Privacy Policy

This Privacy Policy (the "Policy")governs the use of your personal information on our electronic tradingplatform, including any website or mobile application (the "Site")for accessing the platform, and any services provided through the platform(collectively, the "Platform") (the "Services") provided byMadu and its affiliates (the "Company", "Madu","we", "us" or "our").

This Privacy Policy is strictly restricted toonly our services and therefore does not apply to services that are not ownedor controlled by us, including third-party platforms/websites. We are committedto handling all personal data provided to us in compliance with both applicableand model data privacy and protection laws.

Madu takes your right to privacy seriously.You have a right to know what we do with your personal information so that youcan make informed choices while visiting our website.

We recommend that you read our Privacy Policycarefully to understand our views and practices regarding your personal dataand information, its collection and usage. By accessing and using our Platformand/or Services, you signify acceptance of the terms of this Privacy Policy.Where we require your consent to process your personal information, we will askfor your consent to the collection, use, and disclosure of your personalinformation as described further below. We may provide additional "just-in-time"disclosures or information about our data processing practices. These noticesmay supplement or clarify our privacy practices or may provide you withadditional choices about how we process your data.

If you do not agree with or you are notcomfortable with any aspect of this Privacy Policy, you should immediatelydiscontinue access or use of our Services.

We may modify this Privacy Policy from time totime which will be indicated by changing the date at the top of this page. Ifwe make any material changes, we will notify you by email (sent to the emailaddress specified in your account), by means of a notice on our Services priorto the change becoming effective, or as otherwise required by law.

You agree to hold us harmless of the releaseof any personal data pursuant to our Privacy Policy. This Privacy Policydescribes the way in which the company deals with the information and data youprovide to us to enable us to manage your relationship with us. We will processany personal information provided to us via the Platform and other relatedmeans.

Your personal data will not be disclosed tothird parties, unless such disclosure is necessary for the processing of yourrequest, such as creating an account on the Platform (the "MaduAccount"), effecting transactions on your Madu Account or to carry outverification procedures.

Whatinformation do we collect?

As part of our operations, we collect andprocess certain types of information (such as names, telephone numbers,addresses, etc.) of individuals/businesses that make them easily identifiable.These individuals/businesses include current, past, and prospective employees,guarantors, referees, suppliers/vendors, customers or former customers, andother individuals/businesses whom we communicate or deal with, jointly and/orseverally ("designated as Data Subject(s)").

You may voluntarily provide us with certainPersonal Information, to enable you to gain access to and use our services.This information relates to an identified person or information that can beused to identify you.

Your Personal Information will be processedsubject to and in accordance with the requirements of applicable dataprotection laws globally.

We will always solicit for your consent beforesharing or disclosing your Personal Information with a third party except asmay be required for the purpose of providing you with our services or underapplicable legislations.

We may collect the following types ofinformation from you:

Business Information: Full nameof your business with registration details, incorporation documents, Tax IDnumber, country of operations, details of Directors and shareholder with validmeans of identification, signature, utility bills, photographs of promoters -their phone numbers, emails, and home addresses. This information is requiredto be provided to us by filling in the forms on the website or any otherinformation you submit to us via the website or email.

Financial Information: Bankaccount information, Transaction history, trading data, and/or taxidentification. Details of the transactions you carry out with us via the Site,including details of payment methods used.

Information we may collect from youautomatically. To the extent permitted under the applicablelaw, we may collect certain types of information automatically, such aswhenever you interact with the Sites or use the Services. This informationhelps us address customer support issues, improve the performance of our Sitesand Services, provide you with streamlined and personalized experience, andprotect your account from fraud by detecting unauthorized access.

Information collected automatically includes:

• Online     Identifiers: Geo location/tracking details, browser     fingerprint, operating system, browser name and version, and/or personal     IP addresses;
• Usage     Data: Authentication data, security questions,     click-stream data, public social networking posts, and other data     collected via cookies and similar technologies. Details of your visits to     the website including, but not limited to, location data, weblogs and other     communication data.

