MINEa PRIVACY POLICY

Made In Nigeria Entrepreneur Africa (MINEa)
MINEa Forge Ltd.

Effective Date: Seprember 1, 2026
Last Updated: September 1, 2026
Version: 1.0

1. OUR COMMITMENT TO YOUR PRIVACY

At MINEa — Made In Nigeria Entrepreneur Africa, we believe that trust is fundamental to building a successful digital marketplace and entrepreneurial ecosystem.

We are committed to collecting, using, storing and protecting personal information responsibly and transparently.

This Privacy Policy explains how MINEa Forge Ltd. ("MINEa", "we", "us" or "our") collects, uses, shares, stores and protects personal information when you:

• Visit the MINEa website.

• Create a MINEa account.

• Purchase products.

• Sell products on MINEa.

• Use MINEa Marketplace.

• Use MINEa Academy.

• Participate in MINEa HIVE.

• Use MINEa Analytics.

• Use MINEa Moove or related logistics services.

• Contact MINEa.

• Subscribe to our communications.

• Participate in MINEa promotions, surveys or programmes.

• Interact with MINEa through social media or other digital channels.

This Policy should be read together with our Terms and Conditions, Seller Handbook, Cookie Policy, Returns and Refund Policy and any other policies that apply to specific MINEa services.

MINEa is committed to processing personal data in accordance with applicable Nigerian data protection law, including the Nigeria Data Protection Act, 2023 (NDP Act) and applicable regulatory guidance issued by the Nigeria Data Protection Commission (NDPC).

2. WHO WE ARE

MINEa is an entrepreneurial ecosystem designed to help African businesses discover opportunities, access markets, build capacity, connect and grow.

The MINEa ecosystem may include:

MINEa Marketplace

A digital marketplace where customers can discover and purchase products from participating sellers.

MINEa Academy

An educational platform providing business education, resources, templates, training and other learning materials.

MINEa HIVE

A community designed to connect entrepreneurs, sellers, creators and business partners.

MINEa Analytics

Business and market intelligence services designed to help businesses understand markets and make better decisions.

MINEa Moove

Logistics, delivery, movement and related services that may support transactions within the MINEa ecosystem.

Because these services operate as part of one ecosystem, information collected through one MINEa service may, where legally permitted and appropriate, be used to provide, secure, improve or support another MINEa service.

3. WHAT IS PERSONAL DATA?

Personal data is information that identifies, relates to, describes or can reasonably be associated with an identifiable individual.

Depending on how you interact with MINEa, this may include:

• Full name

• Username

• Email address

• Telephone number

• Delivery address

• Billing information

• Business information

• Seller information

• Account credentials

• Transaction information

• Order history

• Product preferences

• Customer support communications

• Reviews and ratings

• Device information

• IP address

• Browser information

• Approximate location information

• Website usage information

• Cookies and similar technologies

• Marketing preferences

• Information you provide through forms

• Information required for identity or business verification

• Other information you voluntarily provide to us

We seek to collect only information that is reasonably necessary for a specified and legitimate purpose.

The NDP Act requires personal data processing to follow principles including purpose limitation, data minimisation, storage limitation and appropriate security.

4. INFORMATION WE COLLECT

4.1 Information You Provide Directly

We may collect information when you:

• Register an account.

• Become a seller.

• Place an order.

• Contact customer support.

• Subscribe to communications.

• Complete a survey.

• Submit a review.

• Participate in a competition or promotion.

• Apply for a MINEa programme.

• Register for MINEa Academy.

• Participate in MINEa HIVE.

• Request information.

• Submit business information.

• Communicate with another party through MINEa functionality.

4.2 Seller Information

If you register as a MINEa seller, we may collect additional information required to establish and operate your seller account.

This may include:

• Name

• Business name

• Business address

• Phone number

• Email address

• CAC/business registration information

• Bank or payout information

• Tax-related information where applicable

• Product information

• Business category

• Identity verification information

• Seller performance information

• Customer service records

• Transaction information

Certain information may be mandatory because MINEa cannot provide seller services without it.

