Privacy Notice

Sustainability Handlers Limited ("SHL", "we", "us" or "our") respects the privacy of visitors, clients, prospective clients, partners and other persons who interact with our website and digital services. Enhancing Capabilities (EC)™ is the trademarked business and innovation brand of Sustainability Handlers Limited. Where personal information is collected through EC-branded sections, products or enquiry channels operated by SHL, Sustainability Handlers Limited is responsible for the processing of that information unless a different data controller is expressly identified. This Privacy Notice explains how we collect, use, store, disclose and protect personal data obtained through this website and how individuals may exercise their rights in relation to their personal data. SHL recognises the constitutional protection of privacy under Section 37 of the Constitution of the Federal Republic of Nigeria 1999 (as amended) and processes personal data in accordance with applicable Nigerian data-protection legislation, including the Nigeria Data Protection Act 2023 (NDP Act) and applicable regulations, directives and guidance issued by the Nigeria Data Protection Commission.

For personal data collected directly through this website, the responsible entity is: Sustainability Handlers Limited (SHL) Registration Number: RC4319449 Registered Address: 24/26, Moshood Shittu street, Lagelu Estate, Challenge. Ibadan. Nigeria. Country of Incorporation: Federal Republic of Nigeria Privacy Contact: admin@shlencap.com General Contact: info@shlencap.com Where another organisation processes personal data jointly with SHL or independently in connection with a specific service, project or partnership, additional privacy information may be provided at the point at which the information is collected.

Depending on how you interact with the website, SHL may collect information including:

your name;

email address;

telephone number;

organisation or company name;

job title or professional information voluntarily supplied by you;

project, partnership or investment enquiry information;

messages and other information submitted through contact forms;

documents voluntarily uploaded through the website;

communication and correspondence records;

newsletter or marketing preferences;

IP address and basic device/browser information;

website usage and analytics information;

cookie identifiers and similar technical information; and

any other information you voluntarily provide when contacting SHL.

Visitors should avoid submitting sensitive personal data through general website enquiry forms unless it is necessary for the request and an appropriate collection mechanism has been provided.

We may obtain personal data:

directly from you when you complete a website form;

when you contact SHL by email, telephone or another communication channel;

when you request information about SHL or Enhancing Capabilities™ products and services;

when you subscribe to approved communications;

through cookies and similar technologies, subject to applicable consent requirements;

from organisations you represent where reasonably necessary for a business relationship; and

from service providers or business partners where such collection and subsequent processing is lawful.

SHL may process personal data for purposes including: Responding to enquiries: To receive, assess and respond to requests submitted through the website. Business development: To evaluate potential projects, partnerships, investments, collaborations and commercial opportunities. Service delivery: To provide requested information, products, services or support. Relationship management: To maintain appropriate records of communications with clients, prospective clients, partners and stakeholders. Website administration and security: To maintain website functionality, diagnose technical problems, protect our systems and prevent misuse. Analytics and improvement: To understand how visitors use our website and improve its content, functionality and user experience, subject to applicable cookie and consent requirements. Legal and regulatory compliance: To comply with applicable Nigerian law, regulatory requirements, court orders and lawful requests from competent authorities. Marketing communications: To send approved news, insights, product information and similar communications where you have consented or where another lawful basis permits such communication. We will not process personal data in a manner incompatible with the purpose for which it was collected unless permitted by applicable law.

Depending on the circumstances, SHL will process personal data on an appropriate lawful basis recognised under applicable Nigerian data-protection law. This may include:

your consent;

steps necessary at your request before entering into a contract;

performance of a contract;

compliance with a legal obligation;

protection of vital interests;

performance of a task carried out in the public interest where applicable; or

legitimate interests pursued by SHL or another relevant party, provided those interests do not improperly override the rights and interests of the data subject.

Where processing is based on consent, you may withdraw that consent in accordance with applicable law.

Submission of a general website enquiry does not automatically subscribe you to SHL marketing communications. Where SHL provides an option to receive news, insights, opportunities or marketing information, the website should provide a separate and clearly identifiable choice. Where marketing is based on consent, individuals may withdraw their consent or unsubscribe from future communications using the mechanism provided or by contacting SHL.

