> For the complete documentation index, see [llms.txt](https://docs.aaable.io/llms.txt). Markdown versions of documentation pages are available by appending `.md` to page URLs; this page is available as [Markdown](https://docs.aaable.io/legal-terms/privacy-policy.md). # Privacy Policy **AAABLE, Inc. Privacy Policy** *Last Updated: August 2026* This Privacy Policy describes how AAABLE, Inc. and its applicable affiliates (collectively, "AAABLE," "we," "us," or "our") collects, uses, stores, shares, and protects your information. This Privacy Policy describes our practices in connection with information collected through our website, aaable.io, and other AAABLE services or products (the "AAABLE Services"). This Privacy Policy provides a general overview of our privacy practices. It should be read together with any other privacy notice or fair processing notice we may provide on specific occasions, which may be applicable to you when we collect or process personal data about you. This Privacy Policy supplements those notices and is not intended to override them. Jurisdiction-specific information for individuals residing in the European Economic Area ("EEA"), the United Kingdom, and Switzerland is set out at the end of this Privacy Policy. **1. Overview** We know how important privacy is to the institutions and individuals we work with, which is why this Privacy Policy explains how we collect and use data. AAABLE, Inc. does not itself custody digital assets, hold user funds, or act as the issuer of aaaUSD. aaaUSD is issued by Anchorage Digital Bank, N.A. under its own regulatory authorizations, using M0's infrastructure. Where you interact directly with Anchorage, M0, or another regulated third party in connection with minting, redeeming, or holding aaaUSD, that party's own privacy policy governs the personal data you provide to them. This Privacy Policy governs only the data we collect through our own Site and Services. **2. The Data We Collect About You** Personal data means any information about an individual from which that person can be identified. It does not include data where identity has been removed (anonymous data). We may collect, use, store, and transfer, or use third-party services to collect, use, store, and transfer, the following categories of personal data: Identity Data - first name, middle name, last name, title, tax ID, date of birth, nationality, identity document number, and other information contained in identification documents you provide (e.g., passport or driver's license). Contact Data - business address, residential address, email address, and telephone number. Financial Data - bank account details and wallet address information relevant to institutional onboarding. Transaction Data - details of your activity in connection with AAABLE Services, including counterparty, amount, date, and time, to the extent such information is provided to or collected by us directly (as distinct from on-chain data, which is public). Technical Data - internet protocol (IP) address, login data, browser type and version, time zone, browser plug-in types, operating system, and platform. Profile Data - username, password, preferences, feedback, and survey responses. Usage Data - information about how you use the AAABLE Services and Site. Marketing and Communications Data - your preferences in receiving communications from us and your communication preferences. Survey and Customer Feedback Data - information you provide in any survey or feedback form. Location Data - information about your device location, where applicable. We also collect and use Aggregated Data, such as statistical or demographic data, for any purpose. Aggregated Data may be derived from personal data but is not itself personal data, as it does not directly or indirectly identify you. If we combine Aggregated Data with personal data such that it identifies you, we treat the combined data as personal data under this Privacy Policy. We do not collect Special Categories of Personal Data (race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, health data, or genetic or biometric data). **Information about criminal convictions** Where you engage with AAABLE in a due diligence, onboarding, or institutional partnership context, we may receive information about criminal convictions as part of standard verification or compliance checks. We carry out these checks to detect or prevent unlawful or fraudulent activity and to comply with our legal obligations. **If you fail to provide personal data** Where we need to collect personal data by law or under a contract with you, and you fail to provide it, we may be unable to perform that contract or provide the relevant Services. We will notify you if this is the case. **3. How We Collect Your Personal Data** Direct interactions. You may provide Identity, Contact, Financial, Transaction, Profile, Usage, Marketing and Communications, and Location Data by completing forms or corresponding with us by email, post, or otherwise - including when we request information to verify your identity, meet legal obligations, or evaluate an institutional relationship; when you request marketing communications; when you participate in a survey; or when you provide feedback. Automated technologies. When you interact with our Site, we may automatically collect Usage and Technical Data through cookies, server logs, and similar technologies. See our Cookie Policy for further detail. Third parties and publicly available sources. We may receive personal data from analytics providers, technical or infrastructure service providers, verification and compliance service providers, and - where relevant to institutional counterparties - from Anchorage Digital or other regulated partners in connection with joint due diligence. If you provide us with personal data of any individual other than yourself, you confirm that you have obtained that individual's consent to disclose their personal data to us for the purposes described in this Privacy Policy. **4. How We Use Your Personal Data** We collect the information described in Section 2 to provide the AAABLE Services. This allows us to: Deliver the functionality of