ABGALIS — Enterprise Risk Management and Climate Risk Intelligence Platform

Privacy Policy

Effective: 1 January 2026 · Last updated: 9 March 2026 · Version 1.0

1. Data Controller

Abgalis Limited, a UK private limited company registered in England and Wales. Registered office: Flat 2, 38 Harcourt Terrace, London SW10 9JR. Company registration number: 17247499. For all data protection enquiries: [email protected].

2. What We Collect & Why

Data Category	Lawful Basis (UK GDPR)	Purpose
Name, email, company, role (contact form)	Legitimate interests (Art. 6(1)(f))	Responding to your enquiry; scheduling a consultation
IP address, browser type, pages visited	Legitimate interests	Website security, analytics, performance monitoring
Client portfolio/exposure data (platform users)	Contract performance (Art. 6(1)(b))	Delivering the Abgalis platform service
Cookies and similar technologies	Consent (PECR Reg. 6)	See our Cookie Policy

3. How We Use Your Data

We process personal data to respond to enquiries, deliver platform services under contract, improve our platform through aggregated and anonymised analytics, comply with legal obligations, and communicate service updates. We do not sell personal data. We do not use personal data for automated decision-making that produces legal effects on individuals.

4. Data Sharing

We share personal data only with cloud infrastructure providers (Microsoft Azure, with data processing agreements in place), professional advisers (legal, audit) under confidentiality obligations, and regulatory authorities where required by law. Where client data is processed through AI/ML models, outputs are analytical only and no personal data is used to train general-purpose models without explicit consent.

5. International Transfers

Abgalis Limited is a UK private limited company. Where personal data is transferred from the UK or EEA to the United States, we rely on the UK-US Data Bridge (extension of the EU-US Data Privacy Framework) or the ICO's International Data Transfer Agreement (IDTA) where the Data Bridge does not apply. For transfers to other jurisdictions, we use appropriate safeguards under UK GDPR Article 46.

6. Data Retention

Contact form submissions: 24 months from last interaction. Platform client data: duration of service agreement plus 12 months. Website analytics: 26 months (aggregated). We delete or anonymise personal data when it is no longer necessary for the purposes for which it was collected.

7. Your Rights

Under UK GDPR and the Data (Use and Access) Act 2025 (DUA), you have the right to access your data, rectify inaccuracies, request erasure, restrict processing, data portability, and object to processing. To exercise any right, email [email protected]. We will respond within one calendar month. If you are dissatisfied with our response, you may lodge a complaint with the UK Information Commissioner's Office (ICO) at ico.org.uk.

8. US Privacy Rights

If you are a California resident, the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), provides additional rights including the right to know, delete, correct, and opt out of the sale or sharing of personal information. Abgalis does not sell personal information. For Virginia (VCDPA), Colorado (CPA), Connecticut (CTDPA), Utah (UCPA), Texas (TDPSA), Oregon (OCPA), Montana (MCDPA), and other US state privacy law residents: equivalent rights apply. Contact [email protected] to exercise your rights.

9. Canadian Privacy Rights

If you are a Canadian resident, the Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial legislation (including Quebec's Law 25) provide you with the right to access, correct, and withdraw consent for processing of your personal information. Contact our privacy team for requests.

10. Asia-Pacific Privacy Rights

For residents of Australia, the Privacy Act 1988 and Australian Privacy Principles (APPs) apply. For Singapore, the Personal Data Protection Act 2012 (PDPA) applies. For India, the Digital Personal Data Protection Act 2023 (DPDPA) applies. For Japan, the Act on the Protection of Personal Information (APPI) applies. Contact [email protected] for jurisdiction-specific requests.

11. Middle East Privacy Rights

For residents of the UAE, the Federal Decree-Law No. 45/2021 on Personal Data Protection applies. For DIFC, the DIFC Data Protection Law (Law No. 5 of 2020) applies. For ADGM, the ADGM Data Protection Regulations 2021 apply. For Saudi Arabia, the Personal Data Protection Law (PDPL) applies. For Bahrain, the Personal Data Protection Law (Law 30 of 2018) applies.

12. Children's Privacy

Abgalis services are intended for business professionals. We do not knowingly collect personal data from individuals under 18 years of age. If you believe we have inadvertently collected such data, please contact us immediately.

13. Security

We implement technical and organisational measures aligned to ISO 27001 and SOC 2 Type II standards, including encryption in transit (TLS 1.3) and at rest (AES-256), access controls, regular penetration testing, and incident response procedures.

