1. Who We Are

Vesica™ Capital Ltd is registered in England and Wales under company number 13606027. Our registered office is 124 City Road, London, EC1V 2NX.

In this Privacy Policy, Vesica™, we, us, and our refer to Vesica™ Capital Ltd.

We are the data controller for personal information collected through our websites, including vesica.co.uk and re-play.io, our contact forms, investor and strategic partner enquiries, RE-PLAY™ access requests, private access requests, and any associated Vesica™ services that link to this Privacy Policy.

For data protection questions, requests, or concerns, contact us at: info@vesica.co.uk

2. Scope of This Policy

This Privacy Policy applies to personal information we collect when you:

• Visit the Vesica™ website at vesica.co.uk
• Visit the RE-PLAY™ website at re-play.io
• Submit a contact form
• Submit a RE-PLAY™ access request
• Send us an email
• Request private access
• Make an investor or strategic partner enquiry
• Register interest in Vesica™ or RE-PLAY™
• Communicate with us about our services
• Use any public Vesica™ or RE-PLAY™ website page that links to this Privacy Policy
• Use any private Vesica™ or RE-PLAY™ platform, application, dashboard, or member area that links to this Privacy Policy

This Privacy Policy does not apply to third party websites, services, platforms, or applications that we do not control.

If Vesica™ or RE-PLAY™ launches additional private platforms, applications, member areas, or investment related services in the future, those services may include additional privacy notices or terms where required.

3. Personal Information We Collect

We may collect and process the following categories of personal information.

3.1 Information You Provide Directly

This may include:

• Full name
• Email address
• Phone number if provided
• Organisation or company name
• Job title or professional role
• Location or country
• Area of interest
• Website or platform interest
• Message content
• Investor or strategic partner enquiry details
• Private access request details
• RE-PLAY™ access request details
• Communication preferences
• Trading experience or market participation details if voluntarily provided
• Organisation or professional affiliation if voluntarily provided
• Any information submitted through Formspree powered forms
• Any information you voluntarily include in forms, emails, or correspondence

Please do not send us sensitive personal information unless we specifically request it and there is a lawful reason for doing so.

3.2 Website and Technical Information

When you visit our websites, we may collect limited technical and usage information, including:

• IP address
• Approximate location derived from IP address
• Browser type and version
• Device type and operating system
• Pages viewed and time spent on pages
• Referring website or source
• Click paths and engagement
• Screen size and general device information
• Date and time of visit
• Cookie and consent preferences
• Cookie preference choices
• Consent settings
• Theme preference
• Local storage settings used for website or app functionality

3.3 Analytics Information

We may use analytics tools, such as Google Analytics 4 or similar services, to understand website performance and visitor behaviour where those tools are implemented and where required consent has been obtained.

Analytics information may include pages visited, session duration, traffic source, approximate geographic region, device and browser information, engagement events, aggregated usage patterns, performance category choices, and marketing category choices where future marketing measurement tools are implemented.

At the time a website does not use optional analytics, performance, or marketing tools, the relevant cookie preference categories may still be shown so users can manage future optional storage choices. Optional tools should not be activated unless the relevant consent choice allows them.

3.4 Communications Information

If you contact us, we may keep records of emails, contact form submissions, RE-PLAY™ access request submissions, investor enquiry emails, private access requests, meeting requests, follow up correspondence, and internal notes relating to your enquiry.

3.5 Future Platform or Account Information

If Vesica™ or RE-PLAY™ provides access to private platforms, dashboards, applications, member areas, or authenticated app environments, we may collect additional information required to provide those services, such as:

• Account registration details
• Login credentials managed through secure authentication services
• RE-PLAY™ account access records
• App usage preferences
• App interface preferences
• Consent and cookie preference records
• Security events and authentication logs
• Support and access request history

Where additional processing is required, further notices or terms may be provided.

3.6 Formspree and Access Request Forms

Some contact forms or access request forms, including RE-PLAY™ access request forms, may be processed through Formspree or another form processing provider.

When you submit a form, the information you provide may be sent to that provider so the form can be processed and delivered to us by email or through the relevant form management system.

Form submissions may include your email address, message content, submission time, technical metadata, and any other information you choose to provide.

We use this information to review, respond to, and manage your enquiry or access request.

4. How We Collect Personal Information

We collect personal information in the following ways:

• Directly from you when you submit forms, send emails, or communicate with us
• Automatically when you use our websites
• Through cookies and similar technologies
• Through RE-PLAY™ access request forms
• Through Formspree or other form processing providers
• Through cookie preference controls
• Through local storage used for essential website or app functionality
• From service providers that help operate our websites and process enquiries
• From publicly available professional or business sources where relevant to legitimate business communication
• From third parties where you have authorised them to share information with us

5. Why We Use Personal Information

5.1 To Respond to Enquiries

We use your information to respond to messages, contact requests, private access enquiries, investor interest, and strategic partner discussions.

