Introduction.

BOLDSCALE TECHNOLOGIES LTD. and BOLDSCALE TECHNOLOGIES INC. (“BOLDSCALE”, "us", "we", or "our") prioritize and protect the privacy of people who use Bonndle (“Bonndle”, “the Platform”), our group buying and cashback rewards platform, and the related websites and services we operate (“Services”). This Privacy Policy explains how we collect, use, disclose and safeguard your information when you visit or use Bonndle. Please read it carefully.

IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY, PLEASE DO NOT ACCESS OR USE OUR SERVICES.

We may change this Privacy Policy from time to time. We will tell you about material changes through the app, our website or the contact details you have given us, and we will update the “Last Updated” date above. Your continued use of the Services after a change means you accept the updated Privacy Policy.

The information we collect and why.

What we collect depends on the Services you use and how you use them.

Account information

When you sign up we collect information such as your name, email address, phone number, date of birth, country and the BoldTag (username) you choose, along with a payment PIN that we store in protected form. We use this to create and secure your account, let other members find and invite you, and communicate with you.

Identity verification information

To comply with know-your-customer (KYC) and anti-money-laundering obligations, and to make sure accounts belong to real people, we or our verification partners may collect identity details such as a government-issued ID number, a photo of your ID and a selfie. See our AML Policy for more.

Group and activity information

We record the groups you create, join or are invited to, your role in each group, invitations you send or accept, and the deals you engage with. This is what makes group buying work: it lets a group unlock deals together and lets us show members the activity of the groups they belong to.

Cashback and transaction information

When you generate a cashback code and use it with a partner merchant, we receive details of that transaction from the merchant, such as the merchant, the amount spent, the cashback earned, the date and a transaction reference. We use this to calculate, confirm and pay your rewards, and to prevent fraud. We do not receive the list of items you bought unless the merchant includes it in the transaction details.

Financial information

To pay out rewards or process payments we may need payout details such as your bank account or wallet information. Card and bank details are handled by our licensed payment partners; we do not store full card numbers. We encourage you to read our payment partners’ privacy policies.

Device and usage information

When you use the Services our servers collect information such as your IP address (to estimate your general location), browser and device type, operating system, app version and how you use features. This helps us keep the Services secure, fix problems and improve performance across devices.

Push notifications

With your permission we send push notifications about your account, group invitations, deals and rewards. You can turn them off at any time in your device settings.

Support communications

When you contact support we keep your messages and our replies so we can resolve your request and improve our service.

How we use your information.

We may use the information we collect to:

• Create and manage your account and verify your identity.
• Let you create, join and manage groups, and invite other members.
• Show you deals from partner merchants and generate your cashback codes.
• Confirm qualifying purchases with merchants and calculate, credit and pay out your cashback and rewards.
• Process payments, payouts, reversals and refunds.
• Send you service messages about your account, groups, deals and rewards.
• Send you deals, newsletters and promotions that match the preferences you set, where you have agreed to receive them.
• Detect, prevent and investigate fraud, abuse of the rewards program, money laundering and other illegal activity.
• Respond to support requests, resolve disputes and troubleshoot problems.
• Analyse usage and compile anonymous, aggregated statistics to improve the Services.
• Comply with our legal and regulatory obligations.

Disclosure of your information.

We do not sell your personal information. We share it only as described below.

Other members of your groups

Members of a group you belong to or are invited to can see your name, BoldTag, profile photo and your membership of that group. Group activity, such as a deal being unlocked or rewards being paid, may be visible to other members of the same group.

Partner merchants

To confirm a cashback transaction we share with the merchant only what is needed, such as the cashback code and the deal it belongs to. Merchants do not receive your contact details from us unless you ask us to share them.

Service providers

We share information with companies that provide services on our behalf, including identity verification, payment processing and payouts, cloud hosting, data analysis, email and messaging delivery, and customer support. They may use your information only to provide those services to us.

Legal requirements and protection of rights

We may disclose information where we believe it is required by law, regulation or legal process, to respond to lawful requests from authorities, to investigate or prevent fraud or violations of our terms and policies, or to protect the rights, property and safety of our users, BOLDSCALE or others. This includes reporting suspicious activity as described in our AML Policy.

Business transfers

If we sell all or part of our business, merge with or are acquired by another company, your information may be transferred to the successor, which will be bound to handle it in line with this Privacy Policy.

With your consent

We may share your information for other purposes when you ask us to or give us your consent.

Third-party websites.

The Services may contain links to merchant websites and other third-party sites and apps that we do not operate. Once you leave the Services, any information you give those third parties is governed by their own privacy policies, not this one. We are not responsible for their content or privacy practices.

Storing and securing your information.

We store information with reputable cloud infrastructure providers and use administrative, technical and physical safeguards to protect it:

• Administratively, only employees and partners who need access to personal information to do their job can access it.
• Technically, data is encrypted in transit and at rest, and sensitive details such as your payment PIN are stored in protected form.
• Physically, our hosting providers restrict data centre access to authorised personnel.

No security measure is perfect, and no method of transmitting data over the internet can be guaranteed to be completely secure. If a security breach affects your personal information, we will notify you and the relevant authorities as required by law.

How long we keep your information.

We keep your information for as long as your account is active and as needed to provide the Services. After you close your account we may keep some information, such as transaction, verification and rewards records, for as long as needed to comply with legal, tax, audit and anti-money-laundering requirements, resolve disputes and prevent fraud.

Your rights and choices.

Subject to applicable data protection law, including the Nigeria Data Protection Act 2023, you may have the right to access the personal information we hold about you, correct it, ask us to delete it, object to or restrict certain uses, withdraw consent you have given, and receive a copy of your information. You can also lodge a complaint with the Nigeria Data Protection Commission or another relevant authority.

Account information

You can review and update your account information in the app at any time, or contact us to close your account. When you close your account we will deactivate or delete it from our active databases, except for information we must keep as described above.

Emails and notifications

You can unsubscribe from marketing emails using the link in each email, change your preferences in the app, or contact us. You can turn off push notifications in your device settings. We may still send you service messages about your account, groups and rewards.

Children.

Bonndle is not intended for anyone under 18, and we do not knowingly collect personal information from children. If you believe a child has given us personal information, please contact us and we will delete it.

Contact us.

If you have any questions about this Privacy Policy or want to exercise your rights, please contact us at support@bonndle.com.

Effective date.

October 26, 2026

These terms govern Bonndle’s cashback rewards program (“the rewards program”, “the program”), developed and operated by BOLDSCALE TECHNOLOGIES INC. and BOLDSCALE TECHNOLOGIES LTD. (“BOLDSCALE”, “the company”, “we”, “us”, “our”). By using Bonndle (“Bonndle”, “the platform”, “the app”) and taking part in the program, you agree to these terms, as well as our Terms of Use and Privacy Policy.

IF YOU DO NOT AGREE TO THESE TERMS, DO NOT USE THE PLATFORM.

1. How cashback works.

Bonndle lets people buy together. When you join or create a group, your group can unlock deals from our partner merchants, and members earn cashback on qualifying purchases:

• Deals: Each deal is offered by a partner merchant and shows its cashback rate (a percentage of the qualifying purchase), any minimum purchase amount, any maximum cashback or purchase amount, and the dates it is valid. Some deals also award Bonndle reward points.
• Cashback codes: To earn cashback you generate a cashback code for a deal in your group and use it when you pay the merchant, in-store or online, as the deal describes. Each code is unique to you, the group and the deal.
• Qualifying purchases: A purchase qualifies when it is made with a valid code, within the deal’s dates, meets the deal’s minimum amount and is confirmed by the merchant. Cashback is calculated on the confirmed purchase amount, up to any limit shown on the deal.
• Group rewards: Depending on the deal, cashback may be credited to the member who made the purchase, shared among eligible members of the group, or both. How a deal’s cashback is shared is shown on the deal in the app.

2. Tracking your cashback.

You can follow each cashback code in the app:

• Generated — the code has been created and is ready to use.
• Applied — the merchant has confirmed a purchase made with the code. The cashback is pending while we review it.
• Rewarded — the cashback has been credited.
• Expired — the code was not used before the deal ended or the code expired, and it can no longer earn cashback.

Cashback is credited after the merchant confirms the purchase and we complete our checks. This can take time, and we will tell you in the app if anything delays it.

3. Who funds rewards.

Cashback and reward points are funded through the commercial arrangements we agree with our partner merchants. The rewards program is operated by BOLDSCALE, not by the merchants, who may run separate loyalty programs of their own. Merchants are responsible for the goods and services they sell; questions about a purchase itself should go to the merchant.

