This document is where we lay out our commitment to protecting your privacy and securing your information. At Shuaib Holdings, we believe that trust isn't just a nice-to-have; it's the absolute foundation of everything we do. Whether you’re an investor, a partner company employee, a job applicant, or just visiting our website, we want you to feel completely confident about how we handle your personal data.

By engaging with Shuaib Holdings, whether through our website, investments, or partnerships, you’re trusting us with your information. We are deeply committed to honoring that trust.

1. What Information Does Shuaib Holdings Collect?

We only collect information that is necessary for us to operate effectively, provide our services, and maintain our legal and regulatory obligations. The information we gather generally falls into a few categories.

Information You Provide Directly to Us: This is the most common way we receive information.You actively give it to us when you:

· Get in touch with us through our website’s contact form, via email, or by phone.

· Express interest in an investment opportunity with us.

· Apply for a job or a consulting role with Shuaib Holdings.

· Sign agreements or other legal documents as a representative of a portfolio company or partner firm.

· Subscribe to receive updates, newsletters, or reports from us.

· Attend a Shuaib Holdings event and provide your details.

This type of information can include your name, email address, phone number, professional title, company name, and any other details you choose to include in your communication. For job applicants, this extends to your resume, work history, and references. In specific investment contexts, we may need to collect more detailed information to fulfill our due diligence and regulatory obligations, but we will always be transparent about what we need and why.

Information We Collect Automatically: When you visit our website,like most sites on the internet, we automatically collect certain technical information through cookies and similar technologies. This includes:

· Log Data: Your IP address, browser type and version, the pages of our site you visit, the time and date of your visit, and the time spent on those pages.

· Device Information: Information about the device you use to access our site, such as the device type, operating system, and unique device identifiers.

We want to be clear: this data is collected in an aggregated, anonymized way. We use it to understand how people interact with our website so we can improve its design, content, and functionality. It’s about optimizing the user experience, not about tracking you as an individual.

Information from Third Parties and Public Sources: As a holdings firm,part of our work involves thorough research. We may receive information about you from third-party sources, such as professional networking sites like LinkedIn, or from publicly available sources like corporate websites or financial registries. This helps us in our investment analysis and in building potential partnership opportunities. If we reach out to you based on this research, we will always identify ourselves as Shuaib Holdings and explain the context.

2. How We Use Your Information at Shuaib Holdings

We use your information for specific, clear purposes that are connected to our business operations and our relationship with you.

To Communicate and Build Relationships: Primarily,we use your contact information to respond to your inquiries, send you requested information, and facilitate conversations. If you’ve expressed interest in our work, we might use your details to periodically share news about Shuaib Holdings that we believe is relevant to you, always giving you the option to unsubscribe.

For Our Investment and Business Operations: This is at the heart of what we do.We use the information provided to evaluate potential investment opportunities, conduct necessary due diligence, manage our existing portfolio of companies, and handle the legal and financial aspects of these relationships. This processing is essential for the legitimate interests of Shuaib Holdings in making sound investment decisions and fulfilling our contractual obligations.

For Talent Acquisition: If you’ve applied for a role with us,we use your information to process your application, assess your qualifications, conduct interviews, and, if you’re successful, to make an offer of employment. We treat applicant data with the utmost confidentiality.

For Website and Service Improvement: The automatic technical data we collect helps us analyze trends,administer the site, track user movements, and gather broad demographic information. This aggregated data is invaluable for understanding what content resonates with our audience and ensuring our website is technically sound and user-friendly.

For Security and Legal Compliance: Protecting the assets,reputation, and integrity of Shuaib Holdings is paramount. We use information to monitor and improve our security posture, prevent fraud, and protect against malicious activity. Furthermore, we are subject to various legal and regulatory requirements, and we may use your information to comply with these obligations, such as anti-money laundering checks or responding to lawful requests from public authorities.

3. Our Legal Basis for Processing Your Data

We don’t just collect and use data arbitrarily. We rely on a few key legal grounds to process your personal information:

· Your Consent: In some cases, we ask for your explicit consent to process your data. For example, when you sign up for our marketing newsletters. You can withdraw this consent at any time, and we will stop that processing immediately.

· Legitimate Interests: Often, we process data because it is necessary for the legitimate interests of Shuaib Holdings, such as managing our investments, operating our website, and ensuring security. We always balance our interests against your privacy rights to ensure they don’t override them.

· Contractual Necessity: We process information when we need to to fulfill a contract with you or to take steps at your request before entering into a contract.

· Legal Obligation: Sometimes, we are required to process your data to comply with a law we are subject to.

4. How We Share Your Information

We treat your information with confidentiality and discretion. We do not sell, rent, or trade your personal data to third parties for their marketing purposes. There are, however, a few specific scenarios where sharing is necessary:

· Within Shuaib Holdings: Your information may be shared internally among our team members on a need-to-know basis to conduct our business.

· With Our Portfolio Companies and Partners: In the course of evaluating an investment or managing a portfolio company, it may be necessary to share certain information with key personnel at those companies. This is always done with a clear business purpose and under strict confidentiality agreements.

· With Service Providers: We work with trusted third-party vendors who provide services to us, such as cloud hosting providers, email marketing platforms, legal and accounting firms, and IT security services. These providers only process your data on our explicit instructions and are bound by stringent data protection agreements.

· For Legal and Regulatory Reasons: We may disclose your information if we are required to do so by law, court order, or governmental authority, or if we believe disclosure is necessary to protect our rights, your safety, or the safety of others, to investigate fraud, or to respond to a government request.

· In Connection with a Business Transition: In the event that Shuaib Holdings goes through a business transition, such as a merger, acquisition, or sale of all or a portion of its assets, your information may be among the assets transferred.

5. How We Protect Your Information: Our Security Measures

Security isn't an afterthought at Shuaib Holdings; it's integrated into everything we do. We implement a robust set of technical, administrative, and physical security measures designed to protect your personal information from unauthorized access, alteration, disclosure, or destruction.

· Technical Safeguards: We use encryption for data both in transit (using SSL/TLS protocols on our website) and at rest. Our systems are protected by firewalls and intrusion detection systems. We enforce strict access controls, ensuring that only authorized personnel have access to your data, and only for the purposes we’ve described.

· Administrative Safeguards: Our employees receive training on data protection and security practices. We have clear internal policies and procedures for handling data, and we require all our service providers to adhere to similarly high standards through contractual obligations.

· Physical Safeguards: Access to our physical offices and server infrastructure is controlled and limited to authorized personnel.

· Continuous Evaluation: The digital landscape is always changing, and so are threats. We continuously review and update our security practices to address new risks and employ industry-standard best practices.

While we take these extensive measures, it’s important to remember that no method of transmission over the Internet or method of electronic storage is 100% secure. Although we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.

6. Data Retention: How Long We Keep Your Information

We don’t hold onto your data longer than we need to. We will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process it, and whether we can achieve those purposes through other means.

For example, we may retain information related to an investment for the entire duration of our ownership and for a period afterward to comply with financial regulations. Website analytics data might be kept in an aggregated form for trend analysis. If you are a job applicant and are not successful, we may retain your details for a limited period in case future opportunities arise, unless you ask us to delete them.

7. Your Privacy Rights and Choices

You have important rights regarding your personal data. Shuaib Holdings respects these rights and will work to facilitate them. These rights include:

· Access: You can request a copy of the personal information we hold about you.

· Correction: You can ask us to correct any inaccurate or incomplete information we have about you.

· Erasure ("The Right to be Forgotten"): You can request that we delete your personal data in certain circumstances.

· Restriction of Processing: You can ask us to temporarily or permanently stop processing all or some of your personal data.

· Data Portability: You can request a structured, machine-readable copy of your data that you provided to us, or ask us to send it directly to another controller.

· Objection: You can object to us processing your personal data where we are relying on a legitimate interest and you believe it impacts your fundamental rights and freedoms. You can also always object to direct marketing.

· Withdraw Consent: Where we rely on your consent to process your data, you can withdraw that consent at any time.

To exercise any of these rights, please contact us using the details provided in the "Contact Us" section below. We will respond to all legitimate requests in accordance with applicable law. We may need to ask you for specific information to help us confirm your identity, which is a security measure to ensure your data is not disclosed to someone who has no right to receive it.

8. International Data Transfers

Our portfolio companies and service providers may be located in other countries. This means that your personal information may be transferred to, stored, and processed in countries other than your own.

If we do transfer your data outside of your home country, we will ensure that it is protected by implementing appropriate safeguards as required by data protection laws. This is typically done through standard contractual clauses approved by relevant regulatory bodies that ensure your data receives an equivalent level of protection.

9. Use of Cookies and Similar Technologies

Our website uses cookies and similar tracking technologies to collect information about your browsing activities. A cookie is a small piece of data placed on your device when you visit a site.

We use them for essential functions (like keeping you logged in if we had a login portal), for performance and analytics (to see how the site is used), and for functionality (to remember your preferences). You can control the use of cookies at the individual browser level. Most browsers allow you to refuse cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use all features of our website.

10. Links to Other Websites

Our website may contain links to other sites that are not operated by us, such as the websites of our portfolio companies or news articles. If you click on a third-party link, you will be directed to that third party's site. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services. We strongly advise you to review the privacy policy of every site you visit.

11. Changes to This Privacy Policy

The world of technology and data protection evolves, and so might our practices. We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the "Last Updated" date at the top.

We will let you know via a prominent notice on our website prior to any change becoming effective, if the changes are significant. We encourage you to review this privacy policy periodically for any changes. Your continued use of our services after any change in this Privacy Policy will constitute your acceptance of such change.

12. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, we want to hear from you. Please don’t hesitate to reach out to us. Your privacy is important to us, and we are committed to working with you to resolve any issues.

Thank you for taking the time to read our policy. We appreciate your trust in Shuaib Holdings.

Last Updated: 25 August 2025