LEGAL AGREEMENT

Kalabash Technology Solutions Limited

Last Updated: August 28, 2025

Privacy Policy

We at KALABASH TECHNOLOGY SOLUTIONS LIMITED (Kalabash) know how important privacy is to our customers and we have created this Privacy Policy to make sure our customers understand how we collect and use their personal information.
We take the privacy of our website users seriously and we are committed to protecting your privacy in compliance with the relevant laws i.e. The Nigeria Data Protection Act 2023, the Nigerian Data Protection Regulation 2019, its Implementation Framework, and the General Data Protection Regulation (EU 2016/679),(‘Data Protection laws’).

This Privacy Policy discloses the privacy practices for (www.kalabash.com) and when used in this Policy statement, it includes its subsidiaries and other partnerships, corporations, undertakings and entities which are authorized by it. This privacy policy applies to personal information collected by the company and to all types of systems, operations and processes within our environment that involve the collection, storage, use, transmission, and disposal of Personal Information (described below). It is provided to help you understand what information we collect about you, how the information collected is used, how we protect it, and your rights to it, among others.

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

It will inform you of the following:

What personally identifiable information is collected from you through the web site, how it is used and with whom it may be shared.
What choices are available to you regarding the use of your data.
The security procedures in place to protect the misuse of your information.
How you can correct any inaccuracies in the information.

INFORMATION COLLECTION, USE, AND SHARING

We collect information from you when you open an account with Kalabash or our services on any of our platforms.

PERSONAL INFORMATION

As part of our operations, we collect and process certain types of information (such as names, telephone numbers, addresses etc.) of individuals that makes them easily identifiable. These individuals include current, past, and prospective employees, guarantors, referees, suppliers/vendors, customers or former customers, and other individuals whom we communicate or deal with, jointly and/or severally (“Data Subject(s)”).

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

We will always solicit for your consent before sharing or disclosing your Personal Information with a third party except as may be required for the purpose of providing you with our services or under applicable legislations. The following are the information that we collect and process:

Individual personal information (e.g., name, previous names, date, and place of birth, etc.);
Individual personal contact details (e.g., address, email address, mobile numbers);
Identifying information (e.g., photo ID, nationality, utility bill, national ID card and/or number, guarantor’s details, referee details, vendor’s personal data);
Information about the ways you interact with the company (e.g., channels used, geographic information, software used and information concerning your complaints);
Information captured in customer documentation or data exchange such as application forms or advisory documents or via telephone (e.g., records of advice);
Information from cookies and similar technologies used to remember your preferences and tailor content;
Data or records of correspondence related to relevant exchanges of information (e.g., emails);
Information to fulfill regulatory obligations (e.g., transaction details, user activity);
Information from other entities (e.g., relevant transaction information);
Information from third parties providing information to identify and manage fraud;
Data from closed circuit television (CCTV) in and around the company’s facilities (these may collect photos or videos of you);
Other information about you that is voluntarily provided by filling in online forms or by communicating with us, whether face-to-face or via other available channels (e.g., by phone, email, or online).

Registration

For effective use of this website, users are advised to complete the registration form. During registration, a user is required to give certain information such as name, address, telephone number, email address, card information, device information, technical data based on service usage, location and any other information we may require you to provide us with to enable us to render the service to you.

Use

We collect your data and process same for the following reasons:

To contact you in relation to any enquiry;
To process your application for the use of our Services this includes for to verify your identity, preventing and detecting fraud and anti-money laundering (AML) purposes;
To provide the service to you;
To recover the payments due to us;
To provide you with support, updates and communications regarding services you request from us;
To tailor our services to meet your requirements and needs;
To seek to deliver or develop new ranges of products or services
To protect the security of our staff, customers, suppliers, and merchandise (including theft and fraud prevention).
To improve our services and tailor fit our website, offered services and contents to suit your needs and preferences; and
To comply with any laws or regulations to which we are subject.
For general planning and administration.
And any other reason which is key to providing the services envisaged by Kalabash.

This information is also used to contact you about the products/services on our site in which you have expressed interest. At your option, you may also provide demographic information (such as gender or age) about yourself, but this is not required.
We are the sole owners of the information collected on this site. We only have access to/collect information which you voluntarily give us via email or other direct contact from you. We will not sell or rent this information to anyone.
We will use your information to respond to you, regarding the reason you contacted us. We will not share your information with any third party outside of our organization, other than as necessary to fulfill your request.
Unless you ask us not to, we may contact you via email in the future to tell you about specials, new products or services, or changes to this privacy policy.
The Information which we collect may be stored and processed in and transferred between any of the countries in which we operate in order to enable us use the information in accordance with this policy.

