Modified 20 November 2018
Our privacy obligations Chukolo Core. (“Chukolo”) provides this Privacy Policy to let you know our policies and procedures regarding the collection, use and disclosure of information through the “Site”), and any other websites, features, applications, widgets or online services that are owned or controlled by Chukolo and that post a link to this Privacy Policy (together with the Site, the “Service”), as well as any information Chukolo collects offline in connection with the Service. It also describes the choices available to you regarding the use of, your access to, and how to update and correct your personal information. Note that we combine the information we collect from you from the Site, through the Service generally, or offline. The types of personal information we collect and hold We collect personal information about our users in order provide our products, services, and customer support. Our products, services, and customer support are provided through many platforms including but not limited to: websites, phone apps, email, and telephone. The specific platform and product, service, or support you interact with may affect the personal data we collect. Not all information requested, collected, and processed by us is "Personal Information" as it does not identify you as a specific natural person. This will include majority of "User Generated Content" that you provide us with the intention of sharing with other users. Such "Non-Personal Information" is not covered by this privacy policy. However, as non-personal information may be used in aggregate or be linked with existing personal information; when in this form it will be treated as personal information. As such, this privacy policy will list both types of information for the sake of transparency. In some situation users may provide us with personal information without us asking for it, or through means not intended for the collection of particular types of information. Whilst we may take reasonable steps to protect this data, the user will have bypassed our systems, processes, and control and thus the information provided will not be governed by this privacy policy. In some situations, users may provide us personal information over platforms that are outside our control; for example through social media or forums. Whilst any information collected by us is governed by this Privacy Policy, the platform by which it was communicated will be governed by its own Privacy Policy. How we collect personal information Information that you specifically give us While you use our products and services you may be asked to provide certain types of personal information. This might happen through our website, applications, online chat systems, telephone, paper forms, or in-person meetings. We will give you a Collection Notice at the time, to explain how we will use the personal information we are asking for. The notice may be written or verbal. We may request, collect, or process the following information: • Account Details - username, password, profile picture. • Contact Details - email address, phone number. • Location Details - physical address, billing address, timezone. • Identity Details - full name, proof of identity (e.g. drivers licence, passport), proof of address (e.g. utility bill), photograph of the user. • Financial Information - credit card details, • User Generated Content - project descriptions and attachments, bid description, user profiles, user reviews, contest descriptions and attachment, user messages etc. Information that we collect from others Users can give permission for us to connect to their account on other platforms to collect personal information. This includes but is not limited to Facebook, LinkedIn, and Google. Information collected will be governed by this Privacy Policy. Users can stop us from collecting data from other platforms by removing our access on the other platform or by contacting our support team. Users have the ability to invite non-users to our platform by providing contact details such as email address. In these situations, the information will be collected and stored by us to contact the non-user and to prevent abuse of the invite systems. Your payment provider may transmit information about the payment that we may collect or process. In some situations, personal information of users may be collected from public sources. We may collect or process the following information: • Basic Details - username, profile picture. • Contact Details - email address, phone number. • Location Details - Physical Address, billing address, timezone. • Financial Information - payment account details (e.g. bank account number), • List of contacts - email provider address book. • User Generated Content - user profile. Information we collect as you use our service We maintain records of the interactions we have with our users, including the products, services and customer support we have provided. This includes the interactions our users have with our platform such as when a user has viewed a page or clicked a button. In order to deliver certain products or services we may passively collect your GPS coordinates, where available from your device. Most modern devices such as smartphones will display a permission request when our platform requests this data. When we are contacted, we may collect personal information that is intrinsic to the communication. For example, if we are contacted via email, we will collect the email address used. We may collect or process the following information: • Metadata - IP address, computer and connection information, referring web page, standard web log information, language settings, timezone, etc. • Device Information - device identifier, device type, device plugins, hardware capabilities, etc. • Location - GPS position. • Actions - pages viewed, buttons clicked, time spent viewing, search keywords, etc. Links to other sites On our website, you will encounter links to third party websites. These links may be from us, or they may appear as content generated by other users. These linked sites are not under our control and thus we are not responsible for their actions. Before providing your personal information via any other website, we advise you to examine the terms and conditions of using that website and its privacy policy. How we use personal information The information we request, collect, and process is primarily used to provide users with the product or service they have requested. More specifically, we may use your personal information for the following purposes: • to provide the service or product you have requested; • to