurisdiction, you may have the following rights regarding your personal data:

• Right of Access: To request a copy of the personal data we hold about you.
• Right to Rectification: To request correction of inaccurate or incomplete information.
• Right to Erasure: To request deletion of your data, subject to legal retention requirements.
• Right to Restriction: To request that we limit how we process your data in certain circumstances.
• Right to Data Portability: To receive your data in a structured, machine-readable format.
• Right to Object: To object to processing based on legitimate interests or for direct marketing purposes.
• Right to Withdraw Consent: To withdraw consent at any time where processing is based on consent.

To exercise any of these rights, please contact us at privacy@mysabura.com. We will respond to all verifiable requests within 30 days. We may require identity verification before processing your request.

10. International Data Transfers

mySabura may process or store your data in countries outside your country of residence. Where data is transferred internationally, we ensure appropriate safeguards are in place, such as standard contractual clauses approved by relevant regulatory authorities, or transfers to countries recognized as providing adequate data protection.

11. Users Under the Age of 18

mySabura is a financial services platform designed exclusively for use by adults and registered businesses. We do not knowingly collect personal data from anyone under the age of 18. If you believe a minor has created an account on mySabura, please contact us immediately at privacy@mysabura.com and we will take appropriate action.

12. Third-Party Links & Integrations

The mySabura platform may contain links to third-party websites or integrate with external services (such as banking portals or accounting tools). This Privacy Policy does not cover those third-party services. We encourage you to review the privacy policies of any third-party platforms you interact with through or alongside mySabura.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in the law, our services, or our data practices. When we make material changes, we will notify you via email or a prominent notice on the platform at least 14 days before the changes take effect. Your continued use of mySabura after the effective date of the updated policy constitutes your acceptance of the revised terms.

14. Governing Law & Jurisdiction

This Privacy Policy is governed by the laws of [Jurisdiction], without regard to conflict of law principles. Any disputes arising from or related to this Privacy Policy shall be subject to the exclusive jurisdiction of the courts of [Jurisdiction].

15. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or your personal data, please contact:

mySabura Privacy Team

• Email: privacy@mysabura.com
• Support: support.mysabura.com
• Address: [Registered Business Address]

© 2026 mySabura. All rights reserved. This document is for informational purposes and does not constitute legal advice.