Other information and data about you which wemay collect, use, and process include the following:

• Transaction     history Information that we may receive about you from other sources such     as credit information;
• Records     of correspondence received via the website, email & telephone.
• Your     responses to surveys or customer research that we carry out from time to     time;
• Details     of the transactions you carry out with us via the website, telephone or     other means, including details of payment methods used.

PurposeLimitation

We collect Personal Information only foridentified purposes and for which consent has been obtained. Such PersonalInformation cannot be reused for another purpose that is incompatible with theoriginal purpose, except consent is obtained for such purpose.

DataProcessing Principles

Your personal data will be:

• collected     and processed in accordance with specific, legitimate, and lawful     purposes, consented to by you;
• adequate,     accurate and without prejudice to the dignity of the human person;
• stored     only for the period within which it is reasonably needed; and
• secured     against all foreseeable hazards and breaches such as theft, cyberattack,     viral attack, dissemination, manipulations of any kind, damage by rain,     fire, or exposure to other natural elements.

DataMinimization

We limit Personal Information collection andusage to data that is relevant, adequate, and necessary for carrying out thepurpose for which the data is processed. We will evaluate whether and to whatextent the processing of Personal Information is necessary and where thepurpose allows, anonymized data will be used.

Why do weprocess your Personal Information?

We collect and process personal information tocomply with our Know Your Customer ("KYC") obligations underapplicable laws and regulations, and Anti-Money Laundering laws andregulations.

Our LawfulBasis for Processing Personal Information

We use your Personal Information to furnishour contract with you, such as when we provide you with products or services orcommunicate with you about them. This includes when we use your personalinformation to take and handle orders and process payments.

Additionally, we will only use and processyour personal data as permitted by applicable data protection laws. We have setout below a description of all the legal basis we may rely on to process yourpersonal data:

• Where     you have given us consent to the processing of your personal data for one     or more specific purposes;
• where     processing is necessary for the performance of a contract to which you are     a party or to take steps at your request prior to entering into a     contract;
• where     processing is necessary for compliance with a legal obligation to which we     are subject;
• where     processing is necessary to protect your vital interests or the vital     interests of another natural person;
• where     processing is necessary for the performance of a task carried out in the     public interest or in exercise of an official public mandate vested in us,     and;
• for     the purpose of the legitimate interests pursued by us as data controller     or data processor, or by a third party to whom the data is disclosed.

Note that we may process your personal datafor more than one lawful ground depending on the specific purpose for which weare using your personal data. Please contact us by sending an email to:contact@madupay.com, if you need details about the specific legal ground we arerelying on to process your personal data where more than one ground may havebeen used to process your personal data.

For the purpose of this Privacy Policy,consent means any freely given, specific, informed, and unambiguous indicationof the Data Subject's wishes by which they, through a statement or a clearaffirmative action, signify their agreement to the processing of PersonalInformation relating to them.

Use of yourPersonal Information

Madu uses the information collected for thefollowing purposes:

