This privacy policy (this “Privacy Policy”) explains how personal information is collected, used, stored, and disclosed by PoderMonie (“PoderMonie,” “we,” “us,” and “our”).

The provisions contained in this Privacy Policy supersede all previous notices and statements regarding our privacy practices with respect to our services.

Last updated: August, 2026

Application of this Privacy Policy

This Privacy Policy sets out our approach to the collection, use, storage, disclosure and protection of personal data, including the personal data of our Users. This Privacy Policy applies to systems, operations and processes of PoderMonie that involve the collection, use, storage, disclosure and other processing of personal information of our Users.

This Privacy Policy applies to the use of our website at https://wealth.podermonie.com, and any affiliated websites, applications, platforms and digital services owned or operated by us (collectively, the “Website”), as well as other online services and/or related services, sales, marketing, promotional or other activities carried out by or on behalf of PoderMonie (together with the Website, our “Services”).

This Privacy Policy applies to your use of our Services regardless of the means by which you access them. You may access or use our Services through a desktop, laptop, mobile phone, tablet or other consumer electronic device (each, a “Device”).

When you submit an inquiry to us, create or use an account, request or subscribe to any of our Services, interact with us through social media, participate in promotional activities, communicate with our representatives or otherwise voluntarily provide information to us, we may collect personal information from you. Such information may include your name, email address, telephone number, identification information, financial information, transaction information, Device information and other information that identifies or may reasonably be used to identify you (collectively, “Personal Information”).

By accessing or using our Services, you acknowledge that you have read and understood this Privacy Policy. Where consent is required by applicable law, we will obtain your consent before processing your Personal Information on that basis.

Guiding Principles

PoderMonie is committed to maintaining the principles contained in the Nigerian Data Protection Act 2023 (the “NDPA”), the Nigeria Data Protection Act General Application and Implementation Directive 2025 (“NDPA-GAID”) and other applicable privacy and data protection laws regarding the processing of Personal Information.

The NDPA requires personal data to be processed in a fair, lawful and accountable manner and establishes rights and protections for data subjects.

To demonstrate this commitment and our aim of creating a positive privacy culture within PoderMonie, we adhere to the following basic principles relating to the processing of Personal Information:

• lawfulness, fairness and transparency;
• purpose limitation;
• data minimisation;
• accuracy;
• storage limitation;
• integrity and confidentiality; and
• accountability.

LAWFUL BASIS FOR USE OF YOUR PERSONAL INFORMATION

We may process your Personal Information under one or more of the lawful bases recognised under applicable data protection laws, including the following:

Consent

Where required by applicable law, we may process your Personal Information based on your consent.

Where we rely on consent, you may withdraw your consent at any time by contacting us using the contact details provided in this Privacy Policy. Withdrawal of consent will not affect the lawfulness of processing carried out before the withdrawal.

Please note that certain Personal Information may need to be processed on another lawful basis, including contractual necessity or legal obligation, and withdrawing consent will not necessarily require us to stop all processing of your Personal Information.

Contractual obligations

We may process your Personal Information where such processing is necessary to enter into or perform a contract with you or to take steps at your request before entering into a contract.

This may include processing your name, contact details, identification information, financial information, payment information, transaction information and other information necessary to provide our Services, establish or maintain your account, process transactions, provide investment or wealth-related services, communicate with you and manage our contractual relationship with you.

Legal obligations

We may process your Personal Information where necessary to comply with applicable laws, regulations, regulatory requirements, court orders, governmental requests and other legal obligations.

This may include requirements relating to financial services, anti-money laundering, counter-terrorist financing, fraud prevention, taxation, accounting, reporting, customer identification, record keeping and regulatory compliance, where applicable to our Services.

Legitimate Interest

We may process your Personal Information where necessary for our legitimate interests, provided that such interests are not overridden by your fundamental rights and freedoms.

