Effective Date: 2025

Amaka Fund (“Amaka”, “we”, “our”, or “us”) is committed to protecting and respecting your privacy. This Privacy Policy outlines how we collect, use, store, disclose, and protect your personal data when you interact with our website, products, services, and communications.

1. Scope of Policy

This policy applies to:

• Visitors to our website
• Clients and potential clients
• Fund contributors, partners, and institutional investors
• Any individuals whose personal data we process in the course of our business operations

It is intended to comply with applicable data protection legislation including, where applicable, the Data Protection Act of Kenya, the Uganda Data Protection and Privacy Act, and the UK General Data Protection Regulation (UK GDPR).

2. Data We Collect

We may collect and process the following categories of personal data:

a) Information You Provide Directly

• Name, contact number, and email address
• Job title and employer/business details
• Investment-related queries or application details
• Information shared via contact forms, email, or when subscribing to updates or resources

b) Information Collected Automatically

• IP address, browser type, and device information
• Usage data and website interaction patterns
• Cookies and similar tracking technologies (see our Cookie Policy)

3. Purpose and Legal Basis for Processing

We process personal data for the following purposes and based on the legal grounds below:

Purpose	Legal Basis
To respond to inquiries and provide requested services	Performance of a contract / Legitimate interest
To maintain investor and contributor records	Legal obligation / Legitimate interest
To manage communications, newsletters, and updates	Consent / Legitimate interest
To improve website functionality and user experience	Legitimate interest
To comply with legal, regulatory, and risk management obligations	Legal obligation

4. Data Sharing and Disclosure

We may share your personal data with:

• Internal teams and departments of Amaka Fund
• Our service providers, legal and financial advisors, and IT consultants
• Regulators, law enforcement bodies, or public authorities when required by law
• Partners or counterparties in relation to mergers, acquisitions, or fund-related transactions, subject to confidentiality obligations

We ensure that any third party with whom we share data processes it in accordance with applicable laws and maintains appropriate security measures.

5. Data Transfers

Where personal data is transferred across borders (for example, to cloud service providers or affiliates in other jurisdictions), we implement adequate safeguards such as:

• Standard Contractual Clauses (SCCs)
• Data processing agreements
• Compliance with applicable data transfer laws

6. Data Retention

We retain personal data only for as long as is necessary for the purposes for which it was collected, or as required by applicable legal, regulatory, or contractual obligations. Once the retention period expires, data is securely deleted or anonymized.

7. Data Security

We have implemented suitable technical and organizational measures to protect your personal data, including:

• Encrypted communications
• Restricted data access
• Secure storage systems
• Periodic data audits and risk assessments

Despite these measures, no method of transmission over the internet is 100% secure. Therefore, we cannot guarantee absolute security.

8. Your Data Protection Rights

Subject to applicable law, you have the right to:

• Access the personal data we hold about you
• Request correction or deletion of your data
• Object to or restrict our use of your data
• Withdraw your consent at any time (where applicable)
• Lodge a complaint with a data protection authority

To exercise any of these rights, please contact us at info@kwelicapital.com.

9. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in technology, legislation, or our business practices. Any changes will be posted on this page with a revised “Effective Date.” We encourage you to periodically review this page to stay informed of how we protect your data.

10. Contact us

If you have any questions or concerns regarding this Privacy Policy or our data practices, please contact us on the contact provided in the website.