Privacy Policy

Last updated: February 2026

1. Introduction

Runway Trade Solutions LLC ("Runway," "we," "us," or "our") is committed to protecting the privacy of individuals who use our platform and website. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website or use the Runway platform and services.

By using the Services, you consent to the data practices described in this Privacy Policy. If you do not agree with the terms of this policy, please do not access or use the Services.

2. Information We Collect

Information You Provide Directly

We collect information you provide when you submit an inquiry, register for an account, or interact with the platform, including:

• Identity information: name, title, date of birth, government-issued identification
• Contact information: email address, phone number, mailing address
• Business information: company name, industry, annual revenue, EIN/tax identification, ownership structure
• Financial information: bank account details, invoice data, payment history
• Documentation: contracts, financial statements, corporate documents submitted during onboarding
• Communications: messages, support requests, and other correspondence with Runway

Information Collected Automatically

When you access the platform or website, we may automatically collect:

• Log data: IP address, browser type and version, pages visited, time and date of visits
• Device information: device type, operating system, unique device identifiers
• Usage data: features used, actions taken, session duration
• Cookies and similar tracking technologies (see Section 7 below)

Information from Third Parties

We may receive information about you from third parties in connection with our compliance and due diligence processes, including identity verification services, credit bureaus, sanctions screening providers, and public records databases.

3. How We Use Your Information

We use the information we collect to:

• Provide, operate, and improve the Services
• Process inquiries and onboard program participants
• Conduct KYC, AML, and sanctions screening as required by applicable law
• Facilitate invoice approvals, funding requests, and payments
• Communicate with you about your account, programs, and service updates
• Comply with legal and regulatory obligations
• Detect, investigate, and prevent fraud or other unlawful activity
• Analyze platform usage to improve functionality and user experience
• Enforce our Terms and Conditions and other agreements

4. Legal Basis for Processing

We process your personal information on the following legal bases:

• Contractual necessity: Processing required to enter into or perform our agreements with you
• Legal obligation: Processing required to comply with applicable laws and regulations, including AML/KYC requirements
• Legitimate interests: Processing necessary for our legitimate business interests, such as fraud prevention and platform security
• Consent: Processing based on your consent, which you may withdraw at any time

5. How We Share Your Information

We do not sell your personal information. We may share your information with:

• Program counterparties: As necessary to operate SCF and ARF programs — for example, sharing supplier information with the anchor buyer or funder as required by the program structure
• Institutional funders: Information required to evaluate and fund program transactions
• Service providers: Third-party vendors who assist us in operating the platform (e.g., cloud hosting, identity verification, document management), under appropriate data processing agreements
• Compliance and regulatory authorities: As required by applicable law, regulation, court order, or to respond to lawful requests from government agencies
• Sanctions and AML screening providers: To fulfill our legal compliance obligations
• Successors: In connection with a merger, acquisition, or sale of substantially all of our assets

In all cases, we share only the minimum information necessary and require that recipients protect your information consistent with this Privacy Policy.

6. Data Retention

We retain your information for as long as necessary to fulfill the purposes described in this Privacy Policy, maintain your account, comply with legal and regulatory obligations (including AML record-keeping requirements, which may require retention for five years or more), resolve disputes, and enforce our agreements. When retention is no longer necessary, we securely delete or anonymize your information.

7. Cookies and Tracking Technologies

We use cookies and similar technologies to operate and improve the platform and website. Cookies are small data files stored on your browser. We use:

• Essential cookies: Required for the platform to function, including session authentication and security tokens
• Functional cookies: To remember your preferences and settings
• Analytics cookies: To understand how users interact with our platform and website

You can control cookies through your browser settings. Disabling certain cookies may affect platform functionality. We do not use cookies for cross-site behavioral advertising.

8. Data Security

We implement appropriate technical and organizational measures to protect your information against unauthorized access, disclosure, alteration, or destruction. These include encryption of data in transit and at rest, access controls and authentication requirements, regular security assessments, and employee training on data protection. However, no method of transmission over the internet or electronic storage is completely secure, and we cannot guarantee absolute security.

If you become aware of any security vulnerability or breach relating to the Services, please notify us immediately at support@runwaytradesolutions.com.

9. Your Rights and Choices

Depending on your location and applicable law, you may have the right to:

• Access the personal information we hold about you
• Request correction of inaccurate or incomplete information
• Request deletion of your personal information (subject to legal retention obligations)
• Object to or restrict certain processing activities
• Withdraw consent where processing is based on consent
• Receive a copy of your information in a portable format

To exercise any of these rights, please contact us at support@runwaytradesolutions.com. We will respond to your request within the timeframe required by applicable law. Note that certain requests may be limited where we are required to retain information by law or to fulfill our contractual obligations.

10. Children's Privacy

The Services are intended for business use and are not directed to individuals under the age of 18. We do not knowingly collect personal information from minors. If you believe we have inadvertently collected such information, please contact us and we will promptly delete it.

11. International Data Transfers

Runway is headquartered in the United States, and your information is processed and stored in the United States. If you are located outside the US, your use of the Services involves the transfer of your information to the United States, where data protection laws may differ from those in your jurisdiction. By using the Services, you consent to this transfer.

12. Third-Party Links

Our website may contain links to third-party websites. We are not responsible for the privacy practices of those sites and encourage you to review their privacy policies before providing any information.

13. California Privacy Rights

California residents may have additional rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA), including the right to know what personal information is collected, the right to delete personal information, and the right to non-discrimination for exercising privacy rights. To submit a California privacy rights request, contact us at support@runwaytradesolutions.com.

14. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by posting the updated policy on our website with a revised "last updated" date. Your continued use of the Services after any changes constitutes your acceptance of the updated policy.

15. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:

Runway Trade Solutions LLC
Email: support@runwaytradesolutions.com