Our legitimate interests may include fraud prevention and detection, information security, improving our Services, service administration, customer support, analytics, business management, internal auditing, risk management, maintaining the integrity of our systems and protecting our Users and business.

Where we rely on legitimate interests, we will consider the nature and purpose of the processing, the reasonable expectations of Users and the potential impact on their rights and freedoms.

Vital Interest

We may process your Personal Information where necessary to protect your vital interests or the vital interests of another natural person, where permitted by applicable law.

Public Interest

We may process your Personal Information where necessary to perform an obligation carried out in the public interest or in the exercise of official authority, where applicable.

These lawful bases may be extended to cover any additional lawful grounds for processing Personal Information recognised under applicable data protection laws from time to time.

INFORMATION WE COLLECT AND HOW WE COLLECT IT

Information You Provide Us

You may be able to visit https://wealth.podermonie.com without directly identifying yourself or providing Personal Information.

However, where you register for an account, request our Services, communicate with us, complete forms, make transactions or otherwise interact with our Services, we may collect Personal Information from you.

In general, we collect Personal Information you provide to us by completing forms, registering for an account, corresponding with us by telephone, email, social media or other communication channels, submitting documents, making transactions or otherwise communicating with us.

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

• Identity Information: which may include your first name, last name, title, date of birth, gender, identification numbers and other information used to establish or verify your identity.
• Contact Information: which may include your email address, telephone number, residential address, billing address and other contact details.
• Financial Information: which may include bank account information, payment information, income information, financial objectives, investment information and other financial information required to provide our Services.
• Transaction Information: which may include details of deposits, withdrawals, investments, payments, transfers, purchases, redemptions and other transactions carried out through or in connection with our Services.
• Device Information: which may include information relating to the Devices used to access our Services.
• Profile Information: which may include your username, account information, preferences, financial objectives, feedback, survey responses and other information associated with your account.
• Usage Information: which may include information about how you use our Website, applications and Services.
• Marketing and Communications Information: which may include your preferences regarding receiving marketing communications from us and your communication preferences.
• Location Information: where applicable, which may include general location information derived from your Device or information voluntarily provided by you.

We may also collect, use and share aggregated or statistical information that does not directly identify you for legitimate business, analytical, research and operational purposes.

Information About Your Transactions

We collect Personal Information about transactions carried out through or in connection with our Services.

This may include information concerning deposits, withdrawals, transfers, investments, payments, investment products, transaction values, transaction dates and other information necessary to process, verify, reconcile, monitor and maintain records of transactions.

Information from Third Parties

We may receive Personal Information about you from third parties where permitted by applicable law and where such information is necessary to provide or support our Services.

These third parties may include financial institutions, payment service providers, identity verification providers, fraud prevention providers, technology providers, professional advisers, regulators and other service providers.

We may also receive Personal Information from another User where your information is provided to us in connection with a transaction, referral, beneficiary, next-of-kin or other legitimate purpose.

Information Automatically Collected

We or service providers acting on our behalf may automatically collect information about your use of our Services.

This information may include Personal Information as well as statistical information that does not directly identify you (“Analytics”). Where Analytics are directly or indirectly associated or combined with Personal Information, they may be treated as 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, browser type, unique Device identifiers and mobile network information.

Log Information: We may record information from your Device, its software and your activity when accessing or using our Services. This information may include:

• the Device’s Internet Protocol (“IP”) address;
• identification numbers associated with your Device;
• browser information;
• Device event information;
• system activity;
• system configuration information;
• date and time stamps;
• pages or features accessed;
• transaction-related timestamps; and
• other interactions with our Services.

Information Collected Through Cookies and Similar Technologies

We may use cookies and similar technologies to improve our Services, remember preferences, maintain sessions, analyse Website usage, improve security and support certain functionality.

A cookie is a small text file or similar technology stored on your Device by your browser or associated application.