the AAABLE Services and Site; Communicate with you - including customer or institutional support, updates on product developments, and security notices; Verify your identity to prevent fraud or unauthorized activity and comply with applicable law, including sanctions screening and know-your-customer requirements relevant to institutional engagement; and Fulfil any other purpose for which the information was collected. We may combine your information with information from other sources to improve and personalize the AAABLE Services and our content. **Purposes for which we use your personal data** We rely on the following legal bases, as applicable: performance of a contract with you; compliance with a legal or regulatory obligation; our legitimate interests, provided these are not overridden by your rights; or your consent. "Legitimate interest" means our interest in conducting and managing our business to provide the best service and the most secure experience, balanced against any impact on you. Contact if you would like further detail on the specific basis relied on for a given activity. | Purpose/Activity | Data Type | Lawful Basis | | -------------------------------------------------------------------------------------------------- | ------------------------------------------------------------------------------- | ------------------------------------------------------------------------------------------------ | | To register you or your institution as a counterparty | Identity, Contact | Performance of a contract | | To deliver the AAABLE Services | Identity, Contact, Financial, Transaction, Profile, Marketing, Location | Performance of a contract | | To manage our relationship with you (e.g., notifying you of changes to terms, requesting feedback) | Identity, Contact, Profile, Marketing | Performance of a contract; legal obligation; legitimate interest (record-keeping) | | To verify identity and detect/prevent fraud or unauthorized activity | Identity, Contact, Financial, Transaction, Usage | Performance of a contract; legal obligation; legitimate interest (safeguarding the Services) | | To administer and protect the Site and Services (troubleshooting, testing, hosting, security) | Identity, Contact, Technical | Legitimate interest (running our business, network security, fraud prevention); legal obligation | | To deliver relevant content and measure engagement | Identity, Contact, Profile, Usage, Marketing, Technical | Legitimate interest (understanding usage, informing strategy) | | To use data analytics to improve the Site, Services, and institutional relationships | Identity, Contact, Technical, Usage | Legitimate interest (product and business development) | | To improve or develop new products and services | Identity, Contact, Financial, Transaction, Technical, Profile, Usage, Marketing | Legitimate interest (product and business development) | | To make relevant suggestions about products or services | Identity, Contact, Technical, Profile, Usage, Marketing | Legitimate interest (marketing and business development) | **Change of purpose** We will only use your personal data for the purposes described in this Privacy Policy, or as otherwise permitted under applicable law. If we need to use your data for an unrelated purpose, we will notify you and explain the legal basis relied upon. **Third-party links** The Site may include links to third-party websites, including Anchorage Digital, M0, and other infrastructure or institutional partners. We are not responsible for the data practices of those third parties. Please review the privacy policy of any third-party site you visit. **5. Marketing** We may use your Identity, Contact, Technical, Profile, and Usage Data to determine which products, services, or updates may be relevant to you. You will receive marketing communications from us if you have requested information, used the AAABLE Services, or provided your details in connection with an event, promotion, or engagement, and have not opted out. We will obtain your express opt-in consent before sharing your personal data with any company outside the AAABLE group for marketing purposes. **6. Cookies** You can configure your browser to refuse some or all cookies, or to alert you when cookies are set. If you disable cookies, some parts of the Site may not function properly. We do not currently respond to Do Not Track ("DNT") browser signals. See our Cookie Policy for further detail. **7. How We Share Your Personal Data** We may share your personal data with the following categories of recipients, for the purposes described in Section 4: Verification service providers - to detect and prevent fraud and comply with legal obligations, including identity verification and sanctions screening providers. Regulated infrastructure partners - including Anchorage Digital Bank, N.A. and M0, where necessary to facilitate institutional engagement, onboarding, or the issuance, custody, or redemption of aaaUSD. These parties process data under their own regulatory authorizations and privacy policies. Operational service providers - providers of data storage, onboarding, customer support platforms, accounting, IT, communications, security, and fraud detection services necessary to deliver the AAABLE Services. Analytics and marketing service providers - to help us understand usage of the AAABLE Services and, where applicable, to support marketing campaigns. Law enforcement agencies and regulators - where compelled by law, subpoena, court order, or formal regulatory request, or where we believe in good faith that disclosure is necessary to prevent harm or comply with reporting obligations. We aim to disclose only the minimum information necessary. Group companies - including any AAABLE affiliates or the AAABLE Foundation established in connection with the $ABLE token, where necessary to meet legal, regulatory, or operational requirements. Professional advisers - including legal, compliance, accounting, and audit firms (such as Deloitte in connection with attestation services), where necessary to complete audits, attestations, or advisory engagements, or to comply with our legal obligations. Business