4. Using your rewards.

Credited cashback and reward points can be used as described in the app, which may include withdrawing to your bank account or wallet, using them for purchases on the platform, or sending them to other registered users. Any minimum amounts, fees, limits or verification requirements are shown in the app before you confirm. Withdrawals may require you to complete identity verification.

5. Reversals and adjustments.

We may withhold, reverse or adjust cashback or reward points if a purchase is cancelled, returned or refunded, if the merchant does not confirm it, if it does not meet the deal’s conditions, if it was credited in error, or if we detect fraud or abuse. Where we reverse a reward we will tell you why.

6. Validity.

Credited cashback and reward points do not expire while your account is active. Unused cashback codes expire as shown on each deal. We may cancel rewards on an account that has been inactive for a long period, or where suspicious activity is detected, after notifying you where we are able to.

7. Fraud detection and prevention.

We combine automated and human review to monitor the lifecycle of every cashback code and reward, to protect the integrity of the program for all members and our partners. Examples of prohibited behaviour include creating multiple or fake accounts, sharing or selling cashback codes, fake or self-dealing transactions, and colluding to unlock deals artificially. Any attempt at manipulation or fraud may result in rewards being cancelled, the account being suspended or closed, and reports to the relevant authorities in line with our AML Policy.

8. Your responsibilities.

• Keep your account, payment PIN and cashback codes secure, and do not share them.
• Make sure the details you give us, including payout details, are accurate.
• Report any suspicious activity on your account to us straight away through the in-app support channels or at support@bonndle.com.
• You are responsible for any taxes that may apply to rewards you receive.

9. Privacy and data security.

We place the utmost priority on protecting your privacy and data. To run the rewards program we receive purchase confirmations from merchants and share only what is needed to confirm your cashback. Learn more in our Privacy Policy.

10. Communications.

Important information, updates and promotions related to the rewards program will be sent through the app, email and other channels you have agreed to, to keep you informed.

11. Changes to the program.

We may change, suspend or end the rewards program, or change these terms. We will give you advance notice of significant changes, and rewards already credited to your account will be honoured in line with these terms.

12. Customer support.

For help or questions about the rewards program, contact us through the in-app support channels or at support@bonndle.com.

Effective date.

October 26, 2026

1. Purpose

BOLDSCALE TECHNOLOGIES INC. & BOLDSCALE TECHNOLOGIES LTD. (“BOLDSCALE”, “The Company”, “We”, “Us”, “Our”) has defined this AML Policy to help prevent the use of Bonndle Super App (“Bonndle”, “The Platform”) for money laundering or terrorist financing activities. This policy outlines the measures and procedures in place to detect, prevent, and report suspicious activities.

2. Scope

To ensure compliance with applicable laws and regulations the AML Program includes the following components:

• Customer Identification Program (CIP): We will verify the identity of all users who open an account or engage in transactions. The CIP will include procedures for verifying the identity of individuals, entities, and beneficial owners.
• Risk Assessment: Risks assessments will be conducted on users and transactions to identify and mitigate potential money laundering and terrorist financing risks.
• Monitoring and Reporting: User activity will be monitored for suspicious transactions and where needed reported to the appropriate authorities.
• Training and Education: We will provide training and education to our employees and contractors on AML regulations and procedures.

3. Customer Identification Program (CIP)

The CIP will include the following procedures:

• Verification of identity: We will work with our partners to verify the identity of all users who open an account on Bonndle. This will include collecting identifying information such as name, date of birth, and government-issued identification number.
• Risk-based approach: A risk-based approach will be taken to the CIP, applying enhanced due diligence measures for higher risk users and transactions.

4. Risk Assessment

Activities to identify, prevent and address risks will include:

• Assessing the risk profile of each user based on factors such as geographic location and transaction activity.
• Identifying high-risk users and transactions and applying enhanced due diligence measures.
• Regularly reviewing and updating the risk assessment to reflect changes in the user base and transaction activity.

5. Monitoring and Reporting

This will include:

• Implementing automated monitoring systems to detect suspicious transactions.
• Investigating and reporting suspicious transactions to the appropriate authorities.
• Maintaining records of all suspicious activity reports and related documentation.

6. Training & Education

Training activities will include:

• Providing training on AML regulations and procedures.
• Providing training on identifying and reporting suspicious activity.
• Regularly updating and reviewing the training program to ensure it remains current and effective.

7. Contact Information

For further information and enquiries contact us at team@boldscale.io.

Signed
Austin Nwokediuko (CEO)