CORNERPULSE LTD PRIVACY POLICY

1. Introduction

CORNERPULSE LTD. and its affiliates (“CORNERPULSE LTD”, “we”, “our” or “us”) takes the privacy and protection of personal information seriously. By visiting our website or using our services, you acknowledge and accept the practices and policies outlined in this Privacy Policy (the “Privacy Policy”). This Privacy Policy applies to all information collected from or about you by CORNERPULSE LTD. The purpose of this document is to help you understand what information is collected from or about you, how this information is used and protected, and what options you have with regard to this information.

2. Information Covered by this Policy

For purposes of this Privacy Policy, our use of the term “Information” means any and all information we receive from or about you. This may include information collected from you directly or indirectly, manually or otherwise, or via electronic devices.

Information is divided into two distinct categories:

• Non-Personal Information: Information which does not personally identify a person.
• Personal Information: Information related to a natural person that can be used to directly or indirectly identify the person, such as names, addresses, e-mail addresses, and phone numbers, as well as other non-public information that is associated with the foregoing.

3. Acceptance of Terms

We obtain and use Information in accordance with this Privacy Policy. We will ask for your consent before using Personal Information in a manner other than as set out in this Privacy Policy.

BY USING OUR SERVICES OR VISITING OUR SITE OR SUBMITTING INFORMATION THROUGH THE SERVICES OR VIA OUR SITE, YOU EXPRESSLY CONSENT TO THE COLLECTION, PROCESSING, AND USE OF YOUR INFORMATION IN ACCORDANCE WITH THIS PRIVACY POLICY.

IF YOU DO NOT AGREE WITH OUR PRIVACY POLICY, PLEASE DO NOT USE OUR SITE, PLATFORM, OR SERVICES.

4. How we Obtain and Collect Your Personal Information

You may provide us with your personal information voluntarily. However, we may also receive personal information about you from third parties such as marketing agencies, market research companies, our suppliers, contractors, and public agencies.

We collect Personal Information that you give us by filling in forms, using our Services, setting up an account, contacting us by phone or email, and through business dealings.

5. Information We Collect

When you register as an individual or on behalf of an organization, we may collect:

• Your first and last names, gender, date of birth, place and country of birth, nationality, and country of residence.
• Government-issued identification numbers and photo identification.
• Company name, job title, company/personal email address, telephone numbers, and corporate industry/regulatory status.
• Technical telemetry: Internet protocol (IP) address, browser version, operating system, and platform details.
• Behavioral data: Time and length of visits, page interaction data (scrolling, clicks), and referral URLs.

6. Cookies

We, and third parties we may partner with, may store and retrieve information on and from your browser by placing a small text file called a “Cookie” in the browser files of your device. By using the Services or the Site, you agree that we may use, store, and access Cookies.

7. Use of Personal Information

Personal Information is used to:

• Create and manage the business relationship and support your user accounts;
• Facilitate, execute, and verify digital currency orders and transactions;
• Bill users, resolve disputes, and maintain operational stability;
• Comply with regulatory obligations and monitor anti-money laundering (AML) protocols;
• Enhance security, prevent fraud, market abuse, malware, or security breaches; and
• Deliver service updates and relevant notifications.

8. Disclosure of Personal Information

Except as stated in this Privacy Policy, we do not disclose or share your Personal Information with third parties without authorization. We disclose information to:

• Subsidiaries, joint ventures, or entities under common control;
• Legal, regulatory, or governmental authorities as required by Nigerian law;
• Authorized third-party service providers (analytics, hosting, payment processors, KYC verifiers) working on our behalf; and
• Successors in interest in the event of a merger, acquisition, or asset transfer.

9. Retention of Your Personal Information

We retain your Personal Information for as long as is necessary for the purposes for which it is processed, as required to comply with statutory legal obligations, or to establish, exercise, or defend legal rights.

10. Data Transfers

We may transfer Personal Information to recipients in countries outside the African Union (AU). In such cases, we take appropriate measures—such as Commission-approved standard contractual clauses—to ensure recipient entities safeguard your personal data.

11. Your Rights under the Nigerian Data Protection Act

Under the Nigerian Data Protection Act, you have explicit rights regarding your personal records, including:

• The right to access your Personal Information;
• The right to restrict or object to the processing of your data;
• The right to request rectification of inaccurate or incomplete records;
• The right to request erasure of your personal data where retention is no longer legally mandated; and
• The right to data portability in a structured, machine-readable format.

12. Contact Us and Opting-Out

If you wish to exercise any of your rights, submit a data export/erasure request, or inquire about our data governance practices, please contact our Compliance Officer at: info@cornerpulseltd.com.