Empowering
Agri-Finance
at Scale

This policy applies to all employees, contractors, consultants, officers, and platform users who access portfolio company data within the Nala Capital Partners platform. All users are bound by these obligations regardless of their role or access level.

The platform collects and processes personal information including but not limited to: farmer identity data (name, ID number, contact details), financial information (income, assets, liabilities), farm and enterprise data, GPS coordinates, photographs, and assessment scores. This information is used solely for investment readiness assessment and portfolio management purposes.

Non-public information includes any data about a portfolio company or farmer that has not been publicly disclosed and that could affect investment decisions. This includes financial reports, business strategies, assessment results, and compliance records. All such information must be treated as strictly confidential.

All platform users must:

• Maintain strict confidentiality of all personal information accessed
• Process personal information only for its intended purpose
• Not share, export, or disclose data to unauthorised third parties
• Return or delete data at the end of their engagement
• Report any suspected data breach immediately to the data protection officer

Access to personal information is restricted to individuals who require it to perform their job responsibilities. Role-based access controls are enforced within the platform. Sharing login credentials is strictly prohibited.

Farmers and other data subjects have the right to access, correct, and request deletion of their personal information. Requests should be directed to the Fund's data protection officer. The Fund will respond within 30 days of receiving a valid request.

Any suspected or actual breach of this policy must be reported immediately to your supervisor and the legal department. Failure to report a breach may result in disciplinary action and/or legal liability.