14. Changes to This Policy

We will update this policy as necessary. Material changes will be communicated via the website. The "Last updated" date above reflects the most recent revision.

Cookie Policy

Effective: 1 January 2026 · Last updated: 11 July 2026

1. What Are Cookies and Similar Technologies

Cookies are small text files placed on your device when you visit a website. Similar technologies include locally stored preferences and tracking identifiers. Under the UK Privacy and Electronic Communications Regulations 2003 (PECR) and the EU ePrivacy Directive, we require your consent before placing non-essential cookies or identifiers.

2. What We Use

Item	Type	Purpose	Duration
abgalis-consent-v1	Strictly necessary (locally stored preference — not a cookie)	Records your analytics consent choice	Until you clear your browser data
Apollo.io identifiers	Analytics / marketing (optional)	Business-visitor analytics: helps us understand which organisations read our research	Set only after you accept; durations governed by Apollo.io

We do not use Google Analytics, LinkedIn Insight Tag, or any other tracking technology on this website. Nothing optional loads before you consent, and visitors sending a Global Privacy Control signal are treated as having declined.

3. Your Choices

The optional analytics identifiers are placed only with your explicit consent, requested via the banner on your first visit. You can change or withdraw your choice at any time using the button below; withdrawal takes effect from your next page view. Most browsers also let you clear stored data and block identifiers through their settings.

Manage cookie preferences

4. Third-Party Processing

The optional analytics service is provided by ZenLeads Inc. (trading as Apollo.io), a United States company. Identifiers it sets are subject to its own privacy policy. Where personal data is transferred outside the UK or EEA, UK GDPR international-transfer safeguards apply.

5. International Compliance

This cookie policy complies with: UK PECR 2003, EU ePrivacy Directive (2002/58/EC as amended), the CNIL guidelines (France), the TDDDG (formerly TTDSG) (Germany), and the CCPA/CPRA (California, USA) as applicable.

Terms of Use

Effective: 1 January 2026 · Last updated: 9 March 2026

1. About This Website

This website is operated by Abgalis Limited, a UK private limited company ("Abgalis", "we", "us"). By accessing this website you agree to these terms. If you do not agree, please do not use this website.

2. Intellectual Property

All content on this website — including text, graphics, logos, the Abgalis seven-pillar logo and parabolic arc, the Abgalis Engine™ framework, research papers, software descriptions, and design — is the intellectual property of Abgalis Limited and is protected by copyright, trade mark, trade secret, and other intellectual property laws of the United Kingdom, the United States, and international treaties. No part may be reproduced, distributed, or transmitted without prior written consent.

3. No Financial or Actuarial Advice

Nothing on this website constitutes financial advice, investment advice, insurance advice, actuarial advice, or a recommendation to purchase, sell, or hold any financial product or insurance contract. Abgalis provides data analytics and risk intelligence tools. Any decisions based on information presented on this website are made at your own risk. You should consult qualified professional advisers before making financial, actuarial, or insurance decisions.

4. No Regulatory Advice

Content relating to Solvency II, ORSA, IFRS 17, PRA requirements, NAIC RBC, OSFI LICAT, EIOPA guidelines, IAIS standards, or any other regulatory framework is provided for informational purposes only. It does not constitute legal or regulatory advice. Regulatory requirements vary by jurisdiction and change over time. Consult your compliance team or legal advisers for specific regulatory guidance.

5. AI and Model Outputs Disclaimer

The Abgalis platform uses artificial intelligence, machine learning, and stochastic modelling techniques. All model outputs are analytical tools intended to support — not replace — human judgement. Abgalis does not guarantee the accuracy, completeness, or timeliness of any model output. Users of the platform remain solely responsible for regulatory submissions, underwriting decisions, capital calculations, and risk management actions taken on the basis of platform outputs.

6. Limitation of Liability

To the fullest extent permitted by law, Abgalis Limited excludes liability for any indirect, consequential, special, or incidental damages arising from your use of this website or reliance on its content. Our total aggregate liability shall not exceed the greater of USD $100 or the amount paid by you to Abgalis in the 12 months preceding the claim. Nothing in these terms excludes liability for death or personal injury caused by negligence, fraud, or fraudulent misrepresentation.

7. Research Papers

Research papers available for download are provided for informational and educational purposes. They represent the views of the authors at the time of publication and do not constitute professional advice. Abgalis reserves all intellectual property rights in its research publications.

8. Links to Third Parties

This website may contain links to third-party websites. We do not control or endorse such websites and are not responsible for their content or privacy practices.

