Website Privacy Policy

Effective date: October 1, 2026

1. Who we are and what this policy covers

Guilder Financial LLC, a Texas limited liability company, operates the website www.guilder.money. In this policy, “we”, “us” and “our” mean Guilder Financial LLC. We are responsible for deciding how information collected through the website, launch-update sign-up and business-interest forms is used.

Guilder Payment Solutions Limited is a separate group company incorporated in Zambia under registration number 120210024561. It operates Vuna Voucher in Zambia. This policy concerns the Texas company’s website activities, not an application for a payment account or identity verification.

We handle information under the privacy, security and electronic-communications laws applicable to the activity. Our Texas establishment does not remove protections that apply to people in Zambia or elsewhere. This policy is also the “Privacy Notice” linked from our forms; it is not blanket consent.

2. Our live pre-launch forms

“Be part of the Vuna launch.” This form lets you subscribe to emails about the Vuna launch, including confirmed launch locations, buying channels and redemption partners. Providing your town or area is optional.

“Bring Vuna to your business.” This form lets you enquire about selling or accepting Vuna. We use the information to respond and discuss your interest. A separate optional checkbox covers promotional emails. Registering interest does not approve you as a partner or create a payment account.

Submitting a live form sends the information to us for the purposes described here. You do not need KYC verification to browse the website or submit these forms. Please do not send identity documents, dates of birth, bank or card details, passwords, security codes or usable voucher codes through them.

3. Information we collect and its sources

Launch subscribers. Your email address, optional town or area, subscription choice and related correspondence.

Business enquiries. Your business name, contact name, town or area, email address, selected area of interest and follow-up correspondence. Business contact details may still identify an individual.

Preferences and consent. The form used, submission date and time, relevant consent wording and policy version, choices made, and later changes or unsubscribe instructions. We retain proportionate technical evidence of submission where needed for security or to demonstrate your choices.

Website and delivery information. Our website and communications providers may process IP addresses, browser and device details, requested pages, access times, error or security events, and email delivery, bounce and unsubscribe records. Optional tracking is explained in section 9.

Information normally comes directly from you or your interaction with our systems. A business representative may provide information with proper authority. We do not treat someone providing another person’s email address as that person’s marketing consent.

4. Why we use information

We use the relevant information to deliver the website; manage and answer enquiries; send the updates or promotional emails you selected; maintain enquiry and complaint records; organise prospective partner follow-up; understand interest by area; secure our systems; and respect consent and unsubscribe instructions.

We seek your consent for the form processing and messages described at the point of collection. Where applicable law permits, separate security, administrative, legal-compliance or claims-related processing may rely on the relevant legal obligation or legitimate interest. These grounds do not expand your marketing permission.

We identify required fields. Without an email address and the relevant form consent, we cannot provide the requested email subscription or handle an enquiry through that form. Refusing optional marketing does not prevent an enquiry. We explain a materially different proposed use and obtain new consent where required before beginning it.

5. Marketing and your choices

A launch-update subscription is permission for the Vuna launch messages described on that form, not an automatic subscription to every Guilder or affiliate product. On the business-interest form, broader emails about the Vuna launch, partner opportunities and related Guilder products or offers are sent only when you select the separate marketing checkbox.

These messages are sent by or on behalf of Guilder Financial LLC. Replies to your enquiry are separate from optional marketing. We will not add you to marketing merely because you ask a question or make a complaint.

You can unsubscribe at any time using the link in our marketing emails or the privacy contact in section 14. We act promptly and within applicable legal time limits. Marketing messages identify the sender and include a valid postal address and working opt-out method. Changing your marketing choice does not prevent a reply to an enquiry you still want us to handle.

6. Contracted hosting and enquiry support

We may use contracted hosting, customer relationship management software (CRM), email and support services to hold contact information, organize follow-up, maintain correspondence and complaint histories, and record your communication choices.

Importing an enquiry or subscription into a CRM does not change its permitted purpose or override an unsubscribe instruction. Access is limited to people who need the relevant information for their responsibilities. Providers acting on our behalf must follow appropriate contractual instructions, confidentiality, security and restrictions on further use.

7. Sharing information with others

Service providers. We share only the information needed for website delivery, form submission, CRM, email delivery, security, support, backups and associated administration. These providers are not permitted to use our enquiry or subscription lists for their own independent marketing.

Guilder Payment Solutions Limited. Where a business enquiry needs to progress to local assessment or onboarding, we may propose referring the necessary contact details, interest and relevant correspondence to the Zambian operating company. Before referral, we explain the recipient and purpose and obtain any required consent and permissions. A launch subscription alone does not authorise a payment account, KYC check or unrestricted sharing with that company.

Other group companies and affiliates. Ownership or affiliation does not give automatic access to the lists. Any involvement must have a specified role, limited access, an appropriate legal basis and the required disclosure and consent. We do not provide your information for another organisation’s independent marketing without a separate, specific choice.

Advisers, authorities and business changes. Necessary information may be disclosed for legal advice, a lawful regulatory request, security investigation, legal claim or genuine restructuring or transfer of this business, subject to the applicable legal basis, confidentiality and proportionate access. A change of ownership does not authorise unrelated reuse.

