PRIVACY POLICYLast updated: April 4th, 2023

This Privacy Policy applies generally to the business of Nyatwa and serves to set out our approach to personal data, inclusive of personal data of our consumer users (“Users”). This Privacy Policy applies to systems, operations, and processes of Nyatwa that involve the collection, use, storage, and disclosure etc. of personal information.

This Privacy Policy applies to use of our website at https://nyatwa.com, and all affiliated websites and applications owned and operated by us (collectively, the "Website"), other online services and/or any related services, sales, marketing, promotional or events, and social media activities (together with the Website, our "Services"). For our Users, this Privacy Policy is part of our Terms of Use.

This Privacy Policy applies to your use of (regardless of means of access) our Services. You may access or use our Services through a desktop, laptop, mobile phone, tablet, or other consumer electronic device (each, a "Device"). This Privacy Policy also applies to offline interactions with Nyatwa.

By accessing or using our Services, you agree to this Privacy Policy.

In general, you can visit https://nyatwa.com without telling us who you are or revealing any information about yourself or your business.

When you submit an inquiry to us via any means, register for a Nyatwa account, register to attend a Nyatwa event, interact with us on social media, partake in competitions and promotional activities and volunteer information to us; we may collect personal information from you, which may include your name, email address, mobile phone number, banking information, image and other information that identifies you (collectively, "Personal Information"), your officers, employees, or representatives. By providing your Personal Information and any other kind of information or data to us, you expressly agree to our collection, use, storage, and disclosure of such information as described in this Privacy Policy.

As a User, we will also ask you to create login information for your Nyatwa account, such as a username (a “NyatwaID”) and password. When you provide your mobile phone number, we may ask for your consent to receive text messages relating to our Services on that number.

In general, we collect Personal Information you give us by filling in forms or by corresponding with us by phone, email, social media posts & messages, or otherwise.

We may receive, use, store and transfer different kinds of Personal Information about you, including but not limited to the following:

• Identity Information: which includes your first name, last name, maiden name (where applicable), username or similar identifier, marital status, title, date of birth and gender.
• Contact Information: which includes your billing address, delivery address, email address and telephone numbers.
• Transaction Information: which ****includes ****details about your transactions.
• Device Information: which includes information on the devices with which you access the Website.
• Profile Information: which includes your username and password, picture, transaction history, your interests, preferences, feedback and survey responses.
• Usage Information: which includes details of your use of our Services. We may aggregate your usage information to calculate the percentage of Users accessing a specific Website feature.
• Marketing and Communications Information which includes your preferences in receiving marketing from us and our third parties and your communication preferences.
• Location Information: which includes your current location disclosed by GPS technology or any other location territory.

We may also collect, use and share aggregated data such as statistical or demographic data for any purpose.

We collect Personal Information about your transactions with us and others.

Users may provide business-related information to us regarding customer information, staff and personnel information and related data in the process of using or accessing our Services.

We may also collect information from Users' customers in the process of providing our Services.

We also collect Personal Information about you from other companies. For instance, we may receive Personal Information about you from a consumer reporting agency or we may collect Personal Information from your employer where your employer is providing a service to Nyatwa.

We may collect your Personal Information from a User where your Personal Information is filled in a Next-of-Kin form.

We (or our service providers acting on our behalf) may collect information about your use of our Services. This information may include Personal Information as well as statistical information that does not identify you ("Analytics"). Some Analytics may be correlated with Personal Information. When Analytics are, directly or indirectly, associated or combined with Personal Information, such Analytics will be considered Personal Information for purposes of this Privacy Policy.

Information that we automatically collect in connection with your access or use of our Services may include:

Device Information: We may collect Device-specific information (such as hardware model, operating system version, unique Device identifiers, and mobile network Information, including your mobile phone number). We may associate your Device identifiers or mobile phone number with your Nyatwa account.

Log Information: We may record or log information from your Devices, their software, and your activity accessing or using our Services. This information may include:

• The Device's Internet Protocol ("IP") address
• Identification numbers associated with your Devices
• Device event information, such as crashes, system activity, and hardware settings
• Location preferences
• Date and time stamps of transactions
• System configuration information
• Other interactions with our Services

We use cookies to personalize our Services for you and to collect aggregate information about usage of our Services. A cookie is a text file or other local storage identifier provided by your browser or associated applications. We use cookies for record-keeping purposes and to enhance the quality of your use of our Services. The cookies assign random, unique numbers to your Devices to enable our systems to recognize your Devices and to allow us to see how you use our Services. Additional general information about cookies and how they work is available at www.allaboutcookies.org.

Session cookies: Session cookies are temporary cookies that expire and are automatically erased whenever you close your browser window. We use session cookies to grant Users access to content and to enable actions they must be logged into their Nyatwa account to perform.

