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Nabo Capital Limited

Data Protection Policy

Introduction

Nabo Capital Limited (“Nabo”) is committed to promoting good corporate governance by adhering to all national and international laws that are applicable to it. Nabo’s Data Protection Policy (“Policy”) is intended to facilitate the protection of personal data by complying with the Data Protection Act 2019 (“DPA”) and its Regulations.

The DPA seeks to protect the privacy of individuals by ensuring the responsible processing of personal data. It was enacted to give effect to Article 31(c) and (d) of the Constitution. It establishes the Office of the Data Protection Commissioner (“ODPC”), provides for the rights of data subjects and stipulates the obligations of both data controllers and processors.

Nabo reiterates its commitment to protecting the rights and freedoms of data subjects and to the secure processing of their data.

Purpose

This Policy provides guidance on how Nabo shall handle the data it collects. It is designed to aid Nabo in complying with not just the DPA but also relevant international laws such as the General Data Protection Regulations (“GDPR”) of the European Union.

Scope

This Policy applies to all prospective, current and former employees, partners, vendors, contractors, board members, interns, and any third parties who handle and use Nabo’s information.

It also applies to all formats (printed, digital, text, images, documents, audio, etc.). Nabo processes personal data for financial, HR, payroll, regulatory, customer service, and other purposes such as providing investment products, processing applications, customer surveys, research, investigations, and meeting contractual obligations.

Data Protection Officer

Nabo has designated its Legal and Compliance Officer as the Data Protection Officer (DPO). The DPO will advise on data processing requirements, ensure compliance with laws, provide training, advise on impact assessments, and liaise with the ODPC.

Contact: b.otieno@nabocapital.com

Privacy Complaints or Breaches

If you wish to lodge a complaint about a possible breach of privacy or have any query on how personal data is collected or handled, please contact:

Data Protection Officer
Nabo Capital Limited
P.O. Box 10518 – 00100
Nairobi
Email: b.otieno@nabocapital.com


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© 2025 Nabo Capital Limited. All rights reserved.

Nabo Capital Limited is regulated by the Capital Markets Authority. CMA does not take responsibility for the financial soundness of the scheme or for the correctness of any statements made or opinions expressed. Income from investments may increase or decrease. The effective annual yield is net of fees and gross of withholding tax. Past performance does not guarantee future results. In certain circumstances, investors right to redeem investments may be suspended.