Effective Date: 25th August, 2026

www.bankability.co (the "Site") and the BankAbility application (the "App") are owned and operated by Digital Ability Ltd. Digital Ability Ltd is the data controller and can be contacted at: hello@bankability.co, or you can write to us at Digital Ability Ltd, 71-75 Shelton Street, London WC2H 9JQ.

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Purpose

The purpose of this Privacy Policy is to explain how we collect, use and protect personal data when you use our Site or App:

·     The personal data we will collect

·     Use of collected data

·     Who has access to the data collected

·     The rights of Site users

·     The Site's cookie policy

This Privacy Policy applies in addition to any other terms and conditions of our Site.

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GDPR

For users in the European Union, we adhere to the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, known as the General Data Protection Regulation (the "GDPR"). For users in the United Kingdom, we adhere to the GDPR as enshrined in the Data Protection Act 2018. We have not appointed a Data Protection Officer as we do not fall within the categories of controllers and processors required to appoint a Data Protection Officer under Article 37 of the GDPR.

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Consent

By using our Site users agree that they consent to the conditions set out in this Privacy Policy.

When the legal basis for us processing your personal data is that you have provided your consent to that processing, you may withdraw your consent at any time. If you withdraw your consent, it will not make processing which we completed before you withdrew your consent unlawful.

You can withdraw your consent by contacting the Privacy Officer.

Legal Basis for Processing

We only collect and process personal data where we have a lawful basis for doing so under UK data protection law.

Where we rely on your consent to process personal data, you can withdraw your consent at any time.

Some information you choose to provide, or information generated through optional features such as eye-tracking, may be treated as special category personal data. Where we process special category personal data based on your consent, we will ask for your explicit consent in accordance with Article 9 of the UK GDPR.

You can withdraw your consent at any time. This will not affect the lawfulness of any processing carried out before your consent was withdrawn.

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Personal Data We Collect

We only collect data that helps us achieve the purpose set out in this Privacy Policy. We will not collect any additional data beyond the data listed below without notifying you first.

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Data Collected Automatically

When you visit and use our Site, we may automatically collect and store the following information:

·     IP address

·     Location

·     Hardware and software details

·     Clicked links

·     Content viewed

·     Data Collected in a Non-Automatic Way

We may also collect the following data when you perform certain functions on our Site:

·     First and last name

·     Email address

·     Organisation Name

·     Contact Message

This data may be collected using the following methods:

·     Subscribing to news updates; and

·     Submitting a contact request.

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Eye-tracking and gaze data

BankAbility includes an optional eye-tracking session. Eye-tracking only takes place when you choose to start one of these sessions and does not take place during your normal use of the App.

During an eye-tracking session, BankAbility may collect and store gaze and interaction data. We analyse this information to help identify accessibility and interface adjustments that may make the App easier or more comfortable for you to use.

The information is used to recommend potential user interface adjustments. It is not used to diagnose a medical or health condition.

We use eye-tracking and gaze information only to:

• support the eye-tracking session and associated interactions;

• personalise how content, controls and calls-to-action are presented;

• recommend accessibility and interface adjustments; and

• improve the accessibility and user experience of BankAbility.

Because information collected or generated through this process may reveal information about your accessibility needs, we treat it with additional protection and, where applicable, as special category personal data.

We do not use eye-tracking, gaze data or resulting accessibility recommendations to make financial decisions, assess your financial circumstances or creditworthiness, determine your eligibility for financial products or services, verify your identity, or monitor you for security purposes.

Eye-tracking is not used as a biometric identification or authentication system, and we do not sell eye-tracking or gaze information or share it with third parties.

How We Use Personal Data

Data collected on our Site will only be used for the purposes specified in this Privacy Policy or indicated on the relevant pages of our Site. We will not use your data beyond what we disclose in this Privacy Policy.

The data we collect automatically is used for for analytics purposes to improve user accessibility, content relevance and analyse statistics.

The data we collect when the user performs certain functions may be used for communicating with users.

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Who We Share Personal Data With

·         Employees

·         We may disclose user data to any member of our organisation who reasonably needs access to user data to achieve the purposes set out in this Privacy Policy.

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Other Disclosures

We will not sell or share your data with other third parties, except in the following cases:

·     If the law requires it

·     If it is required for any legal proceeding

·     To prove or protect our legal rights

·     To buyers or potential buyers of this company in the event that we seek to sell the company

If you follow hyperlinks from our Site to another Site, please note that we are not responsible for and have no control over their privacy policies and practices.

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How Long We Store Personal Data

User data will be stored for five years. You will be notified if your data is kept for longer than this period.

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How We Protect Your Personal Data

In order to protect your security, we use the strongest available browser encryption and store all of our data on servers in secure facilities. All data is only accessible to our employees. Our employees are bound by strict confidentiality agreements and a breach of this agreement would result in the employee's termination.

While we take all reasonable precautions to ensure that user data is secure and that users are protected, there always remains the risk of harm. The Internet as a whole can be insecure at times and therefore we are unable to guarantee the security of user data beyond what is reasonably practical.

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Your Rights as a User

Under the GDPR, you have the following rights:

·     Right to be informed

·     Right of access

·     Right to rectification

·     Right to erasure

·     Right to restrict processing

·     Right to data portability

·     Right to object.

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Children

We do not knowingly collect or use personal data from children under 16 years of age. If we learn that we have collected personal data from a child under 16 years of age, the personal data will be deleted as soon as possible. If a child under 16 years of age has provided us with personal data their parent or guardian may contact our privacy officer.

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How to Access, Modify, Delete, or Challenge the Data Collected

If you would like to know if we have collected your personal data, how we have used your personal data, if we have disclosed your personal data and to who we disclosed your personal data, if you would like your data to be deleted or modified in any way, or if you would like to exercise any of your other rights under the GDPR, please contact our privacy officer, David Agar, here: hello@bankability.co, or you can write to us at Digital Ability Ltd, 71-75 Shelton Street, London WC2H 9JQ.