Privacy Policy

1Introduction

Benmort Connect (“Benmort”, “we”, “our”, or “us”) respects your privacy and is committed to protecting your personal information.

This Privacy Policy explains how we collect, use, disclose, store, protect, and otherwise process personal information when you access or use any Benmort Connect platform, website, mobile application, marketplace, payment services, advisory services, compliance services, workforce mobility services, or any related product or service.

This Privacy Policy applies to all Benmort Connect business units, including Benmort Marketplace, Benmort Business Solutions (BBS), Benmort Pay, Benmort Global Services (BGS), Benmort Compliance Hub (BCH), and any affiliated products or services that expressly reference this Policy.

By accessing or using Benmort services, you confirm that you have read and understood this Privacy Policy.

2Our Privacy Principles

Everything we do with your personal information is guided by ten core principles. These are not just regulatory checkboxes — they reflect how we genuinely believe your information should be handled.

3Scope of This Policy

This Privacy Policy applies whenever you interact with Benmort, regardless of the device or channel you use. It covers personal information processed when you:

• Visit our website or digital platforms
• Participate in referral or ambassador programmes
• Create or manage an account
• Communicate with us through any channel
• Use our marketplace
• Attend our events or training programmes
• Purchase services
• Subscribe to newsletters
• Apply for jobs or international opportunities
• Participate in surveys or research
• Engage our consulting or advisory services
• Interact with our social media channels
• Use Benmort Pay payment facilitation services

4Key Definitions

The following terms have specific meanings in this Privacy Policy:

This table (Term · Meaning) is being finalised and will appear here shortly.

5Information We Collect

The information we collect depends on the services you use. We only collect what we genuinely need to provide you with the service you have requested. Here is an overview of the categories of information we may collect:

A. Identity Information

• Full name
• Gender (where voluntarily provided or required)
• Date of birth (where required)
• Photograph or profile image
• Nationality (where relevant)
• Government-issued identification details where required for verification or regulatory compliance

B. Contact Information

• Email address
• Country of residence
• Telephone number
• Emergency contact details where relevant
• Postal and residential address

C. Account Information

• Username
• Profile information
• Encrypted password
• Language preferences
• Account preferences
• Account activity history

D. Employment & Professional Information

• Curriculum vitae (CV)
• References
• Employment history
• Skills and competencies
• Qualifications
• Portfolio information
• Professional licences
• Salary expectations (where voluntarily provided)
• Certifications

E. Business Information

• Business name and registration details
• Authorised representatives
• Tax identification information
• Ownership information where legally required
• Business address
• Bank account details for business transactions

F. Financial & Payment Information

• Bank account or mobile money details
• Transaction history
• Payment references
• Invoice records
• Billing information

G. Technical Information

• IP address
• Language settings
• Browser type and version
• Access times and pages viewed
• Device identifiers
• Referring websites
• Operating system
• Application logs and diagnostic information

H. Location Information

• Approximate or GPS location (with permission)
• Country, region, and time zone

I. Communications

• Emails and support tickets
• Call recordings where permitted by law
• Chat messages
• Feedback and survey responses
• WhatsApp or SMS communications

J. Compliance Information

• Identity verification documents
• Any other information required to satisfy legal or regulatory obligations
• Anti-fraud and due diligence documentation

For financial and payment information, Benmort stores only what is reasonably necessary to facilitate authorised transactions and meet legal obligations. Sensitive payment credentials are handled in accordance with applicable security standards and, where appropriate, by regulated payment service providers.

For location information, you may disable location permissions through your device settings, although some features may not function as intended if you do so.

6Information We Receive from Third Parties

We do not only receive information directly from you. In some cases, we may receive personal information from trusted third parties in order to provide or improve our services. These may include:

• Referral partners and ambassadors
• Regulatory authorities
• Authorised employers and recruitment partners
• Publicly available sources
• Educational institutions
• Social media platforms where you interact with our accounts
• Payment service providers
• Other third parties where you have authorised the sharing of your information
• Identity verification providers

We take reasonable steps to ensure that information received from third parties has been obtained lawfully and that those parties have the right to share it with us.

7Information You Choose to Provide

In addition to information we collect as part of our services, you may voluntarily share additional information with us, including profile biographies, business ideas or proposals, pitch decks, portfolios, résumés, testimonials, preferences, survey responses, photographs or videos, and documents uploaded through our platforms.

You are responsible for ensuring that the information you voluntarily provide is accurate, that you have the right to share it, and that sharing it with Benmort does not infringe the rights of any third party.

8Legal Basis for Processing

Benmort processes personal information only where there is a lawful basis to do so. We never process personal information arbitrarily. Here is an overview of the legal bases we rely on and when we use them:

Where consent is the legal basis, you may withdraw it at any time. Withdrawing consent does not affect the lawfulness of any processing carried out before the withdrawal.

9How We Use Your Information

We use the personal information we collect for legitimate purposes that are necessary to operate our business and deliver our services. Specifically, we may use your information to:

• Create and manage user accounts
• Respond to enquiries and support requests
• Verify identity where required
• Administer referral, ambassador, and partner programmes
• Provide requested products and services
• Communicate service updates and important notices
• Facilitate transactions through Benmort Pay
• Issue invoices and process payments
• Manage the holding and release of funds
• Detect and prevent fraud or misuse
• Connect clients with service providers through the Marketplace
• Maintain platform security
• Deliver consulting and advisory services
• Improve our products, services, and user experience
• Provide workforce mobility and career services
• Conduct internal reporting and analytics
• Deliver compliance and governance services
• Comply with legal and regulatory obligations

We will not use your personal information for purposes that are incompatible with those described in this Policy without providing appropriate notice or obtaining consent where required.

10Special Categories of Information

Some of the services we provide may require us to handle information that is particularly sensitive in nature. Examples may include identity verification documents, immigration or visa documentation, professional licences and certifications, educational records, criminal record checks where required by employers or law, and biometric information where legally permitted.

We collect and process sensitive information only where it is reasonably necessary for the service requested, authorised by applicable law, or where we have obtained your explicit consent. We apply higher security standards to the handling of sensitive information.

11Cookies & Similar Technologies

We use cookies and similar technologies on our digital platforms to support session management, user preferences, website functionality, performance analysis, security, and analytics.

Cookies may be used to:

• Maintain your login session
• Enhance platform security
• Remember your preferences
• Understand user behaviour and navigation
• Improve website functionality
• Support marketing and analytics where permitted
• Analyse website performance and usage

You can manage your cookie preferences through your browser or device settings. Please be aware that disabling certain cookies may affect the functionality of some of our services. A separate Cookie Policy may provide additional details on specific cookies in use.

12Analytics

We use analytics tools to help us understand how people use our services, so that we can improve them. Analytics data we collect may include pages visited, time spent on pages, navigation paths, device and browser information, feature usage, and error reports.

Where possible, analytics data is aggregated or de-identified so that it does not identify you personally. We use analytics to improve the quality, usability, and performance of our services — not to profile you as an individual.

13Marketing Communications

With your consent where required, Benmort may send you newsletters, product announcements, promotional campaigns, educational resources, event invitations, service recommendations, and partnership opportunities.

You can opt out of marketing communications at any time by using the unsubscribe link in any marketing email, updating your account preferences, or contacting us directly.

Even if you opt out of marketing communications, we may still send you important service-related communications — such as security alerts, changes to your account, or legal notices — because these are necessary for us to fulfil our obligations to you.

14Artificial Intelligence & Automation

Benmort may use artificial intelligence and automation tools to support aspects of our services, including customer service, candidate matching, workflow automation, fraud detection, document processing, analytics, and recommendation systems.

These technologies are designed to support — not replace — appropriate human oversight, particularly where decisions may significantly affect individuals. Where required by applicable law, you may request human review of significant automated decisions that affect you.

15Sharing Your Information

We share personal information only where it is reasonably necessