PRIVACY POLICY

Platform: susu.prierz.com (the "Platform")

Operator: FOH-PEE ENTERPRISE ("we," "us," "our," the "Company")

Effective Date: July 6, 2026

Contact: admin@susu.prierz.com

This Privacy Policy explains how the Company collects, uses, discloses, and

protects personal data when you use susu.prierz.com (the "Platform"). It is

incorporated into, and should be read alongside, our Terms and Conditions.

By using the Platform, you consent to the practices described in this

Policy.

1. Who This Policy Covers

This Policy applies to anyone who visits the Platform, registers an account,

joins or administers a Group, verifies their identity, or otherwise

interacts with our Service ("you," "User"). It does not apply to third-party

websites or services that may be linked from the Platform, which have their

own privacy practices.

2. Information We Collect

2.1 Information you provide directly

Registration data: full name, phone number, email address, password,

and any profile details you add.

Identity verification (KYC) data: government-issued ID details

(e.g., ID type, number, and images), date of birth, address, selfie/photo

verification, and any other document we require to verify your identity.

Financial and payment data: mobile money number, bank account details

(for withdrawals), and payment card or transaction references processed

through our payment partners (see Section 5).

Group and transaction content: the groups you create or join,

contribution amounts, payout history, guarantor approvals you give or

receive, marketplace listings and purchases, and messages or notes you

submit within the Platform.

Communications: anything you send us via email, support requests, or

in-app messages.

2.2 Information collected automatically

Device and usage data: IP address, device type, operating system,

browser type, app version, and general log data (timestamps, pages/screens

viewed, actions taken).

Location data: approximate location inferred from your IP address, or

precise location if you separately grant permission for a specific

feature.

Cookies and similar technologies: used to keep you logged in,

remember preferences, and understand how the Platform is used (see

Section 9).

2.3 Information from third parties

Payment processors (e.g., Paystack, Flutterwave, mobile money

operators, banks): confirmation of payment success/failure, masked

payment instrument details, and transaction references.

Identity verification partners, if used, to confirm the authenticity

of submitted documents.

Referrers: if you were referred to the Platform by another User, we

receive the referral link/code used.

3. How We Use Your Information

We use personal data to:

create and manage your account and authenticate you;

operate Groups — recording contributions, computing payout order and

schedules, and processing payouts;

process deposits, withdrawals, contribution payments, marketplace

transactions, and fees;

verify your identity (KYC) and screen for fraud, money laundering, or

other prohibited activity;

calculate reputation scores and guarantor obligations;

communicate with you — service notifications, payment confirmations,

contribution reminders, security alerts, and support responses;

enforce our Terms and Conditions, investigate suspicious activity, and

resolve disputes between Members;

comply with legal, regulatory, and tax obligations, including

anti-money-laundering (AML) and know-your-customer (KYC) requirements;

improve, secure, and troubleshoot the Platform; and

send you marketing or promotional communications, where permitted, from

which you may opt out at any time.

We do not use your identity verification documents for any purpose beyond

verification, fraud prevention, and legal compliance.

4. Legal Basis for Processing

Where applicable law requires a legal basis for processing personal data, we

rely on one or more of the following: performance of our contract with you

(these Terms), compliance with a legal obligation (e.g., AML/KYC law),

our legitimate interests (e.g., fraud prevention, Platform security, service

improvement) balanced against your rights, and your consent (e.g., for

optional marketing communications), which you may withdraw at any time.

5. How We Share Information

We do not sell your personal data. We share it only as follows:

Payment processors and financial partners (e.g., Paystack,

Flutterwave, mobile money operators, banks) — to process deposits,

withdrawals, and payments. These providers process data under their own

privacy policies and applicable card-network/regulatory rules.

Other Members of a Group, limited to what is necessary for the

Group to function: your name, reputation score, payout position, and

whether you are current or behind on a contribution. We do not share

your Wallet balance, contact details, or identity verification data with

other Members.

Identity verification and fraud-prevention providers, where we use a

third party to validate submitted documents.

Regulators, law enforcement, or courts, where required by law, legal

process, or to protect the rights, property, or safety of the Company, our

Users, or the public — including anti-money-laundering and

counter-terrorist-financing reporting obligations.

Professional advisors (lawyers, auditors, accountants), bound by

confidentiality, where necessary for our business.

A successor entity, in connection with a merger, acquisition, financing,

or sale of some or all of our assets, subject to that entity honoring the

commitments in this Policy.

With your consent, for any other purpose we disclose to you at the

time.

6. Data Retention

We retain personal data for as long as your account is active and for a

reasonable period afterward as necessary to:

comply with legal, tax, and regulatory recordkeeping obligations

(including AML/KYC record-retention requirements, which may require

retention for several years after account closure);

resolve disputes, enforce our Terms, and defend or pursue legal claims;

and

maintain accurate financial and transaction records for Groups you

participated in, even after you leave the Platform, to the extent needed

to preserve the integrity of those Groups' records for other Members.

When data is no longer needed for these purposes, we take reasonable steps

to delete, anonymize, or securely archive it.

7. Data Security

We implement reasonable administrative, technical, and physical safeguards

designed to protect personal data against unauthorized access, alteration,

disclosure, or destruction, including access controls, encryption of

sensitive data in transit, and restricted internal access to identity

verification and financial data. No system is completely secure, however,

and we cannot guarantee absolute security of information transmitted to or

stored on the Platform.

You are responsible for keeping your login credentials confidential and for

notifying us immediately at admin@susu.prierz.com if you suspect

unauthorized access to your account.

8. Your Rights

Subject to applicable law (including Ghana's Data Protection Act, 2012

(Act 843)), you may have the right to:

access the personal data we hold about you;

correct inaccurate or incomplete data;

request deletion of your data, subject to our right to retain data

required for legal, regulatory, or legitimate business purposes described

in Section 6 (including active Group obligations and financial records);

object to or restrict certain processing, including direct marketing;

withdraw consent where processing is based on consent, without

affecting the lawfulness of processing before withdrawal; and

lodge a complaint with the Data Protection Commission of Ghana or

another applicable supervisory authority.

To exercise any of these rights, contact us at admin@susu.prierz.com. We may

need to verify your identity before acting on your request, and we will

respond within a reasonable time as required by applicable law.

Please note that some rights (particularly deletion) cannot be exercised

while you have an active Group membership, outstanding contribution,

guarantor obligation, or unresolved dispute, since removing that data would

compromise the accuracy of other Members' records.

9. Cookies and Similar Technologies

We use cookies and similar technologies to keep you signed in, remember your

preferences, understand usage patterns, and secure the Platform. You can

control cookies through your browser or device settings; disabling them may

affect the functionality of the Platform, including your ability to stay

logged in.

10. Children's Privacy

The Platform is not directed to, and may not be used by, anyone under 18

years of age. We do not knowingly collect personal data from children. If we

become aware that we have collected personal data from someone under 18, we

will take steps to delete it and, where applicable, close the associated

account.

11. International Data Transfers

The Platform, its payment processors, and its service providers may store or

process data in countries other than your own, including outside Ghana.

Where we transfer personal data internationally, we take reasonable steps to

ensure it receives an adequate level of protection consistent with

applicable data protection law.

12. Third-Party Links and Services

The Platform may link to, or integrate with, third-party services (such as

payment gateways). Those third parties operate under their own privacy

policies, and we encourage you to review them. We are not responsible for

the privacy practices of third parties.

13. Marketing Communications

Where you have opted in (or where permitted by law), we may send you

promotional messages about the Platform, new features, or referral

incentives. You may opt out at any time using the unsubscribe link provided

or by contacting admin@susu.prierz.com. You will continue to receive

essential service communications (e.g., payment confirmations, security

alerts) even if you opt out of marketing.

14. Changes to This Policy

We may update this Privacy Policy from time to time by posting a revised

version on the Platform with an updated effective date. Material changes

will be communicated through the Platform or by other reasonable means.

Your continued use of the Platform after a change takes effect constitutes

your acceptance of the revised Policy.

15. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy

or your personal data, contact:

FOH-PEE ENTERPRISE

Website: susu.prierz.com

Email: admin@susu.prierz.com