Information We Collect and How We Collect It

Information You Provide Us

Personal Information We May Collect About You

Information About Your Transactions

Information from Third Parties

Information Automatically Collected

Information Collected Through Cookies and Similar Technologies

How We Use Information

We may use the Personal Information we collect to:

• Create and manage any accounts you may have with us, verify your identity, provide our services, and respond to your inquiries;
• To administer Friction (i.e.to provide our Services to you) and support internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes This helps ensure Friction's stability and security, improve our Services, website, and user experience, create new products, and solicit your feedback.
• Process your payment transactions (including authorization, clearing, chargebacks and other related dispute resolution activities);
• Protect against and prevent fraud, unauthorized transactions, claims and other liabilities;
• Provide, administer and communicate with you about products, services, offers, programs and promotions of Friction, financial institutions, merchants and partners;
• Evaluate and improve our business, including developing new products and services;
• As necessary to establish, exercise and defend legal rights; As may be required by applicable laws and regulations, including for compliance with Know-Your- Customers and risk assessment, Anti-Money Laundering, anti-corruption and sanctions screening requirements, or as requested by any judicial process, law enforcement or governmental agency having or claiming jurisdiction over Nexos Easywave Limited or it's affiliates/subsidiaries;
• To comply with our legal and regulatory obligations.
• We also facilitate seamless communication between Users and send both marketing and non-marketing communications. This helps us better understand your preferences, enhance the effectiveness of our marketing efforts, and refine our campaigns and communication channels to serve you more effectively.
• For other purposes for which we provide specific notice at the time of collection.

How We Share Information

You agree that we can share your Personal Information, and other information that you share with us:

• if you requestor authorize it;
• if the information is provided to help complete a transaction for you;
• with any of our affiliated companies and service providers;
• with financial service providers, including the financial institutions identified in your cardholder bank agreement that provide banking services in connection with your Friction account;
• with another User, when you signup for our Services via a referral link. The User that referred you may receive information indicating that you have enrolled with us;
• with non-financial companies, such as email service providers that perform marketing services on our behalf, and fraud prevention service providers that use the information to provide services to us;
• with a non-affiliated third-party to access and transmit your personal and financial information from a relevant institution. You grant the third- party the right, power, and authority to access and transmit this information according to terms of their privacy policy;
• with selected third parties including business partners, suppliers and sub- contractors for the performance of any contract we enter into with them or you;
• with third parties to whom we may choose to sell, transfer or merge parts of our business or our assets or alternatively, acquire all or parts of their businesses;
• in response to a request for information, if we are required by, or we believe disclosure is in accordance with applicable laws, rules, regulations, governmental and quasi-governmental requests, court orders, or subpoenas or legal process;
• for our everyday business purposes;
• for publication of our events and competitions on digital and print media;
• protect our rights, property, or safety or the rights, property, or safety of our Users or others; or
• with relevant law enforcement officials or other third parties, such as investigators or auditors, if we believe it is appropriate to investigate fraud.

We do not share your Personal Information with: (1) other companies for joint marketing purposes without your consent; or (2) any other third parties so they can market to you.

If you provide us with bank account or debit card information, or any other payment information, through our Services, we may share that information with third-party payment processors and other third-party service providers, solely to the extent necessary to provide you with the relevant Services.

When you are no longer our User, we may continue to share your information as described in this Privacy Policy as permitted by applicable laws.

We may disclose Analytics with third parties for our commercial purposes.

Other Rights to Your Personal Information With Us

Below are the rights you have as a user in relation to your Personal Information:

• Right to request access or copies to your Personal Information by contacting us
• Right to information on their personal information collected and stored;
• Right to objection or request for restriction; this means refrain us from doing certain things with your data or restrict the extent of our collection or processing of your data.
• Right to correct or rectify any Personal Information that you provide which may be incorrect, out of date or inaccurate.
• Right to object to the processing of your Personal Information for marketing purposes. You have a right to ask us not to contact you for marketing purposes by adjusting your notification preference on the settings page or by opting out via the unsubscribe link in marketing emails we send you.
• Right to request that Friction erase your Personal Information.You have the right to ask us to erase your Personal Information. Please note that this is a limited right which applies where the data is no longer required, or the processing has no legal justification. The exceptions to this right is where the applicable law requires us to retain a historical archive or where we retain a core set of your personal data to ensure we do not inadvertently contact you in future where you object to your data being used for marketing purposes.
• Right to object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you.
• Right to request the movement of data from Friction to a third party; this is the right to the portability of data.
• Right to with draw consent. Where we are relying on consent to process your Personal Information, you may withdraw your consent to the processing of Personal

Information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain Services to you. We may advise you if this is the case at the time you withdraw your consent.

The basis of we processing your Personal Information is your consent. You also have the choice at any time to withdraw consent which you have provided. You may decline to provide your personal Information when it is requested by Friction, however, certain services or all the services may be unavailable to you. You may review your account settings and update your Personal Information directly or by contacting us. If you wish to exercise any of the rights set above, please contact us using the contact information provided in the Contact Us segment below.

Opt-Out Rights

If you do not wish to receive offers or other notices from us in the future, you can "opt out" by contacting us as indicated at the end of this Privacy Policy or by following the "unsubscribe" instructions in any communication you receive from us. Please be aware that if you are a User, you are not able to opt out of receiving communications about your Friction account or related transactions with us.

