NEBEX, INC. — PRIVACY POLICY

Version 1.1

Last revised on: June 22, 2026

1. Introduction and Scope

Nebex, Inc. (“Company”, “we”, “us”, “our”) respects your privacy. This Privacy Policy explains how we collect, use, disclose, and protect personal data in connection with the website at https://www.nebex.com/ together with its subdomains and subdirectories, the “Site”. It applies to personal data we process about visitors to and users of the Site, including individuals who submit our contact form, subscribe to our updates, or correspond with us.

This Policy covers the informational Site only. Access to the Nebra Exchange platform is governed by separate platform terms and a separate privacy notice, which will apply to any personal data processed in connection with the platform. This Policy is incorporated by reference into our Website Terms of Use.

2. Who We Are (Controller)

For the purposes of the EU General Data Protection Regulation (EU GDPR) and the UK GDPR, the data controller is Nebex, Inc., 5 Penn Plaza, 19th floor, New York, New York 10001, USA. Contact: legal@nebex.com.

3. Personal Data We Collect

We collect:

Information you provide directly

  • Through the contact form: your full name, organization, role, email address, phone number, the nature of your enquiry, and any information in your free-text message.
  • Through our newsletter signup: your email address.
  • Through direct correspondence, including info@, press@, or otherwise: the contents of your communications and your contact details.

Information collected automatically

When you visit the Site, we and our service providers may collect technical and usage data such as IP address, device and browser type, operating system, referring URLs, pages viewed, and dates/times of access, through cookies and similar technologies. See Section 8.

We do not intentionally collect special categories of data, such as health, biometric data, or political opinions, through the Site, and ask that you not submit such data in free-text fields.

Where we ask for personal data, we will indicate whether provision is required. If you do not provide data that is necessary to respond to your enquiry or to provide a feature you request, for example, your email address for the newsletter, we may be unable to provide that response or feature.

4. How We Use Personal Data and Legal Bases

We use personal data for the following purposes, relying on the lawful bases indicated:

  • To respond to and manage your enquiries and requests for access, and to evaluate prospective participants — on the basis of the performance of, or taking steps prior to entering into, a contract with you or the entity you represent, and our legitimate interests in responding to business enquiries and developing our business.
  • To send updates and marketing communications where you have signed up — on the basis of your consent, which you may withdraw at any time, or, where permitted, our legitimate interests in marketing to existing business contacts. See Section 9.
  • To operate, secure, maintain, and improve the Site — on the basis of our legitimate interests in the proper functioning, security, and improvement of the Site.
  • To comply with legal, regulatory, and risk-management obligations, including export-control, sanctions, anti-corruption, and anti-money-laundering screening and record-keeping — on the basis of compliance with a legal obligation to which we are subject and our legitimate interests in managing legal and regulatory risk.

Where we rely on legitimate interests, those interests are: operating, securing, and improving the Site; understanding how the Site is used; communicating with business contacts and developing our business; and protecting Company, our users, and third parties from fraud, misuse, and legal or regulatory risk. We balance these interests against your rights and freedoms, and you may object to processing based on legitimate interests as described in Section 9.

5. How We Disclose Personal Data

We disclose personal data to: service providers and processors who act on our behalf, such as website hosting, analytics, email, and IT providers; professional advisors, including legal, accounting, and compliance advisors; authorities and regulators where required by law or to protect our rights; and acquirers or successors in connection with a corporate transaction.

We do not sell personal data, and we do not share data collected through the newsletter signup except with processors who help us deliver those communications.

6. International Transfers

We are based in the United States, and our service providers may process data in the United States and other countries. Where we transfer personal data from the EEA or UK to a country not deemed by the European Commission or the UK authorities to provide an adequate level of protection, we rely on appropriate safeguards, principally the European Commission’s Standard Contractual Clauses and, for UK transfers, the UK International Data Transfer Agreement or Addendum. You may request a copy of the relevant safeguards using the contact details in Section 13.

7. Data Retention

We retain personal data only as long as necessary for the purposes described in this Policy, after which we delete or anonymize it. In particular:

  • Contact-form and enquiry data — retained for the duration of our communications with you and for three (3) years thereafter, to manage our business relationship and for record-keeping.
  • Newsletter data — retained until you unsubscribe, and thereafter only as needed to honor your unsubscribe request.
  • Data retained for legal, tax, or compliance reasons — retained for the period required by applicable law.

Where a precise period cannot be specified in advance, we determine the retention period based on the nature of the data, the purpose for which it was collected, and applicable legal, tax, and regulatory requirements.

8. Cookies and Similar Technologies

The Site uses cookies and similar technologies. Strictly necessary cookies are required for the Site to function and do not require consent. Non-essential cookies, for example analytics and performance cookies, are used only with your consent, which you may give or decline, and later change, through our cookie banner and/or your browser settings.

9. Your Rights

EEA/UK (EU GDPR / UK GDPR)

Subject to conditions and exceptions under applicable law, you have the rights to: access your personal data; rectify inaccurate data; erase data, also known as the “right to be forgotten”; restrict processing; object to processing, including processing based on legitimate interests and, at any time, processing for direct marketing; data portability; and, where processing is based on consent, to withdraw consent at any time without affecting the lawfulness of processing before withdrawal.

To exercise these rights, contact legal@nebex.com. We will respond within the timeframes required by applicable law, generally one month under the GDPR, extendable as permitted.

You also have the right to lodge a complaint with a supervisory authority. In the UK, this is the Information Commissioner’s Office (ICO), https://ico.org.uk. In the EEA, you may complain to the supervisory authority in your country of residence, place of work, or place of the alleged infringement.

Automated decision-making

We do not make decisions producing legal or similarly significant effects about you based solely on automated processing, including profiling.

California (CCPA/CPRA)

California residents have the rights to know/access, delete, and correct personal information; to opt out of “sale” or “sharing” of personal information — we do not sell or share personal information as those terms are defined; to limit the use of sensitive personal information; and to non-discrimination for exercising these rights.

To make a request, contact legal@nebex.com. We will verify your request and respond within the timeframes the CCPA requires; you may use an authorized agent.

10. Security

We maintain reasonable administrative, technical, and organizational measures designed to protect personal data against unauthorized access, loss, misuse, or alteration. No method of transmission or storage is completely secure, however, and we cannot guarantee absolute security.

11. Children’s Privacy

The Site is intended for businesses and professional users and is not directed to children. We do not knowingly collect personal data from children. If you believe a child has provided us with personal data, please contact us at legal@nebex.com and we will take appropriate steps to delete it.

12. Changes to This Policy

We may update this Policy from time to time. We will post the updated version on the Site and revise the “Last revised” date; where changes are material, we will provide additional notice as required by applicable law.

13. Contact Us

Nebex, Inc.
5 Penn Plaza, 19th floor
New York, New York 10001
USA
legal@nebex.com