5.2 To Process RE-PLAY™ Access Requests

We use personal information submitted through RE-PLAY™ access request forms to receive, review, manage, and respond to requests for private access or access notifications.

5.3 To Operate and Improve Our Websites

We use technical and usage data to maintain website functionality, understand performance, fix issues, and improve user experience.

5.4 To Manage Investor and Strategic Partner Communications

We may use enquiry information to assess interest, arrange discussions, maintain communication records, and manage potential strategic relationships. This may include enquiries submitted through Vesica™ websites, RE-PLAY™ websites, direct email, or private access routes.

5.5 To Provide Access to Vesica™ and RE-PLAY™ Services

Where access is granted to any Vesica™ or RE-PLAY™ platform, application, or private environment, we may process information needed to create accounts, provide access, manage support, maintain security, and deliver the service.

5.6 To Send Updates or Marketing Communications

We may send updates, announcements, or relevant communications where you have requested them or where we have a lawful basis to do so. You may opt out at any time.

5.7 To Maintain Security and Prevent Misuse

We may process technical, usage, and communication data to protect our websites, prevent fraud, detect misuse, secure our systems, and maintain audit records.

5.8 To Comply With Legal and Regulatory Obligations

We may process personal information to comply with applicable laws, respond to lawful requests, maintain business records, and protect our legal rights.

6. Cookies and Similar Technologies

Our websites and associated services may use cookies, local storage, and similar technologies.

These technologies may be used to operate the website, remember preferences, manage consent choices, protect forms, maintain security, understand website performance, and improve user experience.

We may use the following categories:

Essentials

Required for website operation, security, theme preferences, form protection, and consent management. Essential storage cannot be switched off through website cookie controls.

Analytics

Helps us understand website usage and improve performance. Analytics tools should only be used where implemented and where the relevant consent choice allows them.

Performance

Helps us understand technical performance, page behaviour, reliability, and user experience. Performance tools should only be used where implemented and where the relevant consent choice allows them.

Marketing

May be used in the future to understand campaign performance or measure interest in Vesica™ or RE-PLAY™. Marketing tools should only be used where implemented and where the relevant consent choice allows them.

The RE-PLAY™ website may store cookie preference choices in local storage under a consent settings key so that the website can remember the user's selection. This is used for consent management.

You can manage cookies through your browser settings and, where available, through our website cookie controls. If you block certain essential technologies, some website features may not work as intended.

7. Analytics Tools

We may use Google Analytics 4 or similar analytics tools to understand how visitors use our websites.

Analytics tools may collect information about pages visited, session duration, device information, approximate location, traffic source, and engagement events.

Where analytics cookies or similar technologies are not strictly necessary, they should only be used where appropriate consent has been obtained.

If analytics tools are not active on a particular website, analytics preference controls may still be shown so users can manage their choices before optional analytics are introduced.

We may use privacy protective settings where available, such as IP anonymisation, reduced data sharing, and limited retention.

8. How We Share Personal Information

We do not sell, rent, or trade personal information. We may share personal information with trusted parties where necessary, including:

• Website and app hosting and infrastructure providers
• Contact form and enquiry processing providers
• Form processing providers such as Formspree
• Email and communication service providers
• Analytics providers such as Google Analytics
• Consent management and preference storage systems
• Private access and app infrastructure providers where relevant
• Professional advisers including lawyers, accountants, and compliance advisers
• Technology providers that support website security and operation
• Authorities, regulators, courts, or law enforcement where required by law
• Potential buyers, successors, or advisers in connection with a business transfer, restructuring, merger, or acquisition, subject to appropriate confidentiality and protection

Where a RE-PLAY™ access request is submitted through Formspree, the submitted information may be processed by Formspree so that the enquiry can be delivered to Vesica™ Capital Ltd.

We only share personal information where there is a lawful basis and where appropriate safeguards are in place.

9. Service Providers and Processors

Where we use service providers to process personal information on our behalf, they are required to process that information only according to our instructions and to protect it appropriately. Our service provider categories may include website hosting, analytics, form processing, email delivery, security monitoring, cloud storage, professional advisory services, form processing providers such as Formspree, cookie consent and preference management tools, private platform and app infrastructure providers, and authentication and security providers where private access is granted.

10. International Transfers

Some service providers may process personal information outside the United Kingdom. Where personal information is transferred internationally, we take steps to ensure appropriate protections are in place. This may include adequacy regulations, the UK International Data Transfer Agreement, the UK Addendum to the European Commission Standard Contractual Clauses, or other approved transfer safeguards.

11. How Long We Keep Personal Information

We keep personal information only for as long as reasonably necessary for the purpose it was collected, including to meet legal, accounting, reporting, security, and business requirements.