Persistent cookies: Persistent cookies usually have an expiration date in the distant future and remain in your browser until they expire, or you manually delete them. We use persistent cookies to better understand usage patterns so we can improve our Services. For example, we may use a persistent cookie to associate you with your Nyatwa account or to remember your choices for our Services.

Third-party cookies: We permit certain third parties to place cookies through our Services to provide us with better insights into the use of our Services and user demographics and to advertise our Services to you. These third parties may collect information about your online activities over time and across different websites when you access or use our Services. For example, we utilize Google Analytics to analyze usage patterns for our Services. Google Analytics generates a cookie to capture information about your use of our Services, which Google uses to compile reports on website activity for us and to provide other related services. Google may use a portion of your IP address to identify its cookie, but this will not be associated with any other data held by Google. We may also permit third-party service providers to place cookies for our Services, as indicated above, to perform analytic or marketing functions where you are notified of them, and you have consented to the usage. We do not control the use of such third-party cookies or the resulting information, and we are not responsible for any actions or policies of such third parties.

By accessing or using our Services, you consent to the placement of cookies on your Devices as described in this Privacy Policy. If you prefer not to receive cookies through our Services, you may control how your browser responds to cookies by adjusting the privacy and security settings of your web browser. Unless you set your browser settings to refuse all cookies, our system may issue cookies when you access or use our Services. If you set your browser settings to refuse all cookies, the performance of certain features of our Services may be limited or not work at all.

Do Not Track ("DNT") is an optional browser setting that allows you to express your preferences regarding tracking by advertisers and other third parties. We do not use technology that recognizes DNT signals from your web browser.

We may use Analytics as described elsewhere in this Privacy Policy and for research and commercial purposes, such as to improve our Services.

We may use Personal Information for the purposes described elsewhere in this Privacy Policy and internally for our general commercial purposes, including, among other things, to fulfill and support our contractual obligations to you, to send important notices such as communications about purchases and changes to our terms, conditions, and policies, to process for our legitimate interests related to internal purposes such as auditing, data analysis, network and IT security, or to offer our products and services, and products and services of third parties that we think you might find of interest. Only Nyatwa, Nyatwa affiliates and our third-party service providers involved in distributing the offers or providing the products or services will have access to your Personal Information. Our third-party service providers will only be permitted to use Personal Information for that intended purpose.

We may use your email address to respond to your inquiries and to provide information about our Services. You may elect not to receive promotional emails from us either by "unsubscribing" to an email you receive from us or by contacting us as indicated below. As a User, if you unsubscribe from receiving emails from us, we may still send you non-promotional emails, such as emails about your Nyatwa account or our ongoing business relations, unless you withdraw your consent to receive electronic communications as provided in our Terms of Use.

You agree that we have the right to share your Personal Information, and other information that you share with us:

• if you request or authorize it;
• if the information is provided to help complete a transaction for you;
• with any of our affiliated companies and service providers;
• with financial service providers, including the financial institutions identified in your cardholder bank agreement that provide banking services in connection with your Nyatwa account;
• with another user, when you sign up for our services via a referral link. The user that referred you may receive information indicating that you have enrolled with us;
• with another user, when you use or verify a Managed Account on our Website. A User that verifies a Managed Account may receive information indicating that a Nyatwa Managed Account has been opened for the person whose Nyatwa account such User verifies;
• with non-financial companies, such as email service providers that perform marketing services on our behalf, and fraud prevention service providers that use the information to provide services to us;
• with a non-affiliated third-party to access and transmit your personal and financial information from a relevant institution. You grant the third-party the right, power, and authority to access and transmit this information according to terms of their privacy policy;
• with selected third parties including business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
• with third parties to whom we may choose to sell, transfer or merge parts of our business or our assets or alternatively, acquire all or parts of their businesses;
• in response to a request for information, if we are required by, or we believe disclosure is in accordance with, any applicable law, regulation, governmental and quasi-governmental requests, court orders, subpoenas or legal process;
• for our everyday business purposes;
• for publication of our events and competitions on digital and print media;
• to protect our rights, property, or safety or the rights, property, or safety of our Users or others; or
• with relevant law enforcement officials or other third parties, such as investigators or auditors, if we believe it is appropriate to investigate fraud.

We do not share your Personal Information with: (1) other companies for joint marketing purposes without your consent; or (2) any other third parties so they can market to you.

If you or your customers provide us with bank account or debit card information, or any other payment information,

This Website may, from time to time contain links, to and from the platforms of our partner networks, advertisers, and affiliates. Please note that these platforms and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data, such as contact and location data, which may be collected through these platforms or services. Please check these policies before you submit any personal data to these platforms or use these Services.

By accessing or using our Services, you agree to this Privacy Policy. If you have any questions or comments about this Privacy Policy, please contact us at info@nyatwa.com.