DATA PROCESSING 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 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.

Legal Basis

We will only use and process your personal data as permitted by the Nigerian Data Protection Act, 2023. We have set out below a description of all the legal bases we may rely on to process your personal 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; and
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.
For the purpose of the legitimate interests pursued by the data controller or data processor, or by a third party to whom the data is disclosed.

hat we may process your personal data on more than one lawful ground depending on the specific purpose for which we are using your personal data. Please contact us by sending an email to: Legal@kalabash54.com, if you need details about the specific legal ground we are relying on to process your personal data where more than one ground may have been used to process your personal data.

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

DATA MINIMIZATION

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

YOUR ACCESS TO AND CONTROL OVER INFORMATION

Once your Personal Information is held by us, you are entitled to reach out to us to exercise the following rights which are guaranteed by the Nigeria Data Protection Act, with some limitations.

Request access to your personal data (commonly known as a “data subject access request”): 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 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, completed 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 processing, 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 of 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 are relying on a legitimate interest (or those of a third party) there may be something about your situation which could justify an objection to processing on this ground, as you may feel it impacts on 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 override 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:
1. If you want us to establish the data’s accuracy;
2. Where our use of the data is unlawful but you do not want us to erase it;
3. 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
4. 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 of your personal data to you or to a third party: We will provide to 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.

In the event you withdraw your consent for a particular purpose which we initially relied on to perform a request/ need, we may be unable to provide you with our services or may be unable to tailor our services to your needs which may have a subsequent effect o the service we provide.

Please let us know if the personal information which we hold about you needs to be corrected or updated. If you wish to exercise any of the rights set out above, please contact us via our contact details in tis Privacy Policy
We would try to respond to all legitimate requests within a month. Occasionally, it could take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.
In addition to existing rights available under the relevant laws, in the event you want to raise a concern about any violation of this privacy policy, you can contact NITDA at https://nitda.gov.ng/nit/contact-us

Use of Google Analytics

Google Analytics is a platform provided by Google. This platform helps us to analyze how our users deploy our website and mobile app. This information is obtained through the use of cookies and information obtained is stored in Google's servers and it is used to evaluate the use of our website and mobile app by you and other users to provide insights into our business.
The features we use and the insights we provide are:
AdWords Remarketing — this uses behavior, demographic, and interest data to identify users who are likely to convert, and then allows us to target those users with remarketing campaigns through Google Ads.
Demographics and Interests Reporting — this provides insight into the age, gender, and purchase interests of users, which we can use to better tailor fit your advertisements.
Google Display Network (GDN) Impression Reporting — measures the impact of unclicked GDN Display ad impressions on conversions and site behavior.
Please note that Google receives your truncated IP address. This is sufficient for Google to identify (approximately) the country from which you are visiting our sites or accessing our website but is not sufficient to identify you, or your computer or mobile device, individually. You can find more information here, including a link to Google's privacy policy.
Click here to opt-out of analysis by Google Analytics on our website and other websites.

SECURITY

We take extra precautions to protect your information. When you submit sensitive information via the website, your information is protected both online and offline. The steps we take to secure your personal data include website protection measures, controlled access to Kalabash's corporate premises, security restrictions on Kalabash's computer systems, policies on document storage, personnel security and training and secure workplace policies. Even though we endeavor to protect personal data of users of our website and mobile app, we cannot guarantee the security of the information you post online and the information is disclosed at your own risk. You can help protect your personal data by keeping your account details confidential. If you become aware of any security breach, please let us know immediately.
Wherever we collect sensitive information (such as credit card data), that information is encrypted and transmitted to us in a secure way. You can verify this by looking for a closed lock icon at the bottom of your web browser, or looking for "https" at the beginning of the address of the web page.
While we use encryption to protect sensitive information transmitted online, we also protect your information offline. Only employees who need the information to perform a specific job (for example, billing or customer service) are granted access to personally identifiable information. The computers/servers in which we store personally identifiable information are kept in a secure environment

Data Retention

We will retain your Personal Information for as long as is needed to provide our services to you, comply with our legal and statutory obligations or verify your information with the required verification authorities.

We are statutorily obligated to retain the Personal Information and data you provide us with to carry out our services and in compliance with laws and regulatory guidelines applicable to us and our partners. Therefore, even after discontinuance of our services, we will retain certain Personal Information and transaction data to comply with these obligations.

For all Personal Information and records obtained, used, and stored by us, we shall perform periodical reviews of the data retained to confirm the accuracy, purpose, validity, and requirement to retain.

