EVERMARK COMPANY LIMITED

PRIVACY POLICY

Adopted pursuant to the Personal Data Protection Act, 2022 (United Republic of Tanzania) and applicable laws.

1.PREAMBLE

This Privacy Policy is issued by Evermark Company Limited (hereinafter referred to as “Evermark”, “the Company”, “we”, “our” or “us”), an online land and property listing platform operating within the United Republic of Tanzania.

This Policy sets out the principles and procedures governing the collection, processing, storage, disclosure, and protection of personal data of customers in compliance with the Personal Data Protection Act, 2022 and other

applicable laws and regulations.

2.INTERPRETATION AND DEFINITIONS

For purposes of this Policy:

“Personal Data” means any information relating to an identified or identifiable natural person.

“Data Subject” means a natural person whose personal data is processed. “Processing” includes collection, recording, storage, adaptation, retrieval, consultation, use, disclosure, transmission, or destruction of personal data.

“Customer” means any individual accessing the Evermark platform for purposes of inquiry, registration, or land transaction.

“Third Party” means any natural or legal person other than the data subject, controller, processor, or authorized persons.

3.PRINCIPLES OF DATA PROCESSING

Evermark shall ensure that personal data is processed lawfully, fairly, and transparently. Processing shall be limited to specific, explicit, and legitimate purposes. Data collected shall be adequate, relevant, and not excessive in relation to the purposes for which it is processed. Personal data shall be accurate and, where necessary, kept up to date. Appropriate security measures shall be implemented to prevent unauthorized access, alteration, disclosure, or destruction.

4.CATEGORIES OF PERSONAL DATA COLLECTED

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

a. Identity Data Full name, National Identification Number (NIDA),passport details (where applicable), date of birth.

b. Contact Data: Telephone number, email address, physical address.

c. Transaction Data: Property preferences, purchase history, payment confirmations.

d. Technical Data: IP address, browser type, device identifiers, usage analytics.

e. Communication Data: Records of correspondence, inquiries, and customer service interactions.

5.LAWFUL BASIS FOR PROCESSING

Personal data shall be processed on lawful grounds including: consent of the data subject; necessity for performance of a contract; compliance with

legal obligations; protection of legitimate interests of the Company; or protection of vital interests of the data subject.

6.PURPOSES OF PROCESSING

Personal data shall be processed strictly for purposes including facilitating land inquiries and transactions; verifying identityfor fraud prevention and compliance;

enabling communication betweencustomers and brokers;processing payments; complying with regulatory requirements; and improving the functionality and security of the platform.

7.DATA SHARING AND DISCLOSURE

Personal data may be disclosed to verified brokers,financial institutions, payment processors, professional advisors, regulatory authorities, and contracted IT service

providers, strictly on a need-to-know basis and subject to confidentiality obligations. Evermark shall not sell personal data.

8.DATA SECURITY MEASURES

Evermark shall implement appropriate technical and organizational measures including encrypted data transmission, secure servers, restricted access controls, periodic security

assessments, and staff confidentiality obligations to safeguard personal data.

9.DATA RETENTION

Personal data shall be retained only for as long as necessary to fulfill the purposes for which it was collected or as required by law. Upon expiration of the retention period, data

shall be securely deleted, destroyed, or anonymized.

10.RIGHTS OF DATA SUBJECTS

Subject to applicable law, data subjects have the right to access their personal data; request correction of inaccurate data; request erasure where legally permissible; object to

certain processing activities; and withdraw consent where processing is based on consent. Requests shall be submitted through official Company communication channels.

11.CROSS-BORDERTRANSFERS

Where personal data is transferred outside the United Republic of Tanzania, Evermark shall ensure that adequate safeguards are implemented in accordance with applicable data protection laws.

12.CHILDREN’S DATA

The Evermark platform is notintended for persons under the age ofeighteen (18) years. The Company does not knowingly collect personal data from minors.

13.POLICY REVIEW AND AMENDMENTS

This Policy may be reviewed and amended periodically to ensure compliance with evolving legal and regulatory requirements. Updated versions shall be published on the Company’s website.