European Accessibility Act

1. Accessibility Statement

Circit is committed to making our digital financial services accessible in accordance with the European Accessibility Act (EAA) as transposed underS.I. No. 636 of 2023, European Union (Accessibility Requirements of Products and Services) Regulations 2023, and to ensuring our services are accessible to the widest possible audience, regardless of technology or ability.

As a regulated Account Information Service Provider (AISP) authorised by the Central Bank of Ireland, we recognise our responsibility to provide inclusive financial services that serve all users, including persons with disabilities.

This accessibility statement applies to our “Services” which comprise:

Circit’s web application platform (SAAS Platform) at circit.io
Circit’s Public-facing website atCircit | Confirmations Platform for Auditors – Verified & Independent (accessed through desktop or mobile web browser applications)

Additional customer support portals and documentation

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2. Compliance Status

Platform

Our platform is substantially compliant with the harmonised European standard EN 301 549 - Accessibility Requirements for ICT Products and Services (based on Web Content Accessibility Guidelines 2.1 AA standards) as required by the European Accessibility Act.

Website

Circit’s website is partially compliant with the harmonised European standard Accessibility Requirements for ICT Products and Services (based on Web Content Accessibility Guidelines 2.1 AA standards).

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3. Non-Compliant Content

The content listed below is what our review determined non-compliant with the EAA requirements. However the website falls out of scope of the Regulations as detailed in Section 3(4)(e) of theEUROPEAN UNION (ACCESSIBILITY REQUIREMENTS OF PRODUCTS AND SERVICES) REGULATIONS 2023 (archived content)

Website

Some images have missing or incomplete descriptions.
Some text may be difficult to read due to low colour contrast.
Some interactions in the website’s main navigation and in paginated navigation-lists may be hard to understand with a screen reader.

4. Accessibility Features

Our Services Include:

Keyboard Navigation: Full functionality available via keyboard without mouse dependency
Screen Reader Support: Compatible with assistive technologies
High Contrast Design: Color contrast ratios exceeding WCAG 2.1 AA standards
Scalable Text: Content can be enlarged up to 200% without loss of functionality
Clear Navigation: Consistent navigation patterns and skip links for efficient browsing
Alternative Authentication: Multiple secure authentication methods for different user needs
Accessible Forms: Clear labels, error messages, and input assistance
Structured Data: Properly formatted tables and financial information for screen readers

5. Testing and Validation

Our accessibility compliance has been verified through:

Automated Testing: Regular scans using industry-standard accessibility testing tools
Manual Testing: Comprehensive evaluation by accessibility experts
Screen Reader Testing: Verification across multiple assistive technologies
External Testing: Independent accessibility assessment by third party

6. Financial Services Accessibility

As a regulated Account Information Service Provider, we have implemented specific accessibility measures for financial services:

Account Information Display: Financial data presented in accessible formats with clear labeling
Security Features: Alternative authentication methods that don't exclude users with disabilities
Error Handling: Clear, understandable error messages and recovery options
Data Export: Account information available in CSV format

7. Compliance Governance

We maintain ongoing accessibility compliance through:

Regular Monitoring: Periodic reviews of accessibility / regulatory developments
User Feedback: Continuous collection and response to accessibility feedback
Staff Training: Periodic accessibility training for all team members
Technology Updates: Ensuring new features meet accessibility standards
Regulatory Compliance: Regular review of EAA and other accessibility requirements

8. Preparation of this Accessibility Statement

This statement was prepared on the 28th of June 2025 and is based on:

Self-assessment conducted in accordance with EAA requirements
External accessibility audit completed in June 2025
Ongoing monitoring and regular accessibility reviews

Our accessibility assessment methodology follows the Website Accessibility Conformance Evaluation Methodology (WCAG-EM) and EAA compliance requirements.

Platform

Circit’s Website and Product were tested for compliance against the Web Content Accessibility Guidelines (WCAG 2.1) Level-AA in June 2025. The review was carried out using the Website Accessibility Conformance Evaluation Methodology (WCAG-EM) approach to deciding on a sample of pages to test. A detailed Gap Analysis of the Technical requirements was conducted of our Services against the WCAG 2.1 AA standards.