The cookies we may use in connection with our Services include:

Session cookies:

Session cookies are temporary cookies that expire and are automatically deleted when you close your browser. We may use session cookies to maintain your session and enable functionality that requires you to remain logged in.

Persistent cookies:

Persistent cookies remain on your Device until they expire or you manually delete them. We may use persistent cookies to remember preferences, understand usage patterns, improve our Services and support functionality.

Third-party cookies:

We may permit selected third-party service providers to place cookies or similar technologies through our Services for purposes such as analytics, security, functionality and marketing, where permitted by applicable law.

These third parties may collect information about your use of our Website and other online services. We do not control the privacy practices of third parties and encourage you to review their respective privacy policies.

Where consent is required for non-essential cookies, we will provide appropriate mechanisms through which you can manage or withdraw your preferences.

By using our Services, you acknowledge that certain cookies may be necessary for the operation and security of the Website. You may also control cookies through your browser settings, although disabling certain cookies may affect the functionality of some features.

Do-Not-Track Signals:

Do Not Track (“DNT”) is an optional browser setting that allows you to express preferences regarding online tracking. Our Services may not respond to all DNT signals or similar mechanisms.

How We Use Information:

We may use Analytics to understand how Users interact with our Services, improve our Website and applications, identify technical issues, conduct research, improve security and support our business operations.

We may use Personal Information to:

• provide, maintain and improve our Services;
• establish and manage User accounts;
• verify your identity;
• process transactions;
• provide investment and wealth-related services;
• communicate with you;
• provide customer support;
• prevent, detect and investigate fraud and other unlawful activities;
• manage risk;
• maintain the security and integrity of our systems;
• comply with legal and regulatory obligations;
• conduct audits and internal reviews;
• analyse and improve our products and Services;
• personalise aspects of our Services;
• send service-related communications;
• send marketing communications where permitted and, where required, with your consent;
• enforce our agreements and policies; and
• protect our rights, property, Users and other persons.

We may use your email address and telephone number to respond to inquiries, provide account-related information, communicate transaction information and provide other important information concerning our Services.

You may elect not to receive promotional communications from us by following the unsubscribe instructions contained in the relevant communication or contacting us directly.

However, you may continue to receive non-promotional communications that are necessary for the operation of your account, transactions, security, legal obligations or our ongoing business relationship with you.

How We Share Information:

You agree that we may share your Personal Information and other information you provide to us:

• where you request or authorise us to do so;
• where necessary to provide or complete a transaction or Service requested by you;
• with our affiliated companies and service providers;
• with financial institutions, payment service providers and other financial service providers involved in providing our Services;
• with identity verification, compliance, fraud prevention and risk management providers;
• with technology, cloud hosting, cybersecurity, communications, analytics and other service providers that support our operations;
• with professional advisers, auditors and consultants where necessary for legitimate business purposes;
• with selected business partners, suppliers and subcontractors where necessary to perform services for us or for you;
• where required to comply with applicable laws, regulations, governmental requests, court orders, subpoenas or legal processes;
• where necessary to protect our rights, property, safety or the rights, property or safety of our Users or others;
• with relevant law enforcement, regulatory or governmental authorities where required or permitted by law;
• where necessary to investigate, prevent or respond to fraud, security incidents or other unlawful activities;
• in connection with a merger, acquisition, restructuring, financing, sale or transfer of all or part of our business or assets; or
• for other purposes permitted under applicable data protection laws.

Where we engage third-party service providers to process Personal Information on our behalf, we require them to process Personal Information only for authorised purposes and to implement appropriate safeguards.

If you provide bank account, payment or other financial information through our Services, we may share such information with relevant financial institutions, payment processors and service providers solely to the extent necessary to provide the relevant Services, process transactions, comply with legal obligations or protect our legitimate interests.

We do not sell your Personal Information to third parties for their own independent marketing purposes.

When you are no longer our User, we may continue to process and share your information as described in this Privacy Policy where permitted or required by applicable law.

