Thamani Cookie Policy

1.1 This Cookie Policy explains how Thamani uses cookies and similar technologies when you visit or use our website, Platform, apps and other online services. We use cookies for a few reasons: some keep the site working properly, others help us understand how people use it and improve the experience. 1.2 Here is what this Policy covers: what cookies are: the types we may use; why we use them; cookie Lifespan; when third parties are involved; how cookies relate to your personal information; how you can manage your choices; and who to contact with questions. Read this alongside our Privacy Notice and Terms of Use.

2.1 Cookies are small text files a website can place on your device when you visit it. They let the website recognise your device and remember certain things about your visit by helping it work properly, remember your preferences, keep you signed in, improve security, understand how visitors use the site, measure performance, and generally make the experience more useful. 2.2 Cookies are not the only technology that does this, as we may also use similar technologies like pixels, tags, and local storage. For simplicity, this Policy refers to all of these collectively as cookies or similar technologies.

Depending on the technology in use on the Platform, we may use cookies to: keep the website and Platform running; remember your settings and preferences; maintain your session; support security; detect unusual or potentially fraudulent activity; understand how visitors use our site; measure performance; improve our products; understand which pages and features people actually use; support communications and marketing where permitted;and generally keep the Thamani experience working well. We aim to use cookies for clear, reasonable purposes and not just because the technology happens to be available.

The categories below cover what is relevant to the Thamani Platform. 4.1 Strictly necessary cookies keep the website or platform working with things like account login, session management, security, authentication, maintaining your settings, and preventing misuse. Because they are needed for the Platform to function, they generally cannot be switched off through a cookie preference tool. Blocking them through your browser may break parts of the site. 4.2 Functional cookies help the website remember choices you have made, like language preference, region, display settings, and similar. They are not always essential to basic operation. Where they are non essential, we ask for your permission before using them on an opt in basis, not by default. 4.3 Analytics and performance cookies These cookies help us understand how visitors use the Thamani website, which pages get visited, how people move around the site, which features get used, how long visitors stay on a page, whether pages work properly, and where the website can improve. Depending on the technology and settings used, this information may or may not directly identify you. Where an analytics tool does process personal information, that use is also covered by our Privacy Notice. 4.4 Security and fraud prevention technologies may use cookies or similar technologies to help protect the Platform by recognising suspicious activity, protecting accounts, preventing unauthorised access, flagging unusual behaviour, and investigating security incidents. These can be essential to keeping our services secure, which is part of why we do not publish granular technical details about them (see Section 10). 4.5 Marketing and advertising cookies Where applicable, we may use cookies to understand how users interact with our communications and campaigns including measuring campaign effectiveness, avoiding showing you the same ad repeatedly, understanding what is relevant to you, and improving our marketing. We only use non essential marketing or advertising cookies where we have a lawful basis, and where consent is required under applicable law only after you have actively opted in. We do not set these by default and wait for you to opt out.

5.1 First party cookies are cookies placed directly by Thamani s website or Platform for essential functions, security, preferences, analytics, or other purposes described in this Policy. 5.2 Third party cookies services on the Thamani Platform may be provided by third parties for example, providers of analytics, payment services, security, communications, customer support, marketing, or embedded content and those providers may place or access their own cookies through the Platform. Third parties may have their own privacy and cookie practices. Where relevant, we will identify these providers in our cookie information or other privacy disclosures.

A cookie does not necessarily identify you by name. But information collected through cookies can sometimes be linked to other information that does identify you, or could reasonably be used to where that happens, it is treated as personal information under applicable data protection law, and our use of it is also covered by the Thamani Privacy Notice, which explains what we collect, why, our legal basis, who we share it with, how long we keep it, international transfers, your rights, and how to reach us.

7.1 Non essential cookies are off by default. Before we set them, you will be given a genuine choice; presented clearly and prominently, not buried in a footer link to accept all non essential cookies, reject them, or choose which categories you are comfortable with. 7.2 Accepting and declining carry equal weight; declining is not made harder to find or click than accepting. Strictly necessary cookies keep running regardless, because the Platform needs them to function. 7.3 Where a cookie preference tool is available, you can change your choices there at any time. Changing your preference doesn t automatically delete cookies already placed on your device and you may need to clear those through your browser.

8.1 You can also manage cookies through your browser settings as most browsers let you see what is stored, delete cookies, block certain ones, block all of them, or get a warning before a cookie is set. The exact steps depend on your browser and device. 8.2 Blocking or deleting certain cookies may affect how the Thamani website or Platform works; for example, if you block essential cookies, some functions may stop working properly.