facilitate the creation of a User Contract (see Terms of Service for more information); • to provide technical or other support to you; • to allow for debugging, testing and otherwise operate our platforms; • to conduct data analysis, research and otherwise build and improve our platforms; • to comply with legal and regulatory obligations; • if otherwise permitted or required by law; or • for other purposes with your consent, unless you withdraw your consent for these purposes. • to answer enquiries about our services, or to respond to a complaint; • to promote our other programs, products or services which may be of interest to you (unless you have opted out from such communications); The 'lawful processing' grounds on which we will use personal information about our users are (but are not limited to): • when a user has given consent; • when necessary for the performance of a contract to which the user is party; • processing is necessary for compliance with our legal obligations; • processing is necessary in order to protect the vital interests of our users or of another natural person. • processing is done in pursuing our legitimate interests, where these interests do not infringe on the rights of our users. We use automated decision when helping matching users to jobs. The primary way this occurs is through how we rank users. These rankings are produced by analysing user generated content, user activity and the outcome of jobs; in this context, user generated content will include reviews that users receive when completing jobs. More information on these ranking guides can be found in our community articles. Automated decision making is also used to recommend potential jobs to our users and as a part of our marketplace security systems. When we disclose personal information Our third-party service providers The personal information of users may be held or processed on our behalf outside Nigeria, including 'in the cloud', by our third-party service providers. Our third-party service providers are bound by contract to only use your personal information on our behalf, under our instructions. Our third-party service providers include: • Cloud hosting, storage, networking and related providers • SMS providers • Payment and banking providers • Marketing and analytics providers • Security providers Third party applications Through the Chukolo API it is possible for users to grant third party applications access to their Chukolo account. Depending on the permissions that are granted, these applications may be able to access some personal information or do actions on the users' behalf. These third-party applications are not controlled by us and will be governed by their own privacy policy. Other disclosures and transfers We may also disclose your personal information to third parties for the following purposes: • if necessary, to provide the service or product you have requested; • we receive court orders, subpoenas or other requests for information by law enforcement; • if otherwise permitted or required by law; or • for other purposes with your consent. As we are a global company, with offices around the world, your personal information may be processed by staff in any of our offices. Chukolo currently has offices in Nigeria. Accessing, correcting, or downloading your personal information You have the right to request access to the personal information Chukolo holds about you. Unless an exception applies, we must allow you to see the personal information we hold about you, within a reasonable time period, and without unreasonable expense for no charge. Most personal information can be accessed by logging into your account. If you wish to access information that is not accessible through the platform or wish to download all personal information, we hold on you in a portable data format, please contact our Privacy Officer. You also have the right to request the correction of the personal information we hold about you. All your personal information can be updated through the user settings pages. If you require assistance, please contact our customer support. Exercising your other rights You have several other rights in relation to the personal data Chukolo holds about you, however, there may be restrictions on how you may exercise the rights. This is largely due to the nature of the products and services we provide. Much of the data we collect is in order to facilitate contracts between users, facilitate payments, and provide protection for the legitimate users of our marketplace - these data uses are protected against the below rights. You have the right to: • seek human review of automated decision-making or profiling • opt-out of direct marketing, and profiling for marketing • erasure • temporary restriction of processing. Human review of automated decision making / profiling - In the case of our ranking algorithms, it is not possible to exercise this right as this ranking is a fundamental part of the marketplace that users participate in, opting out would mean not being able to participate in the marketplace. Decisions affecting marketplace security are already reviewed by humans. Direct marketing and profiling - users can control what emails they receive through their settings page. Erasure - Most personal information and user generated content cannot be deleted as they are used to support contracts between users, document financial transactions, and are used in providing protecting other legitimate users of the marketplace. In the case of non-personal data that can be linked with personal data, it will either be erased or otherwise anonymised from the personal data. Temporary restriction to processing - under certain circumstances you may exercise this right, in particular if you believe that the personal data we have is not accurate, or you believe that we do not have legitimate grounds for processing your information. In either case you may exercise this right by contacting our privacy officer. Unless stated above, users may exercise any of the above rights by contacting our Privacy Officer. To contact our Privacy Officer If you have an enquiry or a complaint about the way we handle your personal information, or to seek to exercise your privacy rights in relation to the personal information we hold about you, you may contact our Privacy Officer as follows: By Email: While we endeavour to resolve complaints quickly and informally, if you wish to proceed to a formal privacy complaint, we request that you make your complaint in writing to our Privacy Officer, by mail or email as above. We will acknowledge your formal complaint within 10 working days of receipt.