The length of storage of your Personal Information 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.

UPDATES, MODIFICATIONS AND AMENDMENTS

We reserve the right to update, modify, change, or revise this Privacy Policy from time to time. The changes will not be retroactive, and the most current version of this Privacy Policy which will always be on this page and will continue to govern our relationship with you. We advise that you check this page often, referring to the date of the last modification on the page. We will also try to notify you of any material changes which could be done via email associated with your account or service notification. By continuing to use our services after the changes become effective, you agree to be bound by the revised Privacy Policy.

If you feel that we are not abiding by this privacy policy, you should contact us immediately via our contact details in this policy or our website.

COOKIES

We use "cookies" on this site. A cookie is a piece of data stored on a site visitor's hard drive to help us improve your access to our site and identify repeat visitors to our site. For instance, when we use a cookie to identify you, depending on your browser settings you would not have to log in a password more than once, thereby saving time while on our site. Cookies can also enable us to track and target the interests of our users to enhance the experience on our site. Usage of a cookie is in no way linked to any personally identifiable information on our site.
Some of our business partners may use cookies on our site (for example, advertisers). However, we have no access to or control over these cookies.

SHARING

We share aggregated demographic information with our partners and advertisers. This is not linked to any personal information that can identify any individual person. We use a credit card processing company to bill users for products and services. These companies do not retain, share, store or use personally identifiable information for any secondary purposes beyond fulfilling your order.
We partner with other parties to provide specific services. When the user signs up for these services, we will share names, or other contact information necessary for the third party to provide these services. These parties are not allowed to use personally identifiable information except for the purpose of providing these services.

Using the Kalabash mobile phone and tablet Apps (the "Mobile Apps")

When you use a Kalabash SIM Card or Mobile App, we collect and use information about you in the same way and for the same purposes as we do when you use our website.
In addition to this, we also use some other information that we collect automatically when you use our Mobile Apps e.g. we collect information about Mobile App functionality that you access and use. This allows us to identify those areas of the Mobile App that are of interest to our customers so that we can refine and continuously improve the Mobile App. The information we collect for this purpose does not enable us to directly identify you. When you use our Mobile App, you can choose to allow access to your current location – provided by your mobile device using GPS or similar technologies – in order to identify nearby airports or merchants. If you choose to allow access, this location data may be collected anonymously as part of search requests logged by our servers. You can switch off the Mobile App's access to your location at any time through your phone settings menu.
Each Mobile App will also send us error-reporting information in the event that it crashes or hangs. This enables us to investigate the error and to improve the stability of the Mobile App for future releases. We do not use this information for any purpose other than investigating and remedying the error.
You always have the ability to control what information a Mobile App sends to us. You can exercise this control either by changing the settings of the Mobile App under its setting menu or changing the settings of your mobile device. Alternatively, you can remove the Mobile App from your mobile device entirely and access our services through our website.

We may share your information with law enforcement agencies, public or tax authorities or other organizations if legally required to do so, or if we have a good faith belief that such use is reasonably necessary to:

Comply with a legal obligation, process, or request (including tax and related reporting requirements);
Enforce our Terms of Service and other agreements, policies, and standards, including investigation of any potential violation thereof;
Detect, prevent, or otherwise address security, fraud, or technical issues; or
Protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (including exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction).

Please see the list and details of categories of third-party processors we share your personal data with below:

Flutterwave - Payment gateway
Airlines and Online travel agencies (OTA’s)

TRANSFER OF PERSONAL INFORMATION TO FOREIGN COUNTRY

Where Personal Information is to be transferred to a country outside Nigeria, we shall put adequate measures in place to ensure the security of such Personal Information. In particular, we shall, among other things, confirm whether the country is on the Nigeria Data Protection Commission ("NDPC”) Whitelist of Countries with adequate data protection laws.

Transfer of Personal Information out of Nigeria would be in accordance with the provisions of the Nigeria Data Protection Act ("NDPA”) 2023. We will therefore only transfer Personal Information out of Nigeria 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 ensure that your Personal Information is transmitted in a safe and secure manner. Details of the protection given when your Personal Information is transferred outside Nigeria shall be provided to you upon request.

LINKS

This web site contains links to other sites. Our website includes hyperlinks to, and details of, third party websites.
Please be aware that we are not responsible and have no control whatsoever over the content or privacy practices of such other sites. We encourage our users to be aware of the same when they leave our site. It is important that all users read the privacy statements of any other site which collects personally identifiable information.

