Privacy Policy

1. Introduction

Excellara Strategic Solutions Limited ("Excellara", "we", "us" or "our") is committed to protecting the privacy, confidentiality and security of personal information entrusted to us.

Excellara is incorporated in Nigeria (RC 9681346) and operates with an international outlook, connecting talent, enterprise, expertise, institutions, partners and investment opportunities across markets, including between the Global South and Global North.

Given the international nature of our activities, personal data may be collected from or processed in relation to individuals located in different jurisdictions. We therefore process personal data responsibly and in accordance with applicable data protection and privacy legislation.

This includes the Nigeria Data Protection Act 2023 (NDPA) and, where applicable to particular processing activities, the European Union General Data Protection Regulation (GDPR), the Swiss Federal Act on Data Protection (FADP), and other applicable data protection requirements in jurisdictions in which we operate.

This Privacy Policy explains what personal data we collect, why we collect it, how we use and protect it, when it may be shared or transferred internationally, and the rights individuals have in relation to their personal data.

2. Scope of This Policy

This Policy applies to personal data collected through:

• the Excellara website;
• talent, employment and workforce enquiries;
• CV, résumé and professional profile submissions;
• contact and enquiry forms;
• business and partnership enquiries;
• client and prospective client interactions;
• professional networking and business development activities;
• events, programmes and meetings;
• mailing lists and communications;
• suppliers, consultants and service providers.

Separate privacy information may be provided where a particular service or activity requires more specific information.

3. Personal Data We Collect

Depending on the nature of an individual's interaction with Excellara, we may collect information including:

Identity and Contact Information Name, title, organisation, job title, email address, telephone number, country or location and other contact information.

Professional and Talent Information CVs or résumés, employment history, educational background, professional qualifications, skills, experience, career interests, languages, professional references, LinkedIn or other professional profiles and information voluntarily provided in connection with employment or professional opportunities.

Business and Partnership Information Information provided by clients, prospective clients, institutional partners, investors, enterprises, consultants, suppliers and other professional contacts.

Communications Information contained in correspondence, enquiries, meeting requests, emails or other communications with Excellara.

Website and Technical Information Our website does not use cookies, analytics or tracking technologies, and does not store any information you enter. When you use the contact form, your message is composed in your own email application and sent to us as an ordinary email — the website itself neither stores nor transmits it. Our hosting provider keeps standard server logs (such as IP address and browser type) for security and operational purposes. Fonts and images are served from our own website, so loading a page does not disclose your details to any third-party content network.

We collect only personal data that is reasonably necessary for the relevant purpose.

4. How We Collect Personal Data

We may obtain personal data:

• directly from individuals;
• through our website's contact options;
• through CV or professional profile submissions sent to us by email;
• through business enquiries and correspondence;
• through clients, partners or professional contacts;
• through publicly available professional sources;
• through events, conferences and networking activities;
• through recruitment or professional platforms.

Where personal data is provided to us concerning another individual, the person providing the information should have appropriate authority or another lawful basis for doing so.

5. How We Use Personal Data

We may process personal data for purposes including:

• responding to enquiries;
• providing our services;
• identifying and assessing talent;
• connecting qualified individuals with potential employment, professional or

project opportunities;

• managing candidate and professional relationships;
• providing workforce and talent solutions to clients;
• facilitating introductions and professional connections;
• developing business and institutional partnerships;
• assessing potential business and investment opportunities;
• managing contracts and commercial relationships;
• communicating about relevant Excellara services, opportunities or activities;
• maintaining security and preventing misuse;
• meeting legal, regulatory, accounting and governance obligations;
• establishing, exercising or defending legal rights;
• improving our services and operations.

We will not use personal data for purposes that are materially incompatible with the purpose for which it was originally collected unless permitted by applicable law.

6. Legal Bases for Processing

Where required by applicable law, Excellara will process personal data on an appropriate legal basis. Depending on the circumstances, this may include:

• the individual's consent;
• taking steps at an individual's request before entering into a contract;
• performing a contract;
• complying with a legal obligation;
• protecting legitimate interests pursued by Excellara or another party, provided

those interests are not overridden by the rights and freedoms of the individual; or

• another lawful basis permitted under applicable legislation.

Where we rely on consent, individuals may withdraw that consent, subject to applicable law. Withdrawal of consent does not affect the lawfulness of processing undertaken before consent was withdrawn.

7. Talent, CV and Professional Information

Given Excellara's talent and workforce activities, we recognise that CVs and professional profiles may contain substantial personal information.

CVs and professional profiles are sent to us by email and are held in our business email system. Information submitted for talent or professional opportunities may be used to:

• assess an individual's skills, experience and suitability;
• identify relevant employment, consultancy, project, internship or other

professional opportunities;

• contact the individual regarding potential opportunities;
• maintain an appropriate record of professional contacts; and
• introduce or share an individual's profile with prospective employers, clients

or partners where there is an appropriate lawful basis for doing so.

