Last Updated: 16th January, 2026

This Privacy Policy ("Policy") sets out in detail how Kendee Dreams Resources Ltd. ("Kendee", "Company", "we", "us", or "our") lawfully collects, uses, processes, stores, transfers, and safeguards personal data when individuals ("users", "you", or "your") access or use the Kendee website, mobile applications, dashboards, and any related digital services, tools, or communications (collectively, the "Platform").

This Policy is drafted to ensure compliance with applicable data protection and privacy laws, including the Nigeria Data Protection Act (NDPA) 2023, and is structured to protect Kendee’s legal, operational, and regulatory interests while providing transparency to users.

By accessing, registering on, or using the Platform, you acknowledge that you have read, understood, and agreed to the terms of this Policy. If you do not agree, you must discontinue use of the Platform.

1. Definitions and Interpretation

For the purposes of this Policy:

"Personal Data" means any information that identifies or can reasonably be used to identify an individual, directly or indirectly.

"Processing" means any operation performed on Personal Data, including collection, recording, storage, use, disclosure, transmission, or deletion.

"Platform" refers to all Kendee-operated digital products, websites, applications, APIs, and communication channels.

"Third Party" means any entity other than Kendee and the user.

Headings are for convenience only and do not affect interpretation.

2. Scope and Applicability

This Policy applies to all Personal Data processed by Kendee in connection with the Platform, whether collected directly from users, automatically through technology, or obtained from third parties in connection with compliance, payments, or service delivery.

This Policy does not apply to anonymized or aggregated data that cannot reasonably be used to identify an individual.

3. Categories of Personal Data Collected

Kendee limits data collection to what is necessary, proportionate, and lawful.

3.1 Personal and Contact Information

Includes full legal name, email address, telephone number, username, and other contact details provided during registration or communication with Kendee.

3.2 Identity, Verification, and Compliance Data

Where required by law or internal risk controls, Kendee may collect KYC/AML information, including government-issued identification, proof of address, biometric or facial verification data, and compliance verification results obtained from authorized third-party providers.

3.3 Financial and Transactional Data

Includes records of platform participation, contributions, withdrawals, milestone activity, account balances, transaction references, and related financial metadata. Payment credentials are processed by licensed third-party payment processors and are not stored by Kendee except where required for reconciliation, compliance, or dispute resolution.

3.4 Technical, Usage, and Log Data

Includes IP address, device identifiers, browser type, operating system, access logs, timestamps, cookies, session data, and interaction history used for analytics, security, and platform optimization.

3.5 Communications Data

Includes emails, support tickets, chat messages, call records, and any other communications between you and Kendee.

4. Sources of Personal Data

• You directly, through account registration and platform use
• Automated technologies and tracking tools
• Third-party service providers (e.g., compliance, payment, analytics)
• Public or regulatory sources, where legally permitted

5. Purposes for Processing Personal Data

• User registration, authentication, and account administration
• Facilitating platform transactions and operational workflows
• Managing funding cycles, milestones, dashboards, and reporting
• Processing payments, reconciliations, and audit trails
• Identity verification, fraud detection, and risk management
• Legal, regulatory, and compliance obligations
• Customer support, dispute resolution, and enforcement of agreements
• Internal analytics, system improvement, and security monitoring
• Business continuity, record-keeping, and corporate governance

Personal Data will not be processed in a manner incompatible with these purposes.

6. Legal Bases for Processing

Kendee relies on one or more lawful bases under applicable law, including:

• Contractual Necessity: Processing required to perform obligations under the Terms of Service.
• Legal Obligation: Processing required to comply with applicable laws, regulations, and lawful authority requests.
• Legitimate Interests: Processing necessary for platform security, fraud prevention, service improvement, and protection of legal rights, provided such interests do not override user rights.
• Consent: Where explicitly obtained, which may be withdrawn subject to legal and contractual limitations.

7. Automated Decision-Making and Profiling

Kendee may use automated systems for fraud detection, compliance screening, risk scoring, or system optimization. Such processing does not produce legal or similarly significant effects on users without appropriate safeguards or human oversight, where required by law.

8. Data Sharing and Disclosure

Kendee does not sell or rent Personal Data. Disclosure occurs only where necessary and lawful, including to:

• Licensed banks, payment processors, and financial institutions
• Compliance, KYC, AML, and fraud-prevention service providers
• Cloud hosting, analytics, and infrastructure providers
• Professional advisers, auditors, insurers, and legal counsel
• Regulatory authorities, courts, or law enforcement agencies

All Third Parties are subject to confidentiality, security, and data protection obligations.

9. Cross-Border Data Transfers

Where Personal Data is transferred outside Nigeria, Kendee ensures appropriate safeguards are in place, including contractual clauses, regulatory approvals, or other lawful transfer mechanisms.

10. Data Security Safeguards

Kendee implements commercially reasonable technical, administrative, and organizational measures to protect Personal Data, including encryption, access controls, monitoring, and secure infrastructure.

However, no system is completely secure. Kendee does not warrant or guarantee absolute security of Personal Data.

11. Data Retention and Deletion

Personal Data is retained only for as long as necessary to:

• Fulfil the purposes outlined in this Policy
• Comply with legal, regulatory, accounting, and audit obligations
• Resolve disputes and enforce agreements

Retention periods vary by data type. Data may be retained beyond account closure where legally required.

12. User Rights

Subject to applicable law, users may request access, correction, restriction, or deletion of Personal Data, or object to certain processing activities.

Kendee reserves the right to refuse or limit requests where permitted by law, including where compliance would impair legal obligations, security, or legitimate business interests.

13. Cookies and Similar Technologies

Kendee uses cookies and similar technologies to enable core functionality, analyze usage, and improve services. Disabling cookies may affect Platform performance or features.

14. Third-Party Platforms

The Platform may contain links to Third-Party websites or services. Kendee is not responsible for their content, security, or privacy practices. Access is at your own risk.

15. Children’s Data

The Platform is not intended for individuals under the age of 18. Kendee does not knowingly collect Personal Data from minors.

16. Business Transfers

In the event of a merger, acquisition, restructuring, or sale of assets, Personal Data may be transferred as part of the transaction, subject to applicable data protection laws.

17. Limitation of Liability

To the maximum extent permitted by law, Kendee shall not be liable for indirect, incidental, consequential, or punitive damages arising from data processing or security incidents beyond its reasonable control.

18. Policy Updates

Kendee may amend this Policy at any time. Updates take effect upon publication. Continued use of the Platform constitutes acceptance of the revised Policy.

19. Governing Law

This Policy shall be governed by and construed in accordance with the laws of the Federal Republic of Nigeria.

20. Contact Information

For privacy-related inquiries or requests:

Kendee Support

Email: support@kendee.co