How we handle personal information.

1. Introduction

Marula Oak Limited ("Marula Oak", "Marula House", "Marula", "we", "our" or "us") respects your privacy and is committed to protecting the personal information entrusted to us.

This Privacy Policy explains how we collect, use, store, disclose and protect personal information when you visit our website, communicate with us, submit an enquiry through our Begin the Conversation form, or otherwise interact with Marula Oak.

As a family office serving founders, enterprise families and succeeding generations, confidentiality and discretion are fundamental to how we operate. Personal information provided to us will be handled carefully, lawfully and only for legitimate purposes connected with your enquiry, our relationship with you, or our legal and regulatory obligations.

This Privacy Policy is intended to comply with the Nigeria Data Protection Act 2023 ("NDP Act") and other applicable data protection and privacy requirements.

2. Who We Are

Marula Oak Limited is a private family office providing advisory and family-office services, including strategic advice, fiduciary services, investment advisory, and financial and personal administration.

For the purposes of applicable data protection legislation, Marula Oak Limited is the data controller in respect of personal information collected through our website and directly through our interactions with you.

Questions concerning this Privacy Policy or our processing of personal information may be sent to:
Email: info@marulaoak.com
Website: marulaoak.com

3. Information We Collect

The personal information we collect depends upon how you interact with us.

a. Information You Provide Through Our Website

When you use the Begin the Conversation form, we may collect:

• your first and last name;
• email address;
• telephone number;
• country;
• state or region;
• your selected investable-assets range; and
• any information you voluntarily provide in the additional-comments section.

You should avoid providing sensitive personal information in the comments section unless it is reasonably necessary for your enquiry.

b. Information You Provide During Subsequent Communications

If you proceed to communicate or engage with Marula Oak following an initial enquiry, we may receive additional information from you concerning your family, enterprise, assets, professional advisers, financial affairs, succession objectives or other circumstances relevant to the services you ask us to consider.

Where such information concerns another person, you should ensure that you are authorised to provide it to us where required by applicable law.

Any more extensive collection and processing of information arising from a formal client engagement may also be governed by the relevant engagement documentation, contractual terms and any additional privacy notices provided to you.

c. Technical Information

When you access our website, limited technical information may be generated automatically by your browser, hosting provider or other technical infrastructure, such as your IP address, browser type, device information, date and time of access, and information required to maintain the security and operation of the website.

Please see our Cookie Policy for further information about cookies and similar technologies.

4. How We Use Your Information

We may use personal information to:

1. receive, review and respond to enquiries;
2. arrange an introductory or private consultation with you;
3. understand the nature of your family, enterprise or family-office requirements;
4. assess whether Marula Oak's services are appropriate for your circumstances;
5. communicate with you regarding an existing or prospective engagement;
6. provide services you have requested where an engagement is established;
7. coordinate with professional advisers or service providers where you have authorised us to do so;
8. administer and secure our website and information systems;
9. maintain appropriate internal business and compliance records;
10. prevent fraud, misuse or unlawful activity;
11. comply with applicable legal, regulatory, tax, compliance or reporting obligations; and
12. establish, exercise or defend legal rights where necessary.

Information submitted through the Begin the Conversation form will not be used for unrelated marketing or referral purposes without an appropriate lawful basis.

5. Lawful Basis for Processing

Depending upon the circumstances, we process personal information on one or more of the following lawful bases:

• Consent: where you have voluntarily provided information or expressly agreed to a particular form of processing and consent is the appropriate lawful basis.
• Steps Prior to or Performance of a Contract: where processing is necessary to respond to a request made by you before entering into an engagement or to perform services under an existing engagement.
• Legitimate Interests: where processing is reasonably necessary for our legitimate business interests, including responding to enquiries, maintaining client and professional relationships, securing our systems and administering our operations, provided that those interests do not override your fundamental rights and freedoms.
• Legal Obligation: where we are required to process or retain information to comply with applicable law, regulation, court orders or lawful requests from regulatory or governmental authorities.

Where processing is based upon consent, you may withdraw that consent at any time. Withdrawal does not affect processing lawfully undertaken before consent was withdrawn.

6. Confidentiality and Disclosure of Information

Marula Oak recognises that information relating to families, their enterprises and their financial affairs may be particularly private. We therefore treat information entrusted to us as confidential.

We do not sell personal information.

We may disclose personal information only where reasonably necessary to:

• employees, officers or authorised representatives of Marula Oak who require access to perform their responsibilities;
• technology, website-hosting, data-storage, communication or other service providers acting on our behalf;
• lawyers, accountants, tax advisers, investment professionals or other professional advisers where required for an engagement and appropriately authorised;
• banks, custodians, trustees or other institutions where necessary to provide an agreed service;
• regulators, courts, law-enforcement bodies or other authorities where disclosure is legally required; or
• a successor or relevant party in connection with a restructuring, merger, acquisition or transfer of the business, subject to appropriate confidentiality and data-protection safeguards.

Our service providers are expected to process personal information only for the purposes for which it has been disclosed and subject to appropriate confidentiality and security obligations.

7. International Transfers

Some technology providers or professional service providers we use may process or store information outside Nigeria.

Where personal information is transferred internationally, Marula Oak will take reasonable steps to ensure that the transfer is made in accordance with applicable data-protection requirements and that appropriate safeguards are in place.

8. How We Protect Your Information

We take reasonable technical and organisational measures designed to protect personal information against unauthorised access, disclosure, alteration, loss, destruction or misuse.

These measures may include access controls, confidentiality requirements, secure technology infrastructure, appropriate information-handling procedures and restrictions on access to personal information based on business need.

No method of electronic transmission or storage is completely secure. We therefore cannot guarantee absolute security, but we will maintain safeguards proportionate to the nature and sensitivity of the information we process.

9. How Long We Keep Your Information

We retain personal information only for as long as reasonably necessary for the purpose for which it was collected and to meet applicable legal, regulatory, accounting or reporting obligations.

Information relating to an initial enquiry that does not result in an engagement will not be retained indefinitely and will be periodically reviewed for deletion or anonymisation when it is no longer reasonably required.

Where an engagement is established, relevant information may be retained for the duration of the relationship and for an appropriate period afterwards where required for legal, regulatory, compliance, record-keeping or legitimate business purposes.

10. Your Data Protection Rights

Subject to applicable law and any relevant exemptions, you may have the right to:

• be informed about how your personal information is processed;
• request access to personal information we hold about you;
• request correction of inaccurate or incomplete information;
• request deletion of your personal information in appropriate circumstances;
• request restriction of processing;
• object to certain processing of your personal information;
• withdraw consent where processing is based upon consent;
• request portability of eligible personal information;
• object to certain forms of automated decision-making, where applicable; and
• lodge a complaint with the Nigeria Data Protection Commission or another competent supervisory authority.

To exercise any of these rights, please contact us at info@marulaoak.com. We may request information reasonably necessary to verify your identity before responding to a request.

11. Automated Decision-Making

Marula Oak does not currently use personal information submitted through the Begin the Conversation form to make solely automated decisions that produce legal or similarly significant effects concerning you.

Initial enquiries are reviewed by a member of the Marula Oak team.

12. Children's Information

Marula Oak's website and enquiry services are intended for adults and are not directed towards children.

We do not knowingly solicit personal information directly from children through our website. Where information relating to children becomes relevant to a family-office engagement, it will be handled in accordance with applicable law and appropriate safeguards.

13. Cookies and Similar Technologies

Our website currently does not use non-essential advertising or analytics cookies.

The website may use limited browser storage or technologies necessary to operate the site and remember your cookie preferences. Further information is provided in our Cookie Policy.

If we introduce analytics, advertising or other non-essential tracking technologies in the future, we will update our Cookie Policy and obtain consent where required before such technologies are activated.

14. Third-Party Websites

Our website may contain links to websites or services operated by third parties.

Marula Oak is not responsible for the privacy practices, security or content of third-party websites. We encourage you to review the privacy notices of any third-party website before providing personal information.

15. Complaints

If you have concerns regarding our handling of your personal information, we encourage you to contact us first so that we can consider and address your concerns.

You also have the right, where applicable, to lodge a complaint with the Nigeria Data Protection Commission (NDPC) or another competent data-protection supervisory authority.

16. Changes to this Privacy Policy

We may amend this Privacy Policy periodically to reflect changes to our services, technology, legal requirements or information-processing practices.

The revised policy will be published on our website with an updated "Last Updated" date. Where a change materially affects how we process personal information, we will provide additional notice where required by law.

17. Contact Us

For questions, concerns or requests concerning this Privacy Policy or Marula Oak's processing of your personal information, please contact:

Marula Oak Limited
Email: info@marulaoak.com
Website: marulaoak.com