SHL does not sell personal data collected through this website. Where reasonably necessary and legally permitted, SHL may disclose relevant personal data to:

technology and website service providers;

professional advisers;

consultants and contractors;

project and implementation partners;

cloud-hosting and communications providers;

companies providing services to SHL;

government agencies, regulators, courts or law-enforcement authorities where legally required; and

other parties where disclosure is necessary for a transaction, project or service requested by the data subject.

SHL will seek to ensure that third parties processing personal data on its behalf are subject to appropriate confidentiality, security and data-protection obligations.

SHL operates and develops partnerships in an international business environment. Accordingly, some technology providers, consultants, cloud-service providers or project partners may process information outside Nigeria. Where personal data is transferred from Nigeria to another country, SHL will take reasonable steps to ensure that the transfer complies with the Nigeria Data Protection Act 2023 and applicable requirements governing cross-border transfers. This may include relying on an adequate level of protection, appropriate contractual or organisational safeguards, or another legally recognised basis for the transfer.

SHL will retain personal data only for as long as reasonably necessary for the purposes for which it was collected and to satisfy applicable legal, regulatory, contractual, accounting, dispute-resolution and legitimate business requirements. As an initial operational standard, general website enquiries and related contact records may ordinarily be retained for up to 24 months following the last substantive interaction, unless:

the enquiry develops into an ongoing business or contractual relationship;

a longer retention period is legally required;

the information is relevant to an ongoing project, transaction, investigation or dispute; or

there is another lawful reason for retaining the information.

Personal data that is no longer required will be deleted, anonymised or otherwise securely disposed of in accordance with SHL's applicable retention procedures.

The website may use cookies and similar technologies to provide essential functionality and, where permitted, to understand website usage and improve the visitor experience. Cookies may include:

strictly necessary cookies;

functional cookies;

analytics or performance cookies; and

marketing cookies, where such functionality is deployed.

Where consent is required for non-essential cookies, those cookies should not be activated until the visitor has made the appropriate choice. Visitors should be provided with appropriate mechanisms to accept, reject or manage non-essential cookie preferences.

SHL will take appropriate technical and organisational measures designed to protect personal data against unauthorised access, accidental loss, misuse, alteration, disclosure or destruction. Such measures may include, where appropriate:

access controls;

secure website connections;

authentication controls;

restricted administrative privileges;

appropriate data backups;

security monitoring;

contractual confidentiality obligations; and

appropriate incident-response procedures.

No internet-based service can, however, be guaranteed to be completely secure.

Where SHL becomes aware of a personal-data breach, it will assess the nature and potential consequences of the incident and take appropriate containment, investigation and remedial measures. Where notification to the Nigeria Data Protection Commission or affected data subjects is required under applicable law, SHL will make the relevant notification in accordance with applicable statutory requirements.

Subject to applicable law and any lawful limitations or exemptions, individuals may have rights concerning their personal data, including rights to:

obtain information about the processing of their personal data;

request access to personal data held about them;

request correction of inaccurate or incomplete information;

request deletion or erasure where legally applicable;

request restriction of certain processing;

object to certain processing;

withdraw consent where processing is based on consent;

request portability of personal data where applicable;

object to certain automated decision-making; and

lodge a complaint with the appropriate data-protection authority.

Requests concerning these rights may be submitted to: admin@shlencap.com SHL may request reasonable information necessary to verify the identity of the person making the request before disclosing, correcting or deleting personal data.

Where you believe that your personal data has been processed contrary to applicable Nigerian data-protection legislation, you may have the right to lodge a complaint with the Nigeria Data Protection Commission (NDPC). You are encouraged to contact SHL first so that we have an opportunity to investigate and respond to your concern. This does not remove any statutory right you may have to approach the Commission or seek another remedy available under Nigerian law.

The SHL website may contain links to websites, platforms or services operated by third parties. SHL is not responsible for the privacy practices of independent third-party websites. Visitors should review the applicable privacy notice of any external website before providing personal information to it.

SHL may amend this Privacy Notice periodically to reflect changes in its website, business activities, technology, legal obligations or data-processing practices. The revised Privacy Notice will display an updated effective or revision date. Where a material change requires additional notice or consent under applicable law, SHL will take appropriate steps to provide such notice or obtain such consent.

Questions, requests or concerns relating to this Privacy Notice or SHL's handling of personal data should be directed to: Sustainability Handlers Limited Privacy/Data Protection Contact Email: admin@shlencap.com