We do not sell or rent personal information. Publishing this policy does not give any recipient unrestricted rights to use it.

8. Processing and storage locations

The arrangement described on the forms includes transfer to, processing and storage in the United States by Guilder Financial LLC and its service providers. It may include form handling, CRM, email delivery, backups and authorised support access. This does not mean that every system is located in Texas.

We use international processing only where lawful and subject to required registrations, authorisations, contractual safeguards and consent.

9. Cookies and other website technologies

Website servers may keep necessary connection and security logs even without cookies. Cookies or similar tools may support requested functions, remember preferences or provide optional analytics.

Our policy is to keep optional analytics, advertising and cross-site tracking disabled until the relevant informed opt-in. You can change that choice using the available controls or contact us. Email subscription alone does not authorise unrelated advertising or tracking. Browser settings can also restrict cookies, although blocking a necessary technology may affect a requested function.

10. How long we keep information

Subscriptions. We use your contact details for the selected emails while the subscription purpose remains active and you have not withdrawn permission. When you unsubscribe or that purpose ends, we stop the activity. We do not automatically convert launch subscriptions into ongoing general marketing lists.

Enquiries and complaints. We keep relevant records while dealing with the matter and for the period needed to document the outcome, resolve follow-up issues and meet applicable legal duties. We review inactive enquiries rather than retaining every prospective contact indefinitely.

Consent, security and suppression records. Limited records may be retained to demonstrate permissions, investigate misuse, meet a legal requirement or ensure we do not contact you again. Suppression records are not a source for further marketing. Website and delivery records are kept only for their operational, security or lawful record-keeping purposes.

We do not automatically apply payment-account or KYC retention periods to a website enquiry or launch subscription. Any applicable statutory minimum, legal hold or specific deletion requirement takes precedence. When no lawful retention purpose remains, we delete or irreversibly anonymise the data; backups follow controlled expiry and restored data remains subject to applicable deletion and unsubscribe instructions.

11. Security and incidents

We use safeguards appropriate to the information and risks, including access controls, confidential handling, secure transmission and storage, staff awareness and service-provider oversight. We assess and respond to suspected misuse or breaches and make legally required notifications within the applicable time limits. No system is entirely risk-free, but that does not remove our legal responsibilities or your rights.

12. Children and future services

These forms are intended for adults interested in launch news or business participation, not children. Please contact us if a child’s information has been supplied so we can assess it and take appropriate action.

Signing up does not initiate ID verification, create a wallet, place an order or write your details to a transaction ledger. Later applications, verification and payment services will have their own collection information, responsible entities and permissions. This policy does not authorise those later activities.

13. Your rights and withdrawing consent

You may contact us to ask what information we hold about you, correct inaccurate details, request deletion, withdraw consent, or object to marketing. Depending on the law that applies, you may also have rights to restrict processing, obtain a portable copy, object to other processing or challenge certain automated decisions. We do not use these pre-launch forms to make solely automated decisions with legal or similarly significant effects.

Where we rely on consent, you may withdraw it without affecting the lawfulness of earlier processing. We stop the consent-based activity and handle the remaining records under the applicable retention rules. Withdrawal of enquiry-processing consent may prevent us from continuing the enquiry; withdrawing marketing consent alone does not have that effect.

Use the email or postal address in section 14 and describe your request. We may seek proportionate evidence of identity or authority to protect you and others. You do not need a payment account to exercise privacy rights. We respond within applicable legal time limits and explain a lawful refusal or limitation and available complaint options unless the law prevents us from doing so.

Texas residents. Where the Texas Data Privacy and Security Act applies, it provides access, correction, deletion, portability and specified opt-out rights, without unlawful discrimination. Requests ordinarily receive a response within 45 days, subject to a permitted extension explained within that period. To appeal a refusal, contact us and mark the request “Privacy appeal”. We explain the appeal outcome and, if denied, how to complain to the Texas Attorney General.

People in Zambia. Where Zambia’s Data Protection Act applies, its rights and safeguards continue to apply to the relevant processing. You may raise a complaint with the Office of the Data Protection Commissioner without first completing our internal process. Nothing in this policy requires you to waive a mandatory legal right because we are a Texas company.

14. Contact and complaints

Responsible company: Guilder Financial LLC, a Texas limited liability company.

Privacy contact: Mathew Mbewe

Email:matew.mbewe@guidler.money

We welcome privacy concerns and will explain how we propose to address them. You may also contact the relevant supervisory or enforcement authority, including Zambia’s Office of the Data Protection Commissioner or the Texas Attorney General where their respective laws apply. We will provide the relevant complaint details on request and when required following a decision.

15. Changes to this policy

We update this policy when collection arrangements, providers, purposes or legal requirements materially change and show the revised effective date. We give additional notice where appropriate and obtain fresh consent where required before beginning a new consent-dependent activity. Reading the policy, submitting information without the required affirmative choice or continuing to browse does not by itself provide consent.