VISITING OUR WEBSITE FROM OUTSIDE NIGERIA

If you are visiting our website from outside Nigeria, please be aware that your information may be transferred to, stored, and processed in Nigeria from where our central database is operated. The data protection law and other laws of Nigeria may vary in content or may not be as comprehensive as those in your country, but please be assured that we take steps to ensure that your privacy is protected. By using our services, you understand that your information may be transferred to our facilities and to those third parties with whom we share it as described in this Policy.

SURVEYS & CONTESTS/PROMOTIONS

From time-to-time our site requests information via surveys or contests. Participation in these surveys or contests is completely voluntary and you may choose whether or not to participate and therefore disclose this information. Information requested may include contact information (such as name and address), and demographic information (such as post code, age level etc). Contact information will be used to notify the winners and award prizes. Survey information will be used for purposes of monitoring or improving the use and satisfaction of this site.

TRANSFER OF OWNERSHIP

In the event Kalabash is involved in any merger, acquisition, reorganization, sale of assets, bankruptcy, or insolvency event, then we may sell, transfer or share some or all of our assets, including your information in connection with such transaction or in contemplation of such transaction (e.g., due diligence). If this occurs, please note that we will notify you before your personal information is transferred and becomes subject to a different privacy policy.

ONLINE PRIVACY POLICY ONLY

This privacy policy applies to personal information collected through our website and personal information collected offline.

TERMS AND CONDITIONS

Please also visit our Terms and Conditions section establishing the use, disclaimers and limitations of liability governing the use of our website at http://www.kalabash.com

YOUR CONSENT

By accessing or using our services in any manner, you suggest to us that you have read and adopted this Privacy Policy and 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 privacy rights and your option to withdraw your consent at any given time.

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

AGE RESTRICTION

If you access our services or platform and you are below 18 years, you represent and warrant that you have obtained consent from your parent(s) or legal guardian(s). If you have inadvertently provided personal data of a child to us, please notify us at Nasir@wakanow.com and we will delete such personal data.

Consistent with Section 8 of the Nigeria Child Rights Act (“the Act”), Cap C50, Laws of the Federation of Nigeria 2010 and Section 31 of the Nigeria Data Protection Act (NDPA) 2023, we will never knowingly request Personally Identifiable Information from anyone below the age of 18 under the Act without prior verifiable parental consent. If we become aware that a child below the age of 18 under the Act has provided us with personal data without verifiable parental consent, we will use our best efforts to remove such information from our files. If as a parent or guardian, you become aware that your child or ward child has provided us with any information without your consent, please contact us through the details provided in this Privacy Policy.

COMPLIANCE

Please note that the collection, processing, security, storage, and erasure of your personal data including any updates to this privacy policy will be in accordance with existing or new privacy and data protection provisions and laws in Nigeria which includes but not limited to the following:

Constitution of the Federal Republic of Nigeria 1999 (as Amended);
Nigeria Data Protection Act 2023 ("NDPA”);
Nigeria Data Protection Regulation 2019 ("NDPR”);
NDPR 2019 Implementation Framework;
Nigeria Cybercrimes (Prohibition, Prevention Etc. Amendment) Act 2024;
Nigeria Money Laundering (Prevention and Prohibition) Act, 2022;
Nigeria Federal Competition and Consumer Protection Act, 2018 (FCCPA);
Nigeria Freedom of Information Act 2011;
Central Bank of Nigeria Risk-Based Cybersecurity Framework and Guidelines for Other Financial Institutions 2022.

COMPLAINTS AND REMEDIES

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

Email: Nasir@wakanow.com

Please note that, the complaint and resolution procedure is not prejudicial to your right to complain to the data protection authorities (in this case, you should contact the Nigeria Data Protection Commission (NDPC) using the following contact details:
Address:
NDPC: No. 5, Donau Crescent,
Off Amazon Street, Maitama,
Abuja, Nigeria.
Email: info@ndpc.gov.ng
We will notify you of any breach and also notify Nigeria Data Protection Commission (NDPC) within 72 hours of becoming aware of such breach.

You may also seek redress in a court of competent jurisdiction. We would, however, appreciate the chance to deal with your concerns before you approach the data protection authorities. Kindly contact us in the first instance by sending an email to: Nasir@wakanow.com

Contact Information

You may also contact us if you have any questions, comments and requests relating to this Privacy Policy or would like to find out more about exercising your data protection rights. Please contact us via Nasir@wakanow.com. and for more details about Travel Data please click here or Contact us at
(customersuccess@kalabash54.com;
Hi@kalabash54.com; +2349087873536,
+2349087873512) or to the following postal address: