Privacy Notice

Sebastian Hunter Holdings Limited is the operator of Project Polaris / VoLTE Partners and the data controller responsible for personal data processed through the Polaris platform.

VoLTE Mobile is the operating brand and underlying business presented through the platform. Where securities are lawfully issued under the current Polaris legal authority, Sebastian Hunter Holdings Limited is also the issuer.

Registered office: 5 Fort George Road, Stony Hill, Kingston 9, St. Andrew, Jamaica.

Depending on how you interact with Polaris, we may process information including your name, organisation, position, email address, country, stated area of interest, messages submitted to us, access-request status and related review information.

For approved users, we may also process account and authentication information, investor or partner identity information, records connected with authorised participation, investment activity, legal ownership records, document access and communications associated with the relationship.

We may process limited technical and security information reasonably necessary to operate, authenticate, protect and troubleshoot the platform.

We process personal data for specified purposes connected with operating Polaris, including reviewing access requests, responding to enquiries, evaluating prospective strategic relationships, administering approved accounts, securing authenticated access, communicating with approved participants and maintaining appropriate corporate, investment and ownership records.

Personal data may also be processed where necessary to comply with applicable law, regulatory requirements, lawful requests, record-keeping obligations, fraud prevention, information-security requirements or the establishment, exercise or defence of legal rights.

We do not treat information supplied for an access request as permission to use that information for unrelated direct marketing.

Personal data is processed in accordance with applicable Jamaican data-protection requirements. We seek to collect only information that is adequate, relevant and reasonably necessary for the purpose for which it is requested.

Where consent is the appropriate basis for a specific processing activity, the consent requested will identify the relevant purpose. Consent may be withdrawn subject to any lawful basis or legal obligation that requires continued processing.

We do not sell personal data.

Personal data may be made available to authorised personnel and to service providers that support the secure operation of Polaris, including providers used for database, authentication, hosting or technology infrastructure. Supabase is currently used within the Polaris authentication and data architecture.

Information may also be disclosed where required by law, regulation, court order, lawful regulatory request or where reasonably necessary to protect legal rights, prevent fraud or secure the platform.

Some technology service providers may process or store information outside Jamaica. Where personal data is transferred outside Jamaica, Sebastian Hunter Holdings Limited is responsible for addressing the requirements of the Data Protection Act, including the applicable conditions, protections and safeguards governing cross-border processing.

Polaris uses authentication and session technologies required to provide and secure approved account access.

At the effective date of this Notice, the current Polaris build does not use advertising pixels or behavioural advertising trackers. If non-essential analytics, advertising or similar tracking technologies are introduced, this Notice and any required consent controls will be updated before those technologies are used.

Access-request information that does not become part of an approved ongoing relationship may ordinarily be retained for up to 24 months after the request is finally closed, unless a shorter or longer period is reasonably required by law, a dispute, security requirements or another legitimate record-keeping purpose.

Records associated with an approved investor, shareholder, partner or other continuing relationship are retained for so long as reasonably necessary to administer that relationship and for any additional period required by applicable corporate, securities, accounting, tax, fraud-prevention or other legal record-keeping obligations.

Legal ownership and corporate records may be retained for the period required by applicable law and corporate-record obligations even after an account is no longer active.

We use technical and organisational measures intended to protect personal data against unauthorised or unlawful processing, accidental loss, destruction, alteration or disclosure.

Access to private investor information is restricted through authenticated account controls and server-side access rules. Security controls are reviewed as the platform and operating environment evolve.

Subject to applicable Jamaican law, you may have rights relating to information held about you, including rights to be informed, request access, request correction, restrict certain processing, withdraw consent where processing depends on consent and raise concerns regarding qualifying automated decision-making.

Requests should be sent to privacy@voltemobile.com. We may need to verify your identity before acting on a request.

If you believe your personal data has not been handled appropriately, you may contact us first so that the matter can be reviewed. You may also have the right to raise a complaint with the Office of the Information Commissioner, Jamaica.

Information about the Office of the Information Commissioner is available at oic.gov.jm.

This Notice may be updated where our processing activities, technology, regulatory requirements or legal obligations materially change. The current effective date and policy version will identify the notice applicable at the relevant time.

Privacy Notice version: POLARIS-PRIVACY-2026-08-23.