COPYRIGHT INFRINGEMENT POLICY Chukolo respects the intellectual property rights of others. If you believe that your work has been copied in a way that constitutes copyright infringement, please provide Chukolo's Copyright Agent with the information specified below in the form of a "Notification of Alleged Infringement." It is Chukolo's policy to respond to clear Notifications of Alleged Infringement, and our policy is designed to make submitting Notifications of Alleged Infringement as straightforward as possible while reducing the number of Notifications that we receive that are fraudulent or difficult to understand or verify. If you are a User (as defined in the User Agreement at or subscriber and concerned about the removal of or blocked access to your content, please provide Chukolo's Copyright Agent with the written information specified below in the form of a "Counter- Notification." NOTIFICATION OF ALLEGED COPYRIGHT INFRINGEMENT If you would like to submit a claim of copyright infringement for material, please substantiate each claim by sending Chukolo's registered Copyright Agent a Notification of Claimed Infringement at the email or mailing address below: Copyright Agent c/o Chukolo, Greenland Estate Lekki Ajah Lagos Nigeria To be considered effective, a Notification of Alleged Infringement must be submitted in writing and include the following information: 1. Physical or electronic signature of the owner, or a person authorized to act on behalf of the owner, of an exclusive copyright that has allegedly been infringed 2. Identification of the copyrighted material claimed to have been infringed 3. Identification of the material that is claimed to be infringing or to be the subject of infringing activity that is to be removed or access to which is to be disabled 4. Information reasonably sufficient to permit Chukolo to locate the material that is claimed to be infringing or to be the subject of infringing activity 5. Information reasonably sufficient to permit Chukolo to contact person submitting the Notification, such as a physical address, email address, and telephone number 6. A statement that the person submitting the Notification has a good faith belief that use of the material in the manner complained of is not authorized by the copyright owner, its agent, or the law 7. A statement that the information in the Notification is accurate, and under penalty of perjury, that the person submitting the Notification is authorized to act on behalf of the owner of an exclusive right that is allegedly infringed

Know Your Customer and Identity Verification Policy What is the Know Your Customer (KYC) program? Chukolo’s KYC program ensures a trusted marketplace for all users by confirming customer identity through documentation collection. This helps to prevent fraud, money laundering, and the financing of terrorism. We believe that KYC is a requirement that ensures a safer and secure online workplace for all Chukolo members. In addition, several of our service providers, such as our payment gateway providers require us to perform certain checks on customer identity. How do I complete KYC to verify my identity? You can become Chukolo Verified by submitting a valid government-issued ID card, keycode verification and 2 recent utility bills or bank statements or 1 of each. To learn more about the identity verification process #link To verify your identity now #link What if the details on my account do not match the name on my ID or documentation? The details registered on your Chukolo account must match the name on your documentation. You will be asked to confirm your details during the verification process before submitting them for review. What happens if I'm not able to pass KYC? If you are unable to become Chukolo Verified, Chukolo may place an account limitation or suspend your account as a security measure. Falsifying your identity is a crime. Chukolo may report users that provide false documentation. ID Verification Sellers are encouraged to verify their identity to market themselves to potential Buyers as trusted members of our Chukolo community. Users that verify their identity also benefit by receiving faster processing of their payments and faster resolution of account issues and disputes. Verification may be completed by users at any time, but Chukolo may also request users verify their identity to uphold our User Agreement. To become Chukolo Verified we require you provide: • Proof of identity by submitting a Government-issued photo ID. • Keycode Verification by submitting a photo of you holding a unique code (that you will be provided) and your ID side-by-side. • Proof of address by submitting two different copies of a recent utility bill, such as an electric, gas, water or phone bill, or a recent bank statement. To verify your identity, complete the following steps: Step 1 - Proof of identity • Confirm your account details are up to date (Go to Profile > Settings > Account Details). • Click the Verify my me link from your Account Details page. • Confirm your name and date of birth and upload a color scan of your current governmentissued photo ID as Proof of identity (see accepted IDs below). • Enter the ID type, the name on the ID, ID number and expiration date and press Save and Continue. Step 2 - Keycode Verification • You will be provided with a unique keycode that you will need to write on a piece of paper or you may print it. • If you are writing the code, ensure you write "Keycode Verification for" then the unique code. • Take a photo of you holding the unique keycode and your ID side-by-side as shown in the example. • Ensure that you include your face and that your keycode and ID are clearly visible. • Upload the photo then press Save and Continue. Step 3 - Proof of address • Confirm your address and enter your preferred contact phone number. If you haven't already set up a Security Phone Number, you will be sent a unique code to verify this number. • Upload a colour scan of two different utility bills or bank statements as proof of residential Address (see accepted documentation below). • Fill in the institutions name, documentation type, and the date it was issued. • Press the Complete. Submit for Review button to have our Verification team review your request. The Chukolo Verification Team will review your request. This can take up to 2-3 business days and you will be notified when the review process is complete. Proof of identity requirements: We require a colour scanned image or digital photo of acceptable government-issued photo identification. Acceptable forms of Identification: • Passport • Driver's License • National ID card Additional requirements: • High quality colour scan image or digital photo. • Image dimensions must be 500 x 300 pixels minimum. • Must be currently valid (not expired). • Must include photo, signature, name and date of birth. • Must not be hand written. • Do not crop, adjust colours, or alter the image in any way. • Name on ID must match the name entered in the Verification Centre. • ID number must match the ID number entered in the Verification Centre. If you have any questions or concerns with these requirements you can contact our customer support team at