Some cookies are session cookies as these clear when you close your browser. Others are persistent, staying on your device for a set period or until you delete them. How long depends on the cookie s purpose and the technology involved. We would not keep cookies longer than reasonably necessary for their stated purpose, subject to applicable technical, security and legal requirements.

Some cookies or similar technologies help protect Thamani and its users. We do not publicly disclose every technical detail of our security systems as publishing that level of detail can itself create security risk, but we will tell you the categories and purposes of the cookies involved.

11.1 We use third party technology providers to help run our website and Platform. Depending on what s actually deployed, these providers may process information through cookies or similar technologies. 11.2 Where a third party processes personal information on our behalf, we take reasonable steps to make sure appropriate data protection and security obligations apply to them. Where a third party processes information for its own purposes, its own privacy and cookie practices apply too. 11.3 Confirmed third party providers currently deployed on the Platform: Mixpanel (product analytics), Airbridge (mobile attribution and campaign performance), and Mailerlite (email marketing). Where these providers process personal information on our behalf, we take reasonable steps to ensure appropriate data protection and security obligations apply to them, including through data processing agreements where required. See Section 12 for how this relates to international transfers. 11.4 The full technical detail for each of these tools and any others added in future will be listed in our Cookie Register and, where appropriate, in the cookie preference tool.

12.1 Some third party technology providers may process information outside Nigeria. Thamani currently uses Amazon Web Services (AWS) infrastructure, including the US West (Oregon) region, for certain data storage and technology services. 12.2 Where cookie related or other personal information is transferred outside Nigeria, we take steps to ensure that transfer is supported by appropriate safeguards under Nigerian data protection law, which may include contractual, technical or organisational measures. See Section 17 of our Privacy Notice for more on how this applies to our cloud infrastructure specifically.

13.1 Where we use cookies for marketing, we do it in line with applicable law by asking for your consent first where required. You can withdraw or change your marketing cookie preferences any time the preference mechanism is available. 13.2 Changing your preferences does not necessarily mean you will stop seeing ads altogether; it may just mean they are less tailored to you.

The Thamani Platform may link to third party websites or services. Once you leave Thamani, that third party may use its own cookies and tracking technologies and we don t control their practices, so check their privacy and cookie policies before you share anything with them.

No, not general access to your files or applications. Cookies are generally used to recognise your browser or device and store or retrieve limited information tied to your interaction with the website. Other technologies may work differently, depending on the specific service

Not necessarily. Some cookies only collect technical or statistical information. But where information from a cookie can be linked to something that identifies you, it may be treated as personal information, and we ll handle it in line with applicable data protection law and our Privacy Notice.

17.1 We may update this Policy from time to time on new products or features, new technology, a change in how we use cookies, a new service provider, a change in the law, or general improvements to our privacy practices. 17.2 When we make a material change, we will update the Last Updated date and, where appropriate, bring it to your attention.

Where information collected through cookies counts as personal information, you may have rights under applicable law to access it, correct it, object to certain processing, restrict processing, request deletion, request portability, withdraw consent where processing is based on consent, and exercise other rights the law gives you. Full detail on these rights is in our Privacy Notice.

Questions about how Thamani uses cookies or similar technologies? Reach us: • Thamani Invest Limited • Privacy/Data Protection Contact:+234 9057488651 • Email: Help@thamani.com • Address: 21 Covenant Estate, Chief Yesufu Abiodun Road, Oniru, Victoria Island, Lagos State We will try to respond to privacy and cookie questions within a reasonable time and in line with applicable requirements.

20.1 We maintain an internal record of the cookies and similar technologies used on the Platform. At minimum, the register identifies: the cookie or technology s name; its provider; whether it s first party or third party; its purpose; its category; what information it collects; whether it processes personal information; how long it stays active; where the information is processed; whether it transfers information outside Nigeria; and the legal basis or consent requirement that applies to it. 20.2 What we show publicly is drawn directly from this register, based on the technologies actually deployed on the Platform. The tools currently in use are identified in Sections 4 and 11 of this Policy; the register is reviewed and updated as our use of cookies and similar technologies changes.

We want our use of cookies to be useful, reasonable and transparent. So we aim to: use cookies for clear purposes; avoid unnecessary tracking; collect only what we reasonably need; respect applicable consent requirements; give you meaningful choices where required; review the third party technologies we use; protect the information cookies collect; and drop cookies we no longer need. As Thamani grows and adds new technology, we will keep reviewing our cookie practices and update this Policy accordingly.