partners - where you transact or interact with a business partner of AAABLE, we may share relevant status information (such as name, email, and institutional affiliation) to the extent necessary for that partner to meet its own legal and regulatory obligations. Parties to a business transaction - if AAABLE is involved in a merger, acquisition, financing, or sale of assets, your personal data may be shared with and used by the relevant counterparty in accordance with this Privacy Policy. Parties you authorize - we will share your data with any other third party where you specifically direct or authorize us to do so. Sub-processors - a list of AAABLE's sub-processors is available upon request by contacting . By agreeing to this Privacy Policy, you consent to such sub-processors collecting and processing your personal data on our behalf, consistent with this Policy. **8. International Transfers** AAABLE operates internationally, and personal data may be stored and processed in any country where we or our service providers operate, including the United States and the United Kingdom. Where we transfer personal data from the EEA, UK, or Switzerland to a country not deemed to offer an adequate level of data protection, we rely on Standard Contractual Clauses (SCCs) or another lawful transfer mechanism. **9. How We Protect Your Personal Data** We use physical, technical, and administrative security measures designed to reduce the risk of loss, misuse, unauthorized access, disclosure, or alteration of your personal data, including encryption, access controls, and firewalls. Certain personal data may be stored with trusted third-party service providers for the purposes described in this Privacy Policy. **10. Data Retention** We retain personal data only as long as necessary to fulfil the purposes for which it was collected, including to satisfy legal, accounting, tax, or regulatory requirements - which, for institutional counterparties, may include recordkeeping obligations under applicable financial services or anti-money laundering regulations. We consider the amount, nature, and sensitivity of the data, the risk of harm from unauthorized use or disclosure, whether we can achieve our purposes by other means, and applicable legal requirements when determining retention periods. **11. Children's Privacy** The AAABLE Services are not directed to, and may not be used by, anyone under 18. We do not knowingly collect personal data from anyone under 18. If we become aware that we have collected personal data from a person under 18, we will delete it promptly. **12. Changes to This Privacy Policy** We may update this Privacy Policy from time to time. Material changes will be indicated by updating the date at the top of this Policy, and, where the change is significant, by notification or a notice posted on our Site. Please contact with any questions about changes to this Privacy Policy. It is important that the personal data we hold about you is accurate and current. Please notify if your details change. **Customers in the EEA, UK, and Switzerland** This section applies to individuals in the EEA, UK, and Switzerland, and supplements the rest of this Privacy Policy. We most commonly rely on the following legal bases: performance of a contract with you; our legitimate interests (or those of a third party), balanced against your rights; compliance with a legal or regulatory obligation; or your explicit consent. We generally do not rely on consent other than for third-party direct marketing communications by email or text, which you may withdraw at any time by contacting . For purposes of the General Data Protection Regulation (EU) 2016/679 ("GDPR"), the UK Data Protection Act 2018, the UK GDPR, and the Swiss Federal Act on Data Protection, AAABLE, Inc. is the controller of your personal data. **Your legal rights** Subject to applicable law, you have the right to: Request access - receive confirmation of whether we process your personal data, and a copy of that data. Request correction - have inaccurate or incomplete data corrected. Contact to add or amend your information. Request deletion - ask us to delete personal data where there is no good reason for us to continue processing it, where you have successfully objected to processing, where we have processed it unlawfully, or where deletion is required to comply with applicable law. This right does not apply where we must retain data to comply with a legal obligation or to establish, exercise, or defend a legal claim. We will notify you if we are unable to comply with a deletion request. Object to processing - object to processing based on our legitimate interests, or to processing for direct marketing purposes. We may demonstrate compelling legitimate grounds that override your rights in some cases. Request restriction of processing - ask us to suspend processing while we verify accuracy, assess an objection, or where processing is unlawful but you do not want the data deleted, or where you need us to retain data to establish, exercise, or defend a legal claim. Request data portability - receive your personal data in a structured, commonly used, machine-readable format, or ask us to transmit it to a third party, where processing is based on consent or contract and carried out by automated means. Withdraw consent - where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of processing carried out before withdrawal. This may affect our ability to provide certain Services, and we will advise you if so. You will not usually have to pay a fee to exercise these rights, though we may charge a reasonable fee, or decline the request, where it is clearly unfounded, repetitive, or excessive. We may need to request specific information from you to confirm your identity before actioning a request. We aim to respond to legitimate requests within one month, or as required by applicable law; more complex requests may take longer, in which case we will notify you. **How to Contact Us** You may contact us regarding this Privacy Policy by email at: --- # Agent Instructions This documentation is published with GitBook. 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