We may disclose aggregated or anonymised information to third parties for legitimate analytical, research, operational or commercial purposes where the information does not identify you.

Information You Share Socially

Our Services may provide opportunities for you to interact with us through social media or other third-party platforms.

Please be mindful of your privacy when choosing what information to share publicly.

We are not responsible for maintaining the confidentiality of information that you voluntarily make publicly available through third-party platforms.

Third-party websites, applications and services are governed by their own privacy policies and terms. We encourage you to review those policies before providing Personal Information to such third parties.

Security and Storage of your Personal Information

We have appropriate technical, organisational, administrative and physical safeguards designed to protect your Personal Information against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access and other forms of unlawful processing.

Where sensitive financial or account information is transmitted through our Services, we use appropriate security technologies and controls designed to protect such information during transmission.

We limit access to Personal Information to employees, agents, contractors and service providers who have a legitimate business need to access such information.

Persons authorised to process Personal Information are required to handle it in accordance with applicable laws, our policies and our instructions.

We maintain procedures designed to identify, investigate, manage and respond to suspected personal data breaches and will notify affected persons and/or the appropriate regulatory authority where required by applicable law.

We also require relevant third-party service providers that process Personal Information on our behalf to maintain appropriate information security measures.

No method of electronic transmission or storage is completely secure. Therefore, although we take reasonable and appropriate measures to protect your Personal Information, we cannot guarantee absolute security.

You also have a role in protecting your Personal Information. You should keep your account credentials, passwords, authentication information and other security details confidential and should notify us promptly if you believe your account or security information has been compromised.

Subject to applicable law, we will retain your Personal Information for as long as reasonably necessary to fulfil the purposes for which it was collected, including satisfying legal, regulatory, accounting, reporting, security and dispute-resolution requirements.

Protecting Children’s Privacy

Our Services are not directed to, or intended for, children under the age of eighteen (18).

We do not knowingly collect Personal Information from children under the age of eighteen (18) except where permitted or required by applicable law.

If you are under eighteen (18), please do not use our Services or submit Personal Information to us without the involvement of a parent, guardian or other person authorised by applicable law.

Links to Third-Party Websites

When you use our Services, you may be directed to websites, applications or services operated by third parties.

We are not responsible for the privacy practices, security or content of third-party websites, applications or services.

We encourage you to review the applicable privacy policies and terms and conditions of those third parties.

This Privacy Policy applies only to the Services operated or controlled by PoderMonie.

Data security and retention

We deploy appropriate physical, electronic, technical and administrative safeguards designed to protect your Personal Information from unauthorised access, unlawful processing, loss, destruction, alteration, disclosure and other foreseeable security risks.

We generally retain Personal Information for as long as reasonably necessary to fulfil the purposes for which it was collected and to comply with applicable legal, regulatory, accounting, reporting and security obligations.

To determine an appropriate retention period, we consider the amount, nature and sensitivity of the Personal Information, the purposes for which it is processed, the potential risk of harm from unauthorised use or disclosure, applicable legal requirements and our legitimate business needs.

You may request that we delete or erase your Personal Information where permitted by applicable law.

However, we may retain certain Personal Information where we are legally required or permitted to do so, including for regulatory, financial, tax, accounting, audit, fraud prevention, dispute resolution or other legal purposes.

If you would like further information about the retention periods applicable to your Personal Information, please contact us using the contact details provided at the end of this Privacy Policy.

Opt-Out Rights

If you do not wish to receive promotional offers or marketing communications from us, you may opt out by following the unsubscribe instructions contained in the relevant communication or contacting us directly.

Please note that if you are a User, you may not be able to opt out of receiving important non-promotional communications relating to your account, transactions, security, legal obligations or our ongoing business relationship.

Other Rights to Your Personal Information with Us

Beyond your right to withdraw consent where processing is based on consent, you may have the following rights in relation to your Personal Information, subject to applicable law:

• Right to request Correction to your Personal Information

You may request correction of inaccurate, incomplete or outdated Personal Information.

Where you maintain an account with us, you may be able to update certain information through your account. For information that cannot be updated directly, you may contact us.

We may need to verify the accuracy of information before making changes.

• Right to request Access to your Personal Information

You may request confirmation as to whether we process your Personal Information and, where applicable, request access to Personal Information we hold about you.

We may request appropriate information to verify your identity before fulfilling an access request.

The NDPC recognises the right of data subjects to access their Personal Information and provides mechanisms for making data-subject access requests.

• Right to data portability

In certain circumstances, you may request to receive Personal Information that you have provided to us in a structured, commonly used and machine-readable format, or request that such information be transmitted to another controller where technically feasible and where the conditions for exercising this right are met.

• Right to request restriction of processing

In certain circumstances, you may request that we restrict the processing of your Personal Information.

• Right to object to processing

You may have the right to object to certain processing of your Personal Information, including processing carried out for direct marketing purposes.

Where we process Personal Information based on legitimate interests, you may object where you have grounds relating to your particular situation, subject to applicable law.

• Right to request partial or complete erasure of your Personal Information

You may request that we delete or erase your Personal Information where there is no lawful basis for us to continue processing it or where otherwise permitted under applicable law.

However, we may retain Personal Information where we have a legal or regulatory obligation or another lawful basis requiring or permitting us to retain it.

• Right to withdraw consent

Where we rely on consent to process your Personal Information, you may withdraw your consent at any time.

Withdrawal of consent does not affect the lawfulness of processing carried out before consent was withdrawn.

• Right to object to decisions taken by automated means

Where applicable, you may have the right not to be subject to a decision based solely on automated processing, including profiling, where that decision produces legal or similarly significant effects on you, subject to applicable law and relevant exceptions.

Where applicable, we will implement appropriate safeguards, which may include the opportunity to obtain human intervention, express your views and contest the decision.

• Right to lodge a complaint with the Commission

If you believe that the processing of your Personal Information violates applicable data protection law, you have the right to lodge a complaint with the Nigeria Data Protection Commission (“NDPC”).

The NDPC recognises rights including access, rectification, objection, restriction, data portability, erasure, rights relating to automated decision-making and the right to lodge a complaint with the supervisory authority.

You may access information and relevant resources through the Nigeria Data Protection Commission.

Grievance Redress Procedure

Any complaints, questions or requests regarding the processing of Personal Information should be directed to PoderMonie using the contact details provided at the end of this Privacy Policy.

We are committed to promptly addressing concerns relating to the processing of Personal Information and data-subject rights.

Upon receiving a complaint or request, we will acknowledge and assess the matter and take appropriate steps to resolve it in accordance with applicable law.

Where additional time is required because of the complexity of a request, we will communicate the relevant information to the data subject as required by applicable law.

You may also lodge a complaint with the Nigeria Data Protection Commission where you believe your data protection rights have been infringed. The NDPA provides data subjects with rights and remedies in respect of unlawful or improper processing of personal data.

Changes to our Privacy Policy

Subject to applicable law, we may revise this Privacy Policy from time to time.

When we revise this Privacy Policy, we will publish the updated version through our Services and update the “Last updated” date at the top of this Privacy Policy.

The revised Privacy Policy will become effective upon publication unless otherwise stated or required by applicable law.

We encourage you to review this Privacy Policy periodically so that you remain informed about how we collect, use, store and disclose Personal Information.

How can I contact PoderMonie?

If you have any questions, comments, concerns or requests regarding your Personal Information or this Privacy Policy, please contact PoderMonie through the contact details provided on our Website.

For privacy and data-protection related requests, please use our designated privacy contact channel:

Email: hello@podermonie.com

Telephone: +234 901 379 5672

Website: https://wealth.podermonie.com