Excellara will seek consent or otherwise ensure that an appropriate legal basis exists before disclosing identifiable candidate information to third parties.

Submitting a CV to Excellara does not guarantee employment, placement, an interview or any particular professional opportunity.

8. Sharing Personal Data

We may share personal data where reasonably necessary with:

• Excellara personnel and authorised representatives;
• clients and prospective clients;
• employers or organisations considering talent;
• professional and institutional partners;
• consultants and advisers;
• our website hosting and business email providers;
• professional advisers such as lawyers, accountants or auditors;
• regulatory, governmental, judicial or law-enforcement authorities where legally

required.

We do not sell personal data to third parties.

Where third-party service providers process personal data on our behalf, we ensure appropriate contractual, confidentiality and data-protection arrangements are in place.

9. International Transfers

Because Excellara operates internationally, personal data may be accessed, stored, processed or transferred across national borders. Our website hosting and business email providers operate internationally, and personal data may therefore be processed outside Nigeria.

Where personal data is transferred internationally, Excellara ensures that the transfer is undertaken in accordance with applicable data protection legislation and that appropriate safeguards are used where required.

Depending on the applicable jurisdiction and circumstances, these safeguards may include adequacy decisions, contractual protections, standard contractual clauses, consent where legally appropriate, or another legally recognised transfer mechanism.

10. Data Security

Excellara takes reasonable and appropriate organisational and technical measures to protect personal data against unauthorised access, accidental loss, misuse, alteration, unauthorised disclosure and destruction.

Our website is served over encrypted connections (HTTPS). Access to personal information is limited to individuals who require it for legitimate business or operational purposes.

No internet-based system is completely secure, and Excellara cannot guarantee absolute security. However, we take reasonable measures appropriate to the nature of the personal data and the risks associated with its processing.

11. Data Retention

We retain personal data only for as long as reasonably necessary for the purpose for which it was collected, or as required by applicable legal, regulatory, contractual or legitimate business requirements. Retention periods vary depending on the nature of the information.

For talent and candidate information, Excellara periodically reviews whether continued retention is appropriate. Individuals may contact us to request deletion of their information, subject to applicable legal requirements and legitimate retention needs.

12. Cookies and Website Technologies

The Excellara website does not currently use cookies, analytics or similar tracking technologies.

If this changes, this Policy will be updated first, and where required by applicable law non-essential cookies or tracking technologies will be used only after appropriate consent has been obtained.

13. Marketing and Communications

Where permitted by applicable law, Excellara may communicate with individuals regarding relevant services, opportunities, programmes, events or developments.

Where consent is required for such communications, we will seek appropriate consent. Recipients may unsubscribe from marketing communications or request that they no longer receive them at any time.

14. Individual Rights

Depending on the applicable data protection law and circumstances, individuals may have rights concerning their personal data, including the right to:

• request information about how their data is processed;
• obtain access to their personal data;
• request correction of inaccurate or incomplete information;
• request deletion of personal data;
• request restriction of processing;
• object to certain processing;
• withdraw consent where processing is based on consent;
• request portability of personal data where applicable; and
• lodge a complaint with an appropriate data protection authority.

In Nigeria, complaints may be made to the Nigeria Data Protection Commission (NDPC). Individuals in other jurisdictions may have the right to complain to their local supervisory authority.

These rights are not absolute and may be subject to legal limitations or exemptions. Excellara will respond to valid requests in accordance with applicable law.

15. Children's Personal Data

Excellara's commercial and professional services are not directed towards children. We do not knowingly collect children's personal data through our corporate website.

16. Third-Party Websites and Platforms

Our website may contain links to websites, platforms or services operated by third parties. Excellara is not responsible for the privacy practices of independent third parties. Individuals should review the privacy information provided by those organisations before submitting personal data to them.

17. Data Protection Governance

Excellara recognises data protection as part of responsible corporate governance.

As the company grows, we will periodically review our data protection practices, service providers, international data flows, security arrangements, retention practices and internal procedures.

Where required by applicable legislation, Excellara will appoint or designate appropriate data-protection representatives, officers or contacts.

18. Data Breaches

Where Excellara becomes aware of a personal data breach, we will assess the nature and potential impact of the breach and take appropriate measures to contain and address it.

Where notification to affected individuals or a relevant data protection authority is required by applicable law, Excellara will make the required notification within the applicable statutory timeframe.

19. Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect changes in our activities, technology, services, legal obligations or data protection practices. The latest version will be published on our website together with its effective date.

20. Contacting Excellara

Questions, requests or concerns concerning this Privacy Policy or Excellara's handling of personal data may be directed to:

Excellara Strategic Solutions Limited (RC 9681346) Nigeria

Data Protection / Privacy Contact: info@excellarasolutions.com

Website: excellarasolutions.com

Additional contact or representative information may be provided where required under applicable law.