9. Governing Law

These terms are governed by the laws of England and Wales, without regard to conflict of laws principles. For users based in the United Kingdom or European Economic Area, nothing in these terms affects your mandatory statutory consumer rights under the laws of your country of residence.

10. Company Information

Abgalis Limited is registered in England and Wales. UK Companies Act 2006 (s.82) disclosures: Company name: Abgalis Limited. Registered office: Flat 2, 38 Harcourt Terrace, London SW10 9JR. Company number: 17247499. Contact: [email protected].

Modern Slavery & Human Trafficking Statement

Financial year ending: 31 December 2025 · Published: March 2026

1. Our Commitment

Abgalis Limited is committed to preventing modern slavery and human trafficking in all its forms across our operations, supply chain, and business relationships. This statement is made pursuant to Section 54 of the UK Modern Slavery Act 2015, the US Federal Acquisition Regulation (FAR) 52.222-50 on Combating Trafficking in Persons, and the Australian Modern Slavery Act 2018 (Cth), as applicable to our global operations.

2. Our Business

Abgalis is a technology company providing dynamic risk intelligence to insurers and reinsurers worldwide. We are a software and data business with a primarily digital supply chain. Our workforce consists of skilled technology, actuarial, and business professionals.

3. Our Supply Chain

Our supply chain comprises cloud infrastructure providers (Microsoft Azure), third-party data providers, software development tools and SaaS vendors, professional service firms (legal, audit, consulting), and office facilities providers. We assess modern slavery risk as low in our direct supply chain given its predominantly digital and professional services nature. However, we recognise that risk exists within extended supply chains, particularly in hardware manufacturing and data centre operations.

4. Our Policies

We maintain a Supplier Code of Conduct requiring compliance with all applicable laws prohibiting forced labour, child labour, and human trafficking. Our employment practices comply with the UK Employment Rights Act 1996, the US Fair Labor Standards Act (FLSA), and equivalent legislation in all jurisdictions where we operate. We conduct right-to-work checks for all employees. We provide fair and competitive remuneration above minimum wage in all jurisdictions.

5. Due Diligence

We conduct due diligence on new suppliers and review existing suppliers periodically. We require key suppliers to provide their own modern slavery statements or equivalent assurances. We assess country-level risk using the Global Slavery Index and US Department of State Trafficking in Persons Report. We provide training to relevant staff on identifying indicators of modern slavery.

6. Reporting Concerns

Any person with concerns about modern slavery in relation to Abgalis or its supply chain should contact [email protected]. Reports can be made anonymously and will be investigated promptly. We prohibit retaliation against anyone who raises concerns in good faith.

7. Board Approval

This statement has been approved by the Board of Directors of Abgalis Limited and will be reviewed and updated annually.

Accessibility Statement

Last updated: 9 March 2026

1. Our Commitment

Abgalis Limited is committed to ensuring digital accessibility for people of all abilities. We strive to conform to the Web Content Accessibility Guidelines (WCAG) 2.2 at Level AA, in accordance with the UK Equality Act 2010, Section 508 of the US Rehabilitation Act, the Americans with Disabilities Act (ADA), the European Accessibility Act (Directive (EU) 2019/882), and equivalent legislation in jurisdictions where we operate.

2. Measures We Take

We use semantic HTML5 markup with appropriate ARIA attributes, ensure sufficient colour contrast ratios (minimum 4.5:1 for normal text), provide text alternatives for non-text content, ensure all functionality is available via keyboard navigation, use responsive design that supports browser zoom up to 200%, test with screen readers (NVDA, VoiceOver), and avoid content that flashes more than three times per second.

3. Known Limitations

Some interactive elements (3D card flip animations) may not convey their state change to all assistive technologies. Research paper PDFs may have limited accessibility. We are actively working to address these limitations.

4. Feedback

If you encounter any accessibility barriers on this website, please contact [email protected]. We aim to respond within 5 business days and to resolve reported issues within 30 days where technically feasible.

5. Enforcement

UK residents may contact the Equality and Human Rights Commission (EHRC) or the Equality Advisory Support Service (EASS) if they are not satisfied with our response. US residents may file a complaint with the Department of Justice. EU residents may contact their national enforcement body under the European Accessibility Act.

Regulatory & AI Transparency

Last updated: 9 March 2026

Abgalis Limited provides data analytics and risk intelligence software to regulated entities. We are not authorised or regulated as a financial services firm in any jurisdiction. Platform outputs are analytical tools — they do not constitute insurance advice, investment advice, actuarial opinions, or regulatory submissions.

A — Our Regulatory Status

United Kingdom

Abgalis is not authorised or regulated by the Financial Conduct Authority (FCA) or the Prudential Regulation Authority (PRA). Our activities — providing data, analytics, and risk scoring to insurers — do not constitute regulated activity under the Financial Services and Markets Act 2000 (FSMA). Communications on this website are directed at investment professionals (Article 19, Financial Promotion Order 2005) and high net worth companies (Article 49). They are not directed at retail consumers.

United States

Abgalis Limited is a UK private limited company. We are not a registered investment adviser (Investment Advisers Act of 1940), broker-dealer (Securities Exchange Act of 1934), or licensed insurance company, agent, or broker in any US state.

Lloyd's Market

Abgalis is not a Lloyd's coverholder, managing agent, or syndicate. Outputs may be used by Lloyd's market participants to support their Syndicate Business Forecast (SBF), capital model validation, or ORSA processes — subject to their own governance and validation frameworks.

Canada

Abgalis is not a federally or provincially regulated financial institution in Canada.

Asia-Pacific, Middle East & Other Jurisdictions

Abgalis is not licensed or regulated by any Asia-Pacific authority (MAS, APRA, IRDAI, FSA Japan, Hong Kong IA) or any Middle East authority (DFSA, CBUAE, ADGM FSRA, SAMA, CBB). Our outputs support — but do not replace — local regulatory compliance processes in these jurisdictions.

B — Insurance Regulatory Frameworks We Support

Jurisdiction	Framework	How Abgalis Supports
UK / Europe	Solvency II / UK Solvency Regime	Internal model inputs, Standard Formula SCR analysis, ORSA support
United States	NAIC Risk-Based Capital (RBC)	RBC analysis, US-adopted ORSA support
Canada	OSFI LICAT / MCT	Life & P&C capital adequacy analysis
Global	IFRS 17	Insurance contract measurement inputs
Global	IFRS S1 / S2 (ISSB)	Climate and sustainability disclosure inputs

Responsibility for regulatory capital calculations, risk appetite setting, and regulatory submissions remains solely with the regulated entity. Abgalis outputs do not constitute an actuarial opinion or a regulatory filing.

C — AI Transparency

EU AI Act (Regulation (EU) 2024/1689)

Risk intelligence models used by EU-regulated insurers in underwriting, pricing, or capital assessment may be classified as high-risk AI systems under Annex III. As an AI provider, Abgalis maintains:

Obligation	Our Approach
Risk management (Art. 9)	Documented risks per model with mitigation measures and review lifecycle
Data governance (Art. 10)	Training data quality, relevance, representativeness, and bias assessment
Technical documentation (Art. 11)	Model cards extended to EU AI Act standard
Record-keeping (Art. 12)	Automatic logging of system operation for audit
Transparency (Art. 13)	Deployer documentation enabling correct interpretation of outputs
Human oversight (Art. 14)	Design for human override — no fully autonomous decisions
Accuracy & robustness (Art. 15)	Ongoing validation, adversarial testing, documented accuracy metrics
Conformity (Art. 43)	Self-assessment for Annex III; declaration of conformity maintained
Post-market monitoring (Art. 72)	Continuous monitoring plan with incident reporting

DORA (Regulation (EU) 2022/2554)

For EU-regulated clients subject to DORA, Abgalis meets ICT third-party service provider requirements under Article 30: documented SLAs, data processing location transparency, business continuity commitments (defined RTO/RPO), regulator cooperation, audit rights, exit strategy, and data return/deletion on termination.

D — Financial Crime & Sanctions

Anti-Money Laundering

While Abgalis is not directly subject to the UK Money Laundering Regulations 2017, the US Bank Secrecy Act, or EU Anti-Money Laundering Directives, our due diligence processes include identity verification of contracting parties and sanctions screening.

Sanctions Compliance

We screen all business relationships against sanctions lists maintained by OFAC (US), the UK Office of Financial Sanctions Implementation (OFSI), and the EU consolidated list. We do not provide services to sanctioned entities or individuals.

E — ESG & Tax Transparency

Environmental, Social & Governance

Abgalis supports the objectives of TCFD, TNFD, and the ISSB (IFRS S1 and S2). Our platform helps insurers meet climate risk disclosure obligations. Abgalis's own ESG reporting is proportionate to our current stage and will evolve as the business grows.

Tax Transparency

Abgalis is committed to responsible tax practices across all operating jurisdictions (UK, US, EU). We do not use aggressive tax avoidance structures. Transfer pricing arrangements comply with OECD Guidelines and the arm's length principle.