• We may     use your personal information and data together with other information for     the purposes of processing, operating and managing your Madu Account.
• To     maintain legal and regulatory compliance; most of our core Services are     subject to laws and regulations requiring us to collect, use, and store     your personal information in certain ways. For example, Madu must identify     and verify customers using our Services in order to comply with Anti-Money     Laundering laws across jurisdictions. This includes collection and storage     of your business records. In addition, we use third parties to verify your     identity by comparing the personal information you provide against     third-party databases and public records. When you seek to link a bank     account to your Madu Account, we may require you to provide additional     information which we may use in collaboration with service providers     acting on our behalf to verify your identity or address, and/or to manage     risk as required under applicable law. If you do not provide personal     information required by law, we will have to close your account.
• Regularly     providing you with information about promotional offers, products and     services.
• Monitoring     transactions for the purposes of preventing fraud, irregular gaming, money     laundering and cheating.
• Conducting     screening of customers against Politically Exposed Persons (PEP) and     global sanctions lists, global monitoring watchlists and adverse media to     avoid violating various sanctions.
• To     provide customer service; We process your personal information when you     contact us to resolve any questions, disputes, collect fees, or to     troubleshoot problems. Without processing your personal information for     such purposes, we cannot respond to your requests and ensure your     uninterrupted use of the Services.
• To     ensure quality control; We process your personal information for quality     control and staff training to make sure we continue to provide you with     accurate information. If we do not process personal information for     quality control purposes, you may experience issues on the Services such     as inaccurate transaction records or other interruptions.
• To     ensure network and information security; We process your personal     information in order to enhance security, monitor and verify identity or     service access, combat other malware or security risks, and to comply with     applicable security laws and regulations in our jurisdiction.
• For     any purpose that you provide consent; we will not use your personal     information for purposes other than those purposes we have disclosed to     you, without your permission. From time to time, and as required under     applicable law, we may request your permission to allow us to share your     personal information with third parties. In such instances, you may opt     out of having your personal information shared with third parties or     allowing us to use your personal information for any purpose that is     incompatible with the purposes for which we originally collected it or     subsequently obtained your authorization. If you choose to limit the use     of your personal information, certain features of Madu Services may not be     available to you.
• Madu     will also process your personal data for the purpose of carrying out     verification procedures in relation to your use of the services provided     on the website. We may also use your information to improve our products     and services and track/target the interest of our users so that we can     enhance user experience.

YourPrivacy Rights

After we collect your Personal Information,you have the right to contact us to exercise any of the following rightsguaranteed under applicable data protection laws, subject to certainlimitations:

• Right     to request access to your personal data: This     enables you to receive a copy of the personal data we hold about you and     to check that we are lawfully processing it. You will not have to pay a     fee to access your personal data (or to exercise any of your other     rights). However, we may charge a reasonable fee if your request is     clearly unfounded, repetitive, or excessive. Alternatively, we may notify     you of our refusal to comply with your request in these circumstances.     Where we have reasonable doubts concerning the identity of the natural     person/customer making the request for information, we may request the     provision of additional information necessary to confirm the identity of     the Data Subject. Where data is held electronically in a structured form,     such as in a Database, as the Data Subject, you have a right to receive     that data in a common electronic format;
• Right     to request correction of the personal data that we hold about you: This     enables you to have any incomplete or inaccurate data we hold about you     corrected, complete or updated, though we may need to verify the accuracy     of the new data you provide to us.
• Right     to request erasure or deletion of your personal data: This     enables you to ask us to delete or remove personal data where there is no     good reason for us continuing to process it. You also have the right to     ask us to delete or remove your personal data where you have successfully     exercised your right to object to the processing of your personal data     (see below), where we may have processed your information unlawfully or     where we are required to erase your personal data to comply with local     law. Note, however, that we may not always be able to comply with your request     for the erasure for specific legal reasons which will be notified to you,     if applicable, at the time of your request.
• Right     to object to the processing of your personal data:     Where we rely on a legitimate interest (or those of a third party), there     may be something about your situation that could justify an objection to     processing on this ground as you may feel it impacts your fundamental     rights and freedoms. You also have the right to object where we are     processing your personal data for direct marketing purposes. In some     cases, we may demonstrate that we have compelling, legitimate grounds to     process your information, which overrides your rights and freedoms.
• Right     to request restriction of processing of your personal data: This     enables you to ask us to suspend the processing of your personal data in     the following scenarios:
   
  • If      you want us to establish the data's accuracy;
   
  • Where      our use of the data is unlawful but you do not want us to erase it;
   
  • Where      you need us to hold the data even if we no longer require it as you need      it to establish, exercise or defend legal claims; or
   
  • You      have objected to our use of your data but we need to verify whether we      have overriding legitimate grounds to use it.
 
• Request     the transfer/portability of your personal data to you or to a third party: We     will provide you, or a third party you have chosen, your personal data in     a structured, commonly used, machine-readable format. Note that this right     only applies to automated information which you initially provided consent     for us to use or where we used the information to perform a contract with     you.
• Right     to withdraw consent at any time where we are relying on consent to process     your personal data: This will not affect the lawfulness of     any processing carried out before you withdraw your consent. If you     withdraw your consent, we may not be able to provide certain services to     you. We will advise you if this is the case at the time you withdraw your     consent. Your request will be reviewed by us and carried out except as     restricted by law or our statutory obligations. You may decline to provide     your Personal Information when it is requested by us, however, certain     services or all services may be unavailable to you. You may review and     update your Personal Information directly or by contacting us.
• Right     to be informed: To know what personal data is collected     about, and how long it is kept. The right to be informed gives you the     ability to understand what personal data we collect about you and how long     we retain it. This ensures transparency in how we handle your information,     helping you make informed decisions about your data privacy.
• Right     to be Forgotten or Deletion: This right allows you to request the     removal of your personal data from our records. This right empowers you to     have your information erased when it is no longer necessary for the     purpose it was collected or if you withdraw your consent.

Kindly note that these rights are notabsolute, for example some financial information with respect to clause (b),will not be rectified such as Means of ID, Financial history etc. Clause 4(d)will not extend to KYC and verification procedures. While Clause 4(i) issubject to Clause 9 to the extent that it relates only to transaction history.

Security ofyour Personal Information

Madu secures your personal information fromunauthorized access, use or disclosure. We secure the personally identifiableinformation you provide on computer servers in a controlled, secureenvironment, protected from unauthorized access, use or disclosure. Whenpersonal information (such as a credit card number) is transmitted to otherWebsites, it is protected through the use of standard encryption protocol.

InformationStorage and Protection

Madu will take all reasonable steps to ensurethat your information is secured and protected. We will process yourinformation in compliance with the relevant provisions of applicable dataprotection laws. We will only disclose personal information to other companieswithin associated or subsidiary companies and to business partners; successorsin title to our business and suppliers that are engaged to process suchinformation on our behalf. If you apply for an account with us then to help usmake credit decisions about you, to prevent fraud, to check your age andidentity and to prevent money laundering, we may use third parties includingcredit reference agencies who will record any searches on your file. We mayalso make enquiries of and disclose details of how you conduct your account tosuch agencies, security organizations and any other relevant third parties forfraud and money laundering prevention.

However, we cannot guarantee that loss,misuse, unauthorized acquisition, or alteration of your data will not occur.Please recognize that you play a vital role in protecting your own personalinformation. When registering with our Services, it is important to choose apassword of sufficient length and complexity, to not reveal this password toany third parties, and to immediately notify us if you become aware of anyunauthorized access to or use of your account.

Furthermore, we cannot ensure or warrant thesecurity or confidentiality of information you transmit to us or receive fromus by Internet or wireless connection, including email, phone, or SMS, since wehave no way of protecting that information once it leaves and until it reachesus. If you have reason to believe that your data is no longer secure, pleasecontact us using the contact information provided in the "Contact Us"section below.

Use ofCookies

As part of our commitment to providing auser-friendly experience, the company uses cookies on this Website/App to keeptrack of visits and enhance the services it offers. This clause outlines how wehandle cookies and ensure compliance with applicable data protection lawsglobally.

What AreCookies?

Cookies are small pieces of information sentfrom your browser to our server that allow us to recognize your device. Theyhelp us streamline your experience on our Website/App, manage essentialfunctions, and ensure our services are tailored to your preferences.

Why We UseCookies

When you register with us or continue to usethe Website/App, you agree to our use of cookies for the following purposes:

• Improving     Usability: To make your visit to the Website     user-friendlier by remembering preferences and simplifying navigation.
• Managing     Customer Logins: To streamline the login process, making     it easier and more secure for returning users.
• Security: To     protect against security issues and unauthorized access, helping to     safeguard user data.
• User     Preferences: To remember customer preferences such     as language settings and personalized content, so you can have a     consistent experience across sessions.

We do not set a persistent cookie to storeyour passwords to ensure that no one other than you can access your account.

YourPrivacy and Data Protection

We take all reasonable steps to handle yourinformation securely and in line with applicable data protection laws globally.

Third-PartyCookies and Sharing of Information

All cookies used on our website/app aremaintained and implemented either directly by us or by authorized thirdparties. We may work with third-party service providers to collect informationabout how you interact with our website/app. We are likely to disclosecookie-generated data to third-party processors who help us provide, protect,and improve our services.

These third parties may process your data incompliance with applicable data protection laws, and they may be located inother countries. We ensure that such third parties implement adequatesafeguards to protect your data, in line with our obligations under applicabledata protection laws. If you have any questions about our third-party serviceproviders, you can contact us at: contact@madupay.com.

ManagingCookies

You have the option to manage or disablecookies through your browser settings at any time. However, disabling cookiesmay affect your experience on our website/app, as some features rely on them.

For questions regarding this Cookie Clause orour privacy practices, please contact us at (contact@madupay.com).

Disclosureof Information

Madu will disclose your personal information,without notice, only if required to do so by applicable law, regulation,operating agreement, legal process, by a law enforcement agency or in the goodfaith or belief that such action is appropriate and necessary to:

• Conform     to the law or comply with legal processes served on Madu or the site;
• Protect     and defend the rights or property of Madu and,
• Act     under exigent circumstances to protect the personal safety or property of     users of Madu, or the public in the event of a claim or dispute regarding     your use of our services.

You hereby consent to such disclosures. Allsuch information will be held in accordance with this Privacy Policy.

Transfer ofPersonal Information to Foreign Country

Where Personal Information is to betransferred between different countries, we shall put adequate measures inplace to ensure the security of such Personal Information. We shall, amongother things, confirm whether the receiving country has adequate dataprotection laws.

Transfer of Personal Information betweencountries would be in accordance with the provisions of applicable dataprotection laws. We will therefore only transfer Personal Information betweencountries on one of the following conditions:

• the     consent of the Data Subject has been obtained;
• the     transfer is necessary for the performance of a contract between us and the     Data Subject or implementation of pre-contractual measures taken at the     Data Subject's request;
• the     transfer is necessary to conclude a contract between us and a third party     in the interest of the Data Subject;
• the     transfer is necessary for reason of public interest;
• the     transfer is for the establishment, exercise, or defense of legal claims;
• the     transfer is necessary to protect the vital interests of the Data Subjects     or other persons, where the Data Subject is physically or legally     incapable of giving consent.

We will take all necessary steps to ensurethat your Personal Information is transmitted in a safe and secure manner.Details of the protection given when your Personal Information is transferredbetween countries shall be provided to you upon request.

Retentionof Personal Information

We will retain your personal informationsecurely throughout the extant functionality of your Madu Account. We will onlyretain your personal information for as long as necessary to fulfill thepurposes for which we collected it, including for the purposes of satisfyingany legal, accounting, or reporting obligations or to resolve disputes.

We are statutorily obligated to retain thePersonal Information and data you provide us with to carry out our services andin compliance with laws and regulatory guidelines applicable to us and ourpartners. Therefore, even after discontinuance of our services, we will retaincertain Personal Information and transaction data to comply with theseobligations.

For all Personal Information and recordsobtained, used, and stored by us, we shall perform periodical reviews of thedata retained to confirm the accuracy, purpose, validity, and requirement toretain.

The length of storage of your PersonalInformation shall, amongst other things, be determined by:

• the     contract terms agreed between us and the Data Subject or as long as it is     needed for the purpose for which it was obtained; or
• where     the relationship has statutory implication or a required retention period;     or
• where     there is an express request for deletion of the Personal Information by     the Data Subject, provided that such request will only be treated where     the Data Subject is not under any investigation which may require us to     retain such Personal Information or there is no subsisting contractual     arrangement with the Data Subject that would require the processing of the     Personal Information; or
• where     we have another lawful basis for retaining that information beyond the     period for which it is necessary to serve the original purpose.

While retention requirements vary byjurisdiction, information about our typical retention periods for differentaspects of your personal information is described below:

• Personal     information collected to comply with our legal obligations under financial     or anti-money laundering laws may be retained after account closure for as     long as required under such laws;
• Contact     Information such as your name, email address and telephone number for     marketing purposes is retained on an ongoing basis until you unsubscribe.     Thereafter we will add your details to our suppression list to ensure we     do not inadvertently market to you;
• Content     that you post on our Site such as support desk comments, photographs,     videos, blog posts, and other content may be kept after you close your     account for audit and crime prevention purposes (e.g., to prevent a known     fraudulent actor from opening a new account);
• Records     of our telephone calls with you may be kept for a period of up to six     years;
• Information     collected via technical means such as cookies, web page counters and other     analytics tools is kept for a period of up to one year from the expiry of     the cookie.

Third PartySites and Services

If you authorize one or more third-partyapplications to access your Madu Services, the information you have provided toMadu may be shared with those third parties. A connection you authorize orenable between your Madu account, and a third-party account, paymentinstrument, or platform is considered an "account connection". Unlessyou provide further permissions, Madu will not authorize these third parties touse this information for any purpose other than to facilitate your transactionsusing Madu Services.

Please note that third parties you interactwith may have their own privacy policies, and Madu is not responsible for theiroperations or their use of data they collect. Information collected by thirdparties, which may include such things as contact details, financialinformation, or location data, is governed by their privacy practices and Maduis not responsible for unauthorized third-party conduct initiated and concludedby you. We encourage you to learn about the privacy practices of those third parties.

Information that we share with a third partybased on an account connection will be used and disclosed in accordance withthe third party's privacy practices. Please review the privacy notice of anythird party that will gain access to your personal information. Madu is notresponsible for such third-party conduct.

TelephoneCalls

Telephone calls to and from our CustomerContact Centre are recorded for training and security purposes along with theresolution of any queries arising from the service you receive.

Changes,Modifications and Amendments to our Privacy Policy

We reserve the right to update, modify,change, or revise this Privacy Policy from time to time to reflect yourfeedback as well as that of the Company. The changes will not be retroactive,and the most current version of this Privacy Policy will always be on this pageand will continue to govern our relationship with you. You are encouraged toperiodically review our Privacy Policy to remain informed of how yourinformation is protected.

Any changes we may make to our Privacy Policyin the future will be posted on this page and any such changes will becomeeffective upon posting of the revised Privacy Policy. If we make any materialor substantial changes to this Privacy Policy we will endeavor to inform you byemail, notice on the website or other agreed communications channels.

We may enforce material changes to the PrivacyPolicy without your express consent. If you decline to accept the changes tothe Privacy Policy or otherwise do not accept the changes within the timeperiod, we may not be able to continue to provide some or all services. Bycontinuing to use our services after the changes become effective, you agree tobe bound by the revised Privacy Policy.

YourConsent

By accessing or using our services in anymanner, you suggest to us that you have read and adopted this Privacy Policyand consent to the data practices described herein.

You agree that upon granting us your consent,you have the legal capacity to give consent, and you are aware of your privacyrights and your option to withdraw your consent at any given time.

If you do not accept this Privacy Policy anddo not meet or comply with the provisions set forth herein, then you may notuse our services.

AgeRestriction

If you access our services or platform and youare below 18 years, you represent and warrant that you have obtained consentfrom your parent(s) or legal guardian(s). If you have inadvertently providedpersonal data of a child to us, please notify us at contact@madupay.com and wewill delete such personal data.

We will never knowingly request PersonallyIdentifiable Information from anyone below the age of 18 without priorverifiable parental consent. If we become aware that a child below the age of18 has provided us with personal data without verifiable parental consent, wewill use our best efforts to remove such information from our database. If as aparent or guardian, you become aware that your child or ward child has providedus with any information without your consent, please contact us through the contactdetails provided in this Privacy Policy.

Compliance

Please note that the collection, processing,security, storage, and erasure of your personal data including any updates tothis privacy policy will be in accordance with existing or new privacy and dataprotection provisions and laws globally. We comply with applicable dataprotection laws in all jurisdictions where we operate. We are committed torespecting the data protection and privacy requirements in each country wherewe conduct business.

ComplaintsAnd Remedies

You may file a complaint in accordance withthis Privacy Policy if you believe that any provision of this Privacy Policy oryour privacy rights have been violated in respect of your personal informationor if your access to our Services has been compromised, to enable us to takethe necessary steps towards ensuring the security of your Personal Information.All complaints must be addressed to the company by sending an email to our DataProtection Officer using the following contact details:

Email: contact@madupay.com

Please note that, the complaint and resolutionprocedure is not prejudicial to your right to complain to the relevant dataprotection authorities in your jurisdiction.

We will notify you of any breach and alsonotify relevant regulatory authorities as required by applicable law.

You may also seek redress in a court ofcompetent jurisdiction. We would, however, appreciate the chance to deal withyour concerns before you approach the data protection authorities. Kindlycontact us in the first instance by sending an email to: contact@madupay.com.

Contact Us

Madu welcomes your comments regarding ourPrivacy Policy. If you have any concerns or would like more detail about how weprocess your personal information, you can contact us at contact@madupay.com.

Glossary

"Consent" means any freelygiven, specific, informed and unambiguous indication of the Data Subject'swishes by which he or she, whether by a written or oral statement, or a clearaffirmative action, signifies agreement to the processing of Personal Datarelating to him or her or to another individual on whose behalf he has thepermission to provide such consent.

"Database" means a collectionof data organized in a manner that allows access, retrieval, deletion andprocessing of that data; it includes but not limited to structured,unstructured, cached and file system type databases.

"Processing" Any operation orset of operations which is performed on Personal data or on sets of PersonalData, whether or not by automated means, such as collection, recording,organization, structuring, storage, adaptation or alteration, retrieval,consultation, use, disclosure by transmission, dissemination or otherwisemaking available, alignment or combination, restriction, erasure, ordestruction.

"Data Controller" means anindividual, private entity, public Commission, agency or any other body who,alone or jointly with others, determines the purposes and means of processingof personal data.

"Data Processor" means aperson or organization that processes Personal Data on behalf and oninstructions of Madu and its affiliates.

"Data Subject" means anyperson who can be identified, directly or indirectly, by reference to anidentification number or to one or more factors specific to his physical,physiological, mental, economic, cultural or social identity.

"Third Party" Any natural orlegal person, public authority, establishment, or any other body other than theData Subject, the Data Controller, the Data Administrator, and the persons whoare engaged by the Data Controller or the Data Administrator to process PersonalData.

"Personal Data" means anyinformation relating to an identified or identifiable natural person ('DataSubject'); an identifiable natural person is one who can be identified,directly or indirectly, in particular by reference to an identifier such as aname, an identification number, location data, an online identifier or to oneor more factors specific to the physical, physiological, genetic, mental,economic, cultural or social identity of that natural person; It can beanything from a name, address, a photo, an email address, bank details, postson social networking websites, medical information, and other unique identifiersuch as but not limited to MAC address, IP address, IMEI number, IMSI number,SIM, Personal Identifiable Information (PII) and others.

"Sensitive Personal Data"means data relating to religious or other beliefs, sexual orientation, health,race, ethnicity, political views, trades union membership, criminal records,genetic and biometric data - for the purpose of uniquely identifying a naturalperson or any other sensitive personal information prescribed by regulatoryauthorities, as sensitive personal data.

"Personal Data Breach" Abreach of security leading to the accidental or unlawful destruction, loss, alteration,unauthorized disclosure of, or access to, Personal data transmitted, stored, orotherwise processed.

"Foreign Country" Othersovereign states, autonomous or semi-autonomous territories outside the countryof data collection.

"Data Subject Access Request"The mechanism for an individual to request a copy of their data under a formalprocess which may include payment of a fee.

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