Information You Share Socially

Our Services may allow you to connect and share your actions, comments, content, and information publicly or with friends. We are not responsible for maintaining the confidentiality of any information you share publicly or with friends.

Our Services may also allow you to connect with us on, share on, and use third- party websites, applications, and services. Please be mindful of your personal privacy needs and the privacy needs of others, as you choose whom to connect with and what to share and make public. We cannot control the privacy or security of information you choose to make public or share with others. We also do not control the privacy practices of third parties. Please contact those sites and services directly if you want to learn about their privacy practices.

Security and Storage of your Personal Information

We have suitable security measures in place to prevent your Personal Information from being accidentally lost or used or accessed in an unauthorized way by a third party. When your bank account information is transmitted via our Services, it will be protected by encryption technology. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Information on our instructions.

All our employees who have access to your personal data are required to adhere to this Policy and all third-party service providers are requested by Friction to ensure appropriate safeguards are in place. In addition, contracts are in place with third-party service providers that have access to your personal data, to ensure that the level of security and protective measures required is in place, and that your personal data is processed only as instructed by Friction.

We have also put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. Unfortunately, no method of electronic transmission or storage via the Internet is 100% secure. Therefore, we cannot guarantee absolute security of your Personal Information. You also play a role in protecting your Personal Information. Please safeguard your password for your Friction account and do not share them with others.

If we receive instructions using your Friction account login information or other Friction account security information, we will consider that you have authorized the instructions. You agree to notify us immediately of any unauthorized use of your Friction account or any other breach of security. We reserve the right, in our sole discretion, to refuse to provide our Services, terminate Friction accounts, and to remove or edit content.

Subject to applicable law, which might, from time to time, oblige us to store your Personal Information for a certain period of time, we will retain your Personal Information for as long as necessary to fulfill the purposes we collected it for, including the purposes of satisfying any legal, accounting, or reporting requirements.

Data Security and Retention

As a regulated financial institution, Friction is required by law to store some of your personal and transactional data beyond the closure of your account with us. We only access your data internally on a need-to-know basis, and we'll only access or process it if absolutely necessary.

We will always delete data that is no longer required by a relevant law or jurisdiction in which we operate. We do this automatically, so you don't need to contact us to ask us to delete your data. Deletion methods include shredding, destruction and secure disposal of hardware and hard-copy records, and deletion or over-writing of digital data.

We deploy strict physical, electronic, and administrative security measures to protect your information from access by unauthorized persons, against unlawful processing and foreseeable hazards and breaches when online.

We generally retain your Personal Information for as long as is necessary for the purposes we collected it and also to give you better service. To this end, we are committed to maintaining the confidentiality of the Personal Information.

We may retain certain information when necessary to ensure safety, security, and prevent fraudulent activities. For instance, if your account is deactivated due to unsafe behavior or security violations, we may retain specific details about your account to safeguard our platform and prevent unauthorized re- registration or misuse.

To determine the appropriate retention period for Personal Information, we consider the amount, nature and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, and the applicable legal requirements.

By accessing this Website and any of its pages you are agreeing to the terms set out above. You may also request to have all your Personal Information deleted entirely. Please note that if you request the erasure of your Personal Information, we may retain and use your Personal Information to the extent necessary to comply with our legal obligations, including but not limited to tax, legal reporting and auditing obligations.

Third-Party Links

Our Services may, from time to time, contain links to the websites or online platforms of our partner networks, advertisers and affiliates. Please note that these websites have their own privacy policies and that we do not accept any responsibility for them, so if you follow a link, check these policies before you submit any personal data to these websites or platforms.

Age Restriction

Our Services are not directed, or intended to be used by children under the age of 18.

We do not knowingly collect Personal Information from children under the age of 18. If you are under the Age Limit, please do not use the Services, and do not provide any personal data to us. If as a parent or guardian, you become aware that your child or ward child has provided us with any information without your consent, please contact us through the details provided in this Privacy Policy.

Changes to Our Privacy Policy

Subject to applicable law, we may revise this Privacy Policy at any time and in our sole discretion. When we revise this Privacy Policy, we will post the revised version via our Services and will update the date at the top of this Privacy Policy. The revised Privacy Policy will be effective upon posting via our Services, unless otherwise set forth therein or as otherwise required by applicable law. You are free to decide whether or not to accept a revised version of this Privacy Policy, but accepting this Privacy Policy, as revised, is required for you to continue accessing or using our Services. If you do not agree to the terms of this Privacy Policy or any revised version of this Privacy Policy, your sole recourse is to terminate your access and use of our Services. Except as otherwise expressly stated by us, your access and use of our Services is subject to the version of this Privacy Policy in effect at the time of access or use.

Contact Us

If you have any questions, comments or concerns about this Privacy Policy, the personal information we hold on you, or you would like to exercise one of your data protection rights provided for under applicable privacy laws, you may contact us by:

• reaching out to the customer service support available on the website or app.
• sending an email t osupport@usefrictionai.com.
• calling +234 704 466 1075.

If you feel that we have not addressed your questions or concerns adequately, or you believe that your data protection or privacy rights have been infringed, you can complain to your local Data Protection Authority.