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Legal

PRIVACY POLICY

Effective date: May 2026 · Jolden Global Limited · Nairobi, Kenya

At The Forge, we take your privacy seriously. This policy explains what personal data we collect, why we collect it, how we protect it, and what rights you have over it. We have written it in plain language — no legal jargon.

1. Who We Are

The Forge is a professional development intervention programme operated by Jolden Global Limited, a company registered in Nairobi, Kenya (BRS: PVT-JZUAV7YD). Registered address: Nairobi, Kenya Email: info@joldenglobal.com Phone: +254 727 050 356 Website: joldenglobal.com

2. What Information We Collect

We collect the following personal information when you interact with The Forge platform: • Full name and email address (at enrollment and audit booking) • Phone number (optional, for M-Pesa payment processing) • Payment information (processed securely via Stripe — we do not store card details) • Your responses during the Identity Scan, Identity Audit, and Phase sessions • Artifact submissions and Forge Index scores • Usage data including pages visited, session duration, and interaction patterns

3. How We Use Your Information

We use your information to: • Deliver your enrolled programme phases and AI-facilitated sessions • Process payments and issue receipts • Track your Forge Index scores and artifact progress • Send programme-related communications (session reminders, artifact feedback, phase unlocks) • Improve the platform, content, and intervention methodology • Comply with legal obligations under Kenyan law We do not sell, rent, or trade your personal information to third parties.

4. Legal Basis for Processing

We process your personal data on the following legal bases: • Contract performance — to deliver the programme you enrolled in • Legitimate interests — to improve our platform and intervention outcomes • Consent — for marketing communications (you may withdraw at any time) • Legal obligation — where required by Kenyan law or applicable regulation

5. Data Storage and Security

Your data is stored on secure cloud infrastructure (Supabase) with the following protections: • Encrypted data transmission (SSL/TLS) • Row-level security — your data is only accessible to you and authorised Forge staff • No third-party access except service providers listed in Section 6 • Regular security reviews We retain your data for as long as your account is active, plus 3 years after your last interaction, unless you request earlier deletion.

6. Third-Party Service Providers

We share limited data with the following service providers solely to deliver our programme: • Stripe — payment processing (stripe.com/privacy) • Supabase — database and authentication (supabase.com/privacy) • Anthropic — AI session facilitation (anthropic.com/privacy) • Resend — transactional email delivery (resend.com/privacy) • Vercel — platform hosting (vercel.com/legal/privacy-policy) Each provider is contractually bound to protect your data and may not use it for their own purposes.

7. Your Rights

You have the right to: • Access — request a copy of all personal data we hold about you • Correction — request correction of inaccurate or incomplete data • Deletion — request deletion of your personal data ("right to be forgotten") • Portability — receive your data in a structured, machine-readable format • Objection — object to processing based on legitimate interests • Withdrawal of consent — withdraw marketing consent at any time To exercise any of these rights, email: info@joldenglobal.com We will respond within 30 days.

8. Cookies and Tracking

The Forge uses minimal cookies: • Session cookies — to keep you logged into the Cadet portal (essential, cannot be disabled) • Analytics cookies — to understand how the platform is used (you may opt out) We do not use advertising or tracking cookies. We do not run retargeting campaigns using your data.

9. Children's Privacy

The Forge is designed for professionals aged 18 and above. We do not knowingly collect personal data from individuals under 18. If you believe a minor has submitted data to our platform, contact us immediately at info@joldenglobal.com and we will delete it promptly.

10. International Data Transfers

Jolden Global Limited is based in Kenya. Some of our service providers (Stripe, Supabase, Anthropic, Vercel) process data in the United States and European Union. Where data is transferred internationally, we ensure appropriate safeguards are in place in accordance with applicable data protection law.

11. Changes to This Policy

We may update this Privacy Policy from time to time. When we do, we will update the effective date at the top of this page and notify active Cadets by email. Continued use of the platform after changes constitutes acceptance of the updated policy.

12. Contact Us

For any privacy-related questions, requests, or complaints: Jolden Global Limited Email: info@joldenglobal.com Phone: +254 727 050 356 Nairobi, Kenya If you are unsatisfied with our response, you have the right to lodge a complaint with the relevant data protection authority in your jurisdiction.