1. Introduction Welcome to Vatebra Limited, we have created this Privacy Policy (the “Policy”) that applies generally to the business of VATEBRA LIMITED, to describe your privacy rights regarding how we collect, use, and protect your information; including any nonpublic, personal information (Personal Data) for our users {“Users”}. Vatebra Limited provides this Privacy Policy to let you know our policies and procedures regarding the collection, use and disclosure of information through products/online services that are owned or controlled by Vatebra Limited and that post a link to or incorporate the terms of this Privacy Policy, as well as any information collected offline in connection with our services and through other means such as our events and marketing activities. Certain Vatebra Limited products may have their own privacy documentation describing how your information is handled. Please review this Policy whenever you interact with us to stay updated about our information privacy practices as well as ways in which you can protect your privacy. By accessing or choosing to use any of our platforms, you agree to be bound by this Policy.

2. Collection of Personal Information Should you interact or access any of Vatebra’s platforms, you may be asked to provide your Personal Data, and we shall use your Personal Data in accordance with this Policy. We may also acquire personal information from trusted third-party sources and engage third parties to collect personal information on our behalf. Types of data we collect include: • Personal - First name and last name, home address, email address, telephone number, photos, date of birth, bank account information, etc. • Third-party – When you grant us access to a Third-Party Service, we may collect with your consent personal data that is already associated with your Third-Party Service’s account, such as name, email address, activities etc. • Usage – Usage data is automatically collected when using our products. When you interact through a mobile device, we may collect certain information automatically, including but not limited to, your type of mobile device, your mobile device unique ID, the IP address, your mobile operating system etc. • Device - We may request certain permissions that allow us to access your device’s data. By default, these permissions must be granted by you before the respective information can be accessed. Once the permission has been given, it can be revoked at any time.

3. How Do We Use Your Information? We may use your personal data for the following purposes: • Service and product improvement. • Provide product and service requests as well as confirmations. • Identity verification. • Provide technical notices, updates, security alerts, and support and administrative messages. • Respond to your comments, questions, and requests and provide customer service. • Carry out any other purpose for which the information was collected. • Fulfil legal and contractual obligations to you. • Detect and prevent fraud and other illegal activities. • Communicate with you about products, services, offers, promotions, rewards, and events offered by Vatebra Limited.

4. Sharing Information with Third Parties User information may be shared with third-party service providers for the purpose of validating user credentials, securing data storage, marketing, customer service, and other applicable services. Vatebra Limited also may share non-personally identifiable user information with third parties that help us better understand how you use our service or help us detect and prevent fraud and other unauthorized or suspicious activity. Except as expressly disclosed in this Privacy policy, Vatebra Limited will not sell or disclose user information to third parties. We will not sell, rent, share, or trade personally identifiable information to third parties.

5. Security of User Personal Information Personal Data are collected and stored with robust cloud security. We have implemented physical, technical, and procedural safeguards to protect your information from unauthorized access, disclosure, alteration, or destruction. Through computer safeguards such as firewalls and data encryption and authorized access to personally identifiable information only for those employees who require it to fulfill their job responsibilities.

6. How Long Do We Keep Your Data? We will keep your personal data only for as long as is necessary for the purposes set out in this privacy policy. You have the right to request deletion of the data we have collected about you. However, we will retain and use your personal data to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies.

7. Disclosure of Your Personal Data Aside sharing your data with third party services, we may also disclose your information with: • Law Enforcement Under certain circumstances, we may be required to disclose your personal data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency). • Other Legal Requirements We may disclose your personal data in belief that such action is necessary to comply with a legal obligation protect and defend the rights or property of the company prevent or investigate possible wrongdoing in connection with the service to protect the personal safety of users of the service or the public protect against legal liability.

8. Your Rights • You have a right to agree to this policy statement and to withdraw your consent at any time in the future. • You have the right to request and access the data we have of you, as well as information of what we do with it. • You have the right to correct your personal data if it is inaccurate by notifying us. Your request will be handled promptly. • You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you about this before collecting your data. • You have the right to request the deletion of information we have about you. Note that if your personal information is deleted, you may no longer access or be able to use certain products as your account may become deactivated. • If you do not wish to receive offers or other notices from us in the future, you can "opt-out" by contacting us as indicated at the end of this Privacy Policy or by following the "unsubscribe" instructions in any communication you receive from us.

9. Changes to This Document This document will be reviewed on a yearly basis by our Data Protection Officer. If we make any changes, we’ll include that here and if there are major changes, we’ll notify you by email. This policy was last updated on 1st August 2022.

10. Contact Us, If you have any questions, comments, or concerns regarding these Terms or the Services, please contact us at: Head Office Plot 1187, Abimbola Awoniyi Close, Kasumu Ekemode Street Saka Tinubu, Victoria Island, Lagos, Nigeria. T: +234 906 2547 247 E: info@vatebra.com