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9. Feedback and Contact Information

This statement was prepared by the Compliance function. For any queries relating to The European Accessibility Act or Circit’s adherence please contact compliance@circit.io

Accessibility Support / Complaints

If you experience any accessibility barriers or need assistance accessing our services:

Email: compliance@circit.io
Response Time: Circit will respond within 30 days of receiving a formal complaint.

10 . Enforcement Procedure

If you are dissatisfied about how we respond to your request or complaint, you can complain to the Office of the Ombudsman under the terms of the Disability Act 2005.

Office of the Ombudsman
6 Earlsfort Terrace
Dublin 2
D02 W773

Telephone: +353 (0)1 639 5600
Email: complaints@ombudsman.ie
Web: Make a complaint under the Disability Act

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Cookies

We respect your privacy and we are committed to ensuring that you are adequately informed on how you can manage your cookies.

1 What are Cookies?

1.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

1.2 Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

1.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

1.4 Cookies can be used by web servers to identify and track users as they navigate different pages on a website and identify users returning to a
website.

2 Our cookies

2.1 Our platform is separated into a public facing website (www.circit.io) and an application with access restricted to authenticated users (app.circit.io). These are separate systems and each uses a different set of cookies.

2.2 On www.circit.io we do not use any cookies of our own. The only cookies are provider cookies detailed in clause 3.2.3 On app app.circit.io we use session cookies, authentication cookies, security cookies and persistent cookies. The names of the cookies that we use and the purposes for which they are used, are set out below:
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2.3.1 On app.circit.io we use persistant cookies ai_session and ai_user to track users as they navigate the website AND improve the website's usability
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2.3.2 On app.circit.io we use a persistent cookie auth to validate authenticated users sessions

2.3.3 On app.circit.io we use a persistant cookie xsrf to prevent fraud and improve the security of the website

2.3.4 On app.circit.io, when using Single Sign On, we use a session cookie Identity.External to validate authenticated user sessions

3 Providers cookies

3.1 We use providers services for analytics on both www.circit.io and app.circit.io3.2 We use Google Analytics (GA) to analyse the use of our website (www.circit.io) and application (app.circit.io)
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3.2.1 GA generates statistical and other information about website use
by means of cookies.
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3.2.2 The analytics cookies used by our website have the following names: [_ga, _gat, __utma, __utmt, __utmb, __utmc, __utmz and __utmv].

3.2.3 The information generated relating to our website is used to create reports about the use of our website.
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3.2.4 The privacy policy for GA is available at http://www.google.com/policies/privacy/

3.3 We use Microsoft Application Insights (AI) to analyse the use of our application (app.circit.io)
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3.3.1 AI generates statistical and other information about website use by means of cookies.
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3.3.2 Information on data collection, retention and storage in AI is available at https://docs.microsoft.com/en-us/azure/application-i-sights/ app-insights-data-retention-privacy

3.3.3 Our AI data is stored within the EU.

4 Blocking cookies

4.1 Most browsers allow you to refuse to accept cookies; for example:

4.1.1 in Firefox (version 75) you can block all cookies by navigating to about:preferences#privacy and selecting the required level of protection; and

4.1.2 in Chrome (version 81), you can block all cookies by navigating to chrome://settings/content/cookies and selecting the required level of protection

4.2 Blocking all cookies will have a negative impact upon the usability of many websites.

4.3 If you block cookies, you will not be able to use all the features on
our website.

5 Deleting cookies

5.1 You can delete cookies already stored on your computer; for example:

5.1.1 in Firefox (version 75), you can delete cookies by navigating to about:preferences#privacy and clicking Clear Data inthe Cookies and Site Data section; and

5.1.2 in Chrome (version 80), you can delete all cookies by navigating to chrome://settings/clearBrowserData, checking the Cookies and other site data and clicking the Clear Data button.

5.2 Deleting cookies will have a negative impact on the usability of many websites.