• General enquiries: up to 3 years from last meaningful contact
• RE-PLAY™ access requests: up to 3 years from the last meaningful contact, unless a longer period is required for legal, contractual, security, or business reasons
• Form submissions: up to 3 years from the last meaningful contact, unless a longer period is required for legal, contractual, security, or business reasons
• Investor and strategic partner enquiries: up to 6 years from last meaningful contact, unless a longer period is required for legal, contractual, or regulatory reasons
• Private access or platform records: for the duration of the account or service relationship, plus up to 6 years where required for legal, security, contractual, or audit purposes
• Private platform and app access records: for the duration of the access relationship, plus up to 6 years where required for legal, security, contractual, or audit purposes
• Marketing preferences: until you withdraw consent or opt out, with suppression records retained where necessary
• Cookie and consent preference records: usually up to 12 months unless refreshed, changed, deleted by the user, or required for compliance purposes
• Analytics data: up to 26 months unless configured otherwise
• Security and technical logs: usually up to 12 months unless needed for investigation or legal purposes
• Legal and compliance records: as required by applicable law

We may retain anonymised or aggregated data for longer where it no longer identifies you.

12. Data Security

We use appropriate technical and organisational measures to protect personal information. These may include TLS and SSL encryption, access controls, secure hosting environments, data minimisation, internal confidentiality controls, security reviews, backup and recovery processes, and monitoring for misuse or unauthorised access.

No website or digital system can be guaranteed to be completely secure. However, we take reasonable steps to protect personal information and reduce risk. If a personal data breach occurs that is likely to result in a risk to individuals, we will assess our notification obligations and notify the Information Commissioner's Office and affected individuals where required by law.

13. Your Data Protection Rights

Under UK data protection law, you may have the following rights:

• Right of access: you can ask for a copy of personal information we hold about you
• Right to rectification: you can ask us to correct inaccurate or incomplete information
• Right to erasure: you can ask us to delete personal information in certain circumstances
• Right to restriction: you can ask us to restrict the use of your personal information in certain circumstances
• Right to object: you can object to processing based on legitimate interests or direct marketing
• Right to data portability: you can ask to receive certain information in a structured, machine readable format
• Right to withdraw consent: where we rely on consent, you can withdraw that consent at any time
• Rights relating to automated decision making: you have rights in relation to certain automated decisions that produce legal or similarly significant effects

To exercise your rights, contact us at info@vesica.co.uk. We may need to verify your identity before responding. We normally respond within one month, although this period may be extended where permitted by law.

14. Marketing Communications

Where we send marketing or update communications, you can opt out at any time by following the unsubscribe instructions where provided or by contacting us at info@vesica.co.uk. We may still send non marketing communications where necessary, such as service messages, legal notices, security updates, or responses to your enquiries.

Submitting a RE-PLAY™ access request does not automatically mean you have consented to unrelated marketing communications. We may contact you about your access request and related Vesica™ or RE-PLAY™ information. Separate marketing communications will only be sent where we have an appropriate lawful basis.

15. Investor and Strategic Partner Enquiries

If you submit an investor or strategic partner enquiry, this may include enquiries submitted through Vesica™ websites, RE-PLAY™ websites, direct email, or private access routes. We may use the information you provide to review the enquiry, respond to you, arrange discussions, assess strategic alignment, maintain internal communication records, share relevant information privately where appropriate, and meet legal, contractual, or compliance obligations.

Submitting an enquiry does not create an investor relationship, advisory relationship, client relationship, or obligation for Vesica™ to provide information, access, or opportunities.

16. RE-PLAY™ Access Requests

If you submit a RE-PLAY™ access request, we may use the information you provide to:

• Receive and review the request
• Respond to you
• Manage access interest
• Maintain internal communication records
• Assess whether and when access may be introduced
• Send access related updates
• Protect the website and forms from misuse
• Meet legal, contractual, security, or compliance obligations

Submitting a RE-PLAY™ access request does not guarantee access, account creation, platform availability, private onboarding, or any future relationship with Vesica™ or RE-PLAY™.

RE-PLAY™ is a private development environment and access may be introduced selectively at Vesica™ Capital Ltd's discretion.

17. Automated Decision Making and Profiling

We do not use personal information collected through the public Vesica™ or RE-PLAY™ websites to make solely automated decisions that have legal or similarly significant effects. If this changes in connection with future services, we will provide appropriate information and safeguards where required.

18. Children

Our websites and services are not directed at individuals under 18. We do not knowingly collect personal information from children. If you believe a child has provided personal information to us, contact us and we will take appropriate steps to delete it where required.

19. Third Party Links

Our websites may contain links to third party websites or services. This includes links between Vesica™ websites, RE-PLAY™ websites, third party form services, social media platforms, and any external services linked from our websites. We are not responsible for the privacy practices, content, security, or policies of third party websites. You should review their privacy notices before providing personal information to them.

20. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Where changes are material, we may provide notice on our website or by other appropriate means. The date at the top of this page shows when the Privacy Policy was last updated.

21. Complaints

If you have concerns about how we use personal information, please contact us first so we can try to resolve the issue at info@vesica.co.uk.

You also have the right to complain to the Information Commissioner's Office, the UK supervisory authority for data protection matters. ICO website: ico.org.uk

22. Contact Us