Milestone Dispute Resolution Policy This Policy sets out the dispute process to be followed when a Buyer and Seller who have used the Milestone Payment system elect to use to the Milestone Dispute Resolution process to resolve a dispute between them. The Milestone Dispute Team Both parties of the Dispute case can elect to have their dispute arbitrated by the Dispute Team. The role of the Dispute Team extends to making all actions necessary to resolve the case in an impartial and evidential manner. You acknowledge that the verdict of the Dispute Team is final, binding, and irreversible. User Responsiveness Buyers Once a dispute is opened, a Buyer is given 14 days to respond to it. Otherwise, they will automatically lose the dispute and the pending Milestone will be transferred to the Seller's account. Sellers Once a dispute is opened, a Seller is given 4 days to respond to it. Otherwise, they will automatically lose the dispute and the pending Milestone will be returned to the Buyer's account. Milestone Dispute Resolution Process • STAGE 1 - Identifying the issue The complainant should select the Project and the Milestone payment or payments to be disputed. A User could contest all the Milestones related to a single project in one dispute. After which, a description of the issue and an explanation of why the dispute is being opened should be given. From this stage until Stage 3, users are encouraged to attach any files that could support their claims. Finally, the complainant is requested to enter the amount he or she is prepared to pay for the Project (if a Buyer) or wish to get paid for the Project (if a Seller). The amount could be between 0 and the total amount of the Milestone Payment(s) in question. • STAGE 2 - Negotiations At this stage, either party can negotiate for partial compensation, or (after a period of time) choose to have Chukolo's Dispute Team arbitrate the dispute. Both parties will have the opportunity to tell their side of the story and also negotiate terms to resolve the issue between themselves. Only the party who originally filed for the dispute can cancel the dispute. If the issue cannot be resolved through negotiation, either party can choose to pay the Arbitration Fee to have the dispute arbitrated by the Dispute Team. The Arbitration Fee will be refunded if the dispute is either settled through mutual agreement or cancelled before reaching arbitration. • STAGE 3 - Final Offers and Evidence After one of the involved parties has paid the Arbitration Fee, the other party has 4 days to also pay the fee. Either party still has the option in this period to negotiate with the other party. If the responding party does not pay the arbitration fee within the 4 days, the result will be in favour of the party who escalated the dispute into arbitration first. If a solution is found before the responding party pays the fee, the party who paid the Arbitration Fee will be refunded this fee. Stage 3 is the last stage where both Users can submit their final evidence to support their case. After Stage 3, the involved parties are no longer allowed to submit evidence. The dispute will be resolved based upon the evidence provided through the Dispute System, or that is otherwise available to the Dispute Team, such as the project description and correspondence between the parties. Once the dispute has proceeded to Stage 4, further evidence will no longer be accepted. • STAGE 4 - Arbitration At Stage 4, the Dispute Team will review all evidence and other information provided to reach a decision (usually within 48 hours). Dispute verdicts are final, binding, and irreversible. The party who wins the dispute will be refunded their Arbitration Fee. In the event that one of the parties of the Dispute has paid the Arbitration Fee, the other party will be given 4 days to pay the Arbitration Fee to move into Arbitration, and failure to do such will close the dispute by default, in favor of the party who initiated stage 4, with the arbitration fee initially paid refunded. Evidential Requirements for Your Dispute Should you elect to have the Dispute Team arbitrate your dispute, you agree to allow the Dispute Team to read all correspondence made on the Site and download or access, and test (if necessary), all uploaded files, programs, and websites related to the dispute for the sole purpose of having your dispute resolved. You are highly encouraged to submit all the documents that would support your claims on your dispute. Submit e-mail correspondences as screenshots or as *.eml files. If submitting screenshots, ensure that the "To", "From", and the "Date" bar is visible. E-mail correspondences sent in *.txt or *.doc or any word processing software will not be honoured. For proof of external correspondence, users should provide screenshots of their entire unedited conversation. IM (instant messenger) conversations should be submitted as screenshots of the conversation from the IM software. Correspondences sent in *.txt, *.doc, or any word processing software will not be honoured. Provide the products, contracts, and other files relating to the project and the dispute. Chukolo will retain the confidentiality of the project and the privacy of the involved users and will not release the collected information to any party unless required by law. Fee The fee for a milestone dispute is NGN 1,800.00 or 3%, whichever is greater, payable by each party.