PRIVACY POLICY

ABELLA1.COM | ABELLA1 LTD Company number: 13802852 • Contact: info@abella1.com Last reviewed: 15 October 2026 • Registered office: 71–75 Shelton Street, Covent Garden, London WC2H 9JQ, United Kingdom 1. Who we are Abella1 LTD (company number 13802852), registered in the United Kingdom, operates abella1.com (the “Website”). We are the controller of personal information collected to administer and publish advertisements, verify advertisers, receive payments and operate the Website. Contact us at info@abella1.com or at our registered office address above. This notice describes our processing under the UK GDPR, Data Protection Act 2018 and applicable electronic communications rules.

2. Adults only The Website and advertising service are intended only for people aged 18 or over. We require identification to verify age before publication. We do not knowingly accept advertisements featuring minors or knowingly provide services to minors. If you believe information relating to a minor has been submitted or published, contact us immediately at info@abella1.com. Permission from a parent or guardian does not permit use by anyone under 18.

3. Information we receive Advertisers send us information and photographs, and our team prepares and publishes their advertisements; advertisers do not upload their own listings directly. Depending on what is submitted, we process professional or advertising names, legal names, email addresses, telephone numbers, locations, descriptions, photographs, correspondence and publication instructions. We also process transaction and billing details, payment references, support requests, complaint records and technical data such as IP addresses, device/browser information, access timestamps and security logs. Please do not send unnecessary information or another person’s personal data without appropriate authority.

4. Identity and age verification Before publication, we request a passport or government-issued identity card to verify an advertiser’s identity and that the person is at least 18. We use the document solely for the verification and related safety checks. Once verification is complete, we delete the ID or passport copy, including copies received through email, messaging and cloud storage. We may retain a minimal record that verification occurred where justified; we do not publish identification documents. We take steps to check that the identification relates to the person featured in an advertisement.

5. Public advertisements and photographs Advertisers submit their information and photographs to our team, explicitly confirm their agreement to publication, and our team reviews, prepares and publishes approved advertisements. Advertisers do not directly upload listings. Public profiles may contain professional names, photographs, descriptions, general locations and contact telephone numbers. Published material can be indexed, copied or cached by third parties beyond our control. Advertisers can request corrections or removal by emailing info@abella1.com. When an advertisement expires, we delete the advertisement and its photographs from our active systems immediately; independently cached copies may remain outside our control.

6. Sensitive personal information Adult advertising information may reveal details about a person’s sex life or sexual orientation and constitute special category personal data. Where we process such data, we identify an Article 6 UK GDPR lawful basis and an applicable Article 9 condition. Where explicit consent is relied upon, we obtain a specific, recorded affirmative agreement before processing, and provide a way to withdraw it. Advertisers must have appropriate authority to submit images and personal information about every identifiable person featured. We may reject material where identity, consent or permission is unclear.

7. Why we process information and lawful bases We process contact, listing and payment information to respond to enquiries, agree and perform advertising services, administer manual purchases and renewals, and handle refunds (contract or steps requested before entering a contract). We process accounting records where required by law (legal obligation). We process security logs, complaints and fraud-prevention information where necessary for our legitimate interests in keeping the service secure and protecting users, subject to balancing their rights. We process optional electronic marketing and non-essential cookies on consent or another basis only where applicable law permits. For any sensitive profile information, the additional Article 9 condition described above is required. We do not treat the mere use of the Website as consent to every processing activity.

8. Payments and renewals Advertising purchases and renewals are manual, not automatic. We accept bank transfers and card payments processed by Nochex Limited. We do not receive or store customers’ full payment card numbers or security codes. Nochex processes card information in accordance with its applicable privacy notice. We may retain billing contact information, amounts, dates, payment references, invoices, refund records and payment disputes for appropriate contractual, accounting and legal purposes.

9. Recipients and disclosures We share private advertiser information only as necessary with service providers supporting payments, website hosting and technical operations, and where legally required with authorities or professional advisers. Card payments are handled by Nochex Limited; website hosting is provided by GoDaddy. We do not share private advertiser details with other businesses for their independent marketing. Published advertisement details are publicly accessible as described above. Appropriate data processing agreements are used where required.

10. Cookies and electronic marketing We use Google Analytics or other analytics/tracking technologies in addition to cookies required for website operation and security. Where analytics or other technologies are not strictly necessary, we seek consent before setting or accessing them and provide a way to reject or withdraw consent. A cookie notice or settings panel should identify the actual providers, purposes and durations of cookies and similar technologies used on the Website. Electronic marketing is sent only where permitted by applicable UK law, including PECR, and includes an appropriate opt-out.

11. Retention and deletion Passport and ID copies are deleted after verification, including copies in email, messaging and cloud storage. Advertisements and their photographs are deleted from our active systems immediately when the advertisements expire. Other account and correspondence information is retained only for as long as needed to administer the service, respond to disputes, meet legal obligations or protect legitimate interests. Payment and accounting records are retained for applicable statutory periods. Technical and analytics records are retained according to their operational purposes and configured provider settings. We securely delete or anonymise personal information when no longer needed. Deletion from our active systems may not remove independent third-party caches or copies already made.

12. International transfers Our website is hosted by GoDaddy, and we use Nochex Limited for card payments and analytics technologies such as Google Analytics. These providers may process information outside the United Kingdom. Where a restricted international transfer occurs, we use an applicable UK adequacy regulation or another lawful safeguard, such as the UK International Data Transfer Agreement or UK Addendum, where required. Further details of applicable safeguards may be requested at info@abella1.com.

13. Security and data incidents We use appropriate organisational and technical safeguards, including restricting access to sensitive advertiser and verification information, protecting accounts and communications, and reviewing access and deletion procedures. No system is entirely risk-free. We investigate personal data breaches, record them as required and notify the ICO without undue delay and, where required, within 72 hours of becoming aware. We notify affected individuals without undue delay when legally required because of high risk.

14. Your rights Subject to conditions and exceptions, individuals may request access, correction, erasure, restriction, portability and may object to certain processing. They may withdraw consent where consent is relied on, and object at any time to direct marketing. Rights relating to qualifying automated decisions may also apply. Contact info@abella1.com. We may verify identity proportionately before disclosing information and will normally respond within one month, subject to lawful extensions. These rights are not absolute, including where records must be retained for legal obligations or legal claims.

15. Automated decisions A member of our team reviews and decides whether to publish or remove advertisements. We do not make these publication or removal decisions solely by automated means. Website analytics or automated security tools may operate separately, but we do not use solely automated decision-making producing legal or similarly significant effects in relation to these advertising decisions.

16. External websites Links to third-party websites are provided for convenience. Independent third parties control their own privacy practices; review their notices before providing information to them.

17. Complaints Please contact info@abella1.com if you have concerns about our use of personal information. You also have the right to complain to the UK Information Commissioner’s Office (ICO): ico.org.uk, telephone 0303 123 1113. Other competent supervisory authorities may also be available where applicable.

18. Changes to this notice We may update this notice when our practices or legal requirements change. We will display the updated date and provide additional notice where appropriate. Where consent is required for new processing, we will obtain it before that processing.

19. Contact Abella1 LTD • Company number 13802852 • Registered office: 71–75 Shelton Street, Covent Garden, London WC2H 9JQ, United Kingdom • Website: https://www.abella1.com • Email: info@abella1.com.