4.3 Buyer Information

When you purchase products or services through MINEa, we may collect:

• Name

• Contact details

• Delivery address

• Order information

• Payment-related information

• Transaction history

• Delivery information

• Customer support communications

• Product reviews and ratings

4.4 Automatically Collected Information

When you use our website or digital services, we may automatically collect technical information such as:

• IP address

• Device type

• Operating system

• Browser type

• Language settings

• Pages visited

• Search activity on our platform

• Referring website

• Time spent on pages

• Interaction with website features

• Approximate location derived from technical information

• Error logs

• Security and fraud indicators

This information helps us operate, secure and improve MINEa.

5. HOW WE USE YOUR INFORMATION

We may use personal data for legitimate and disclosed purposes, including:

Account Management

To create and manage your MINEa account.

Marketplace Operations

To facilitate purchases, sales, orders, returns and customer support.

Seller Services

To verify sellers, manage seller accounts, process payouts and monitor marketplace performance.

Payments

To facilitate and reconcile transactions through approved payment providers.

Logistics

To coordinate delivery, fulfilment and logistics services.

Security

To detect fraud, abuse, unauthorised access, account compromise and other security threats.

Customer Support

To respond to questions, complaints, disputes and requests.

Personalisation

To improve your experience and present products, content or services that may be relevant to you.

Analytics

To understand marketplace activity, improve our products and services, and develop business and market insights.

Communications

To send service messages, account notifications, order updates and other operational communications.

Marketing

Where legally permitted and where required, with your consent, to send promotional communications, offers, campaigns and information about MINEa services.

Education

To administer MINEa Academy programmes, courses, assessments, certificates and learning services.

Community

To administer MINEa HIVE and related community activities.

Legal and Regulatory Compliance

To comply with applicable laws, court orders, regulatory requirements and lawful requests.

Business Protection

To establish, exercise or defend legal rights and protect MINEa, our users and our partners.

Platform Improvement

To test, troubleshoot, develop and improve MINEa products, features and services.

6. OUR LAWFUL BASES FOR PROCESSING PERSONAL DATA

MINEa will process personal data only where there is an appropriate lawful basis.

Depending on the circumstances, this may include:

• Your consent.

• Performance of a contract with you.

• Taking steps at your request before entering into a contract.

• Compliance with a legal obligation.

• Protection of vital interests where applicable.

• Public interest where applicable.

• Legitimate interests where permitted by law and where those interests are not overridden by your rights and freedoms.

• Other lawful bases recognised by applicable law.

The NDP Act requires organisations to assess and identify the appropriate lawful basis before processing personal data.

Where we rely on consent, you may withdraw that consent, subject to circumstances where another lawful basis permits us to continue processing the information.

7. WHEN WE SHARE YOUR INFORMATION

MINEa does not sell your personal data as a business asset.

We may share relevant information with carefully selected third parties where necessary to operate the MINEa ecosystem or fulfil a legitimate purpose.

These parties may include:

Sellers

Where necessary to fulfil an order, a seller may receive information required to process and deliver your purchase.

Customers

Where appropriate, sellers may receive information necessary to fulfil an order.

Payment Providers

Payment information may be processed by authorised payment processors.

Logistics Providers

We may provide delivery information to logistics partners to enable fulfilment.

Technology Providers

We may use hosting, cloud storage, analytics, communications, security, customer support and other technology providers.

Professional Advisers

We may share information with lawyers, accountants, auditors, insurers, consultants and other professional advisers where necessary.

Regulators and Law Enforcement

We may disclose information where required by law, court order, regulatory requirement or other lawful process.

Corporate Transactions

If MINEa is involved in a merger, acquisition, restructuring, financing, sale of assets or similar transaction, personal data may be transferred as part of that transaction, subject to applicable law and appropriate safeguards.

Third parties receiving personal data are expected to process it only for legitimate purposes and in accordance with applicable contractual, legal and security requirements.

8. SELLER AND CUSTOMER DATA

MINEa operates a marketplace in which independent sellers and customers interact.

Where you purchase from a seller, some information may need to be shared with that seller to enable the transaction.

For example, a seller may need:

• Your name

• Delivery information

• Contact information

• Order details

Sellers are required to handle customer information responsibly and in accordance with their legal and contractual obligations.

Sellers must not use customer information obtained through MINEa to:

• Sell customer information.

• Spam customers.

• Add customers to unrelated marketing databases without lawful permission.

• Conduct unrelated commercial activities.

• Circumvent MINEa's marketplace.

• Share customer information with unauthorised parties.

9. COOKIES AND SIMILAR TECHNOLOGIES

MINEa may use cookies and similar technologies to:

• Keep you signed in.

• Remember preferences.

• Maintain website functionality.

• Improve security.

• Understand how visitors use the platform.

• Analyse website performance.

• Personalise content.

• Support marketing where applicable.

Some cookies are necessary for the operation of the website, while others may be optional.

Where required, MINEa will provide appropriate cookie controls that allow you to accept or decline non-essential cookies.

NDPC guidance specifically recognises the importance of privacy and cookie notices and appropriate user choice.

You may also manage cookies through your browser settings, although disabling certain cookies may affect the functionality of MINEa.

10. MARKETING COMMUNICATIONS

We may send you communications about:

• Products

• Promotions

• MINEa services

• Seller opportunities

• Academy programmes

• HIVE activities

• Business insights

• Platform updates

Where required by law, promotional communications will be sent only where we have an appropriate lawful basis.

You may unsubscribe from marketing communications at any time by:

• Using the unsubscribe option in the communication.

• Updating your account preferences.

• Contacting MINEa through the designated privacy/support channel.

You may continue to receive essential transactional and service communications even after opting out of marketing.

11. DATA SECURITY

Security is a core component of MINEa's platform design.

We use appropriate technical and organisational measures intended to protect personal data against:

• Unauthorised access

• Unauthorised disclosure

• Accidental loss

• Destruction

• Alteration

• Misuse

• Unlawful processing

• Cybersecurity threats

Depending on the nature of the information and the risk involved, security measures may include:

• Encryption in appropriate circumstances

• Access controls

• Authentication controls

• Role-based access

• Logging and monitoring

• Secure development practices

• Security testing

• Backup and recovery measures

• Incident response procedures

• Staff awareness and training

• Vendor security controls

• Data minimisation

However, no internet-based system can be guaranteed to be completely secure.

Users are also responsible for protecting their account credentials and should immediately report suspected unauthorised access.

12. DATA BREACHES AND SECURITY INCIDENTS

MINEa maintains procedures for identifying, investigating, containing and responding to suspected personal data breaches.

Where a breach is likely to create a risk to individuals' rights and freedoms, applicable Nigerian law imposes notification obligations. Under the NDP Act, a data controller must notify the NDPC within 72 hours of becoming aware of a qualifying breach, and high-risk breaches may also require communication to affected data subjects.

Where appropriate, MINEa will:

1. Identify and contain the incident.

2. Assess the nature and scope of the incident.

3. Determine affected data and individuals.

4. Take measures to reduce potential harm.

5. Notify regulators where legally required.

6. Notify affected individuals where legally required.

7. Document the incident and response.

8. Implement corrective measures.

If you believe your MINEa account or personal information has been compromised, contact us immediately.

13. DATA RETENTION

MINEa will not retain personal data indefinitely.

We retain personal information only for as long as reasonably necessary to:

• Provide our services.

• Maintain your account.

• Complete transactions.

• Resolve disputes.

• Maintain appropriate business records.

• Comply with legal and regulatory obligations.

• Prevent fraud and abuse.

• Establish or defend legal claims.

• Protect our legitimate interests.

Different categories of information may have different retention periods.

When personal data is no longer required, we will take appropriate steps to delete, anonymise or securely dispose of it, subject to applicable legal and operational requirements.

Storage limitation is one of the recognised data protection principles under Nigeria's data protection framework.

14. INTERNATIONAL DATA TRANSFERS

Some of our technology providers, service providers or business partners may process information outside Nigeria.

Where personal data is transferred outside Nigeria, MINEa will take steps required by applicable Nigerian data protection law to ensure that the transfer is lawful and that appropriate safeguards are in place.

This may include contractual, regulatory, technical or other appropriate safeguards depending on the circumstances.

Nigeria's data protection framework contains requirements concerning international and cross-border transfers of personal data.

15. YOUR DATA PROTECTION RIGHTS

Subject to applicable law and relevant limitations, you may have the right to:

Right to Be Informed

To know how and why your personal data is processed.

Right of Access

To request access to personal data we hold about you.

Right to Rectification

To request correction of inaccurate or incomplete personal data.

Right to Data Portability

To request your personal data in an appropriate format and, where applicable, have it transferred to another controller.

Right to Object

To object to certain processing of your personal data.

Right to Restrict Processing

To request that processing of your personal data be restricted in certain circumstances.

Right to Erasure

To request deletion of personal data where applicable.

Right to Withdraw Consent

Where processing is based on consent, you may withdraw consent.

Rights Relating to Automated Decision-Making

Where applicable, you may have rights concerning decisions based solely on automated processing.

Right to Lodge a Complaint

You may lodge a complaint with the Nigeria Data Protection Commission where you believe your data protection rights have been violated.

These rights are recognised within Nigeria's current data protection framework.

16. HOW TO EXERCISE YOUR RIGHTS

To exercise a privacy right, contact our privacy team using the details provided in Section 25 of this Policy.

Your request should include:

• Your name.

• Email address associated with your account.

• Description of your request.

• Relevant account or transaction information where applicable.

• Any additional information reasonably required to verify your identity.

We may need to verify your identity before processing certain requests.

This is an important security measure designed to prevent someone else from obtaining or altering your personal information.

We will handle valid requests within the timeframe required by applicable law.

17. CHILDREN'S PRIVACY

MINEa is not intended to knowingly collect personal data from children in circumstances where such collection is prohibited by applicable law.

Where a MINEa service is specifically directed toward children or young persons, additional privacy safeguards may apply.

If you believe a child has provided personal information to MINEa improperly, please contact us so that we can investigate and take appropriate action.

18. THIRD-PARTY WEBSITES AND SERVICES

MINEa may contain links to third-party websites, applications or services.

These third parties may have their own:

• Privacy policies

• Terms of use

• Cookie practices

• Security practices

MINEa is not responsible for the privacy practices of third-party services that we do not control.

We encourage you to review the privacy policy of any third-party service before providing personal information.

19. PAYMENTS

MINEa may use third-party payment processors to facilitate transactions.

Depending on the payment method, payment information may be processed directly by the relevant payment provider.

MINEa may receive transaction-related information necessary to:

• Confirm payments.

• Reconcile transactions.

• Process refunds.

• Detect fraud.

• Provide customer support.

• Maintain financial records.

MINEa does not intend to store complete payment card information where the payment process is handled by an appropriately authorised payment provider.

Payment providers may have separate privacy policies governing their processing of personal information.

20. FRAUD PREVENTION AND PLATFORM SECURITY

To protect customers, sellers and the MINEa ecosystem, we may analyse information for indicators of:

• Fraud

• Account takeover

• Fake accounts

• Payment abuse

• Marketplace manipulation

• Suspicious transactions

• Spam

• Cybersecurity attacks

• Other malicious activity

This may include analysing transaction patterns, device information, account activity and other security signals.

Where automated systems are used to assist with fraud detection or security, appropriate safeguards will be applied in accordance with applicable law.

21. ANALYTICS AND BUSINESS INTELLIGENCE

MINEa may analyse information about how users interact with the platform.

This may help us:

• Improve marketplace functionality.

• Understand customer behaviour.

• Improve search and discovery.

• Improve seller tools.

• Detect marketplace abuse.

• Develop new services.

• Measure platform performance.

Where MINEa develops aggregated or anonymised insights, we will take appropriate measures so that the resulting information is not used to identify individuals where such identification is not necessary.

MINEa Analytics may provide business intelligence products to eligible businesses. Personal information will not be disclosed as part of such products except where lawful and appropriate.

22. REVIEWS, RATINGS AND PUBLIC INFORMATION

If you submit a product review, seller review, rating, testimonial or other content intended for public display, some information associated with that content may be visible to other users.

Before submitting public content, consider carefully whether you want your information to be publicly available.

MINEa may moderate or remove content that violates our policies or applicable law.

23. SOCIAL MEDIA

MINEa may maintain accounts or pages on third-party social media platforms.

If you interact with us through those platforms, the social media provider may collect and process information according to its own privacy policy.

Information you publicly post may be visible to others.

We encourage you to use appropriate privacy settings on your social media accounts.

24. CHANGES TO THIS PRIVACY POLICY

MINEa may update this Privacy Policy from time to time.

Changes may be made to reflect:

• Changes to our services.

• Changes to our technology.

• Changes to our business model.

• Changes to applicable law.

• Changes to regulatory requirements.

• Improvements to our privacy practices.

When we make material changes, we will provide an appropriate notice where required.

The "Last Updated" date at the top of this Policy will indicate when the Policy was most recently revised.

25. CONTACT US ABOUT PRIVACY

If you have questions, concerns or requests relating to this Privacy Policy or your personal data, contact:

MINEa Forge Ltd.
Data Protection / Privacy Team

Email: [privacy@minea.ng]
Website: [www.minea.ng]
Business Address: [Insert Registered Business Address]
Data Protection Officer: [Insert DPO Name/Title, if applicable]

For privacy rights requests, please use the subject:

"MINEa Data Protection Request"

For suspected security incidents:

"MINEa Security Incident"

Please do not include passwords, payment card numbers or other highly sensitive information in ordinary email communications.

26. COMPLAINTS TO THE REGULATOR

If you believe MINEa has not adequately addressed your privacy concern, you may have the right to lodge a complaint with the Nigeria Data Protection Commission (NDPC), subject to applicable law and the Commission's procedures.

The NDPC is Nigeria's data protection regulator and provides mechanisms for data subjects to exercise their rights and raise privacy concerns.

27. PRIVACY BY DESIGN

MINEa aims to incorporate privacy and security considerations into the design and development of our products and services.

Where appropriate, we seek to:

• Minimise the amount of personal data collected.

• Limit access to authorised personnel.

• Protect data throughout its lifecycle.

• Consider privacy risks before introducing new processing activities.

• Use appropriate technical and organisational safeguards.

• Review third-party service providers.

• Provide transparency about significant processing activities.

Privacy and data protection should be considered part of the MINEa product development process rather than an afterthought.

28. OUR PRIVACY PROMISE

At MINEa, we believe that trust is a product feature.

We will strive to:

Collect responsibly.
Only collect information we reasonably need.

Use transparently.
Explain why we process personal information.

Protect rigorously.
Use appropriate security controls to protect information.

Respect your choices.
Provide appropriate controls over your personal information.

Retain responsibly.
Keep information only as long as reasonably necessary.

Respond when things go wrong.
Investigate and respond appropriately to security and privacy incidents.

Keep improving.
Continuously strengthen our privacy and security practices.

29. GOVERNING FRAMEWORK

This Privacy Policy is intended to operate within the legal and regulatory framework applicable to MINEa, including the Nigeria Data Protection Act, 2023 and applicable regulations, directives and guidance issued by the Nigeria Data Protection Commission.

Where MINEa operates services in another jurisdiction, additional privacy requirements may apply.

30. ACKNOWLEDGEMENT

By using MINEa, you acknowledge that you have had an opportunity to read and understand this Privacy Policy.

Where MINEa requires your consent for a particular processing activity, we will request that consent in accordance with applicable law.

Your continued use of MINEa does not, by itself, override your statutory data protection rights.

MINEa

Made In Nigeria Entrepreneur Africa

Building the future of African enterprise.

Privacy. Security. Trust.

© [Year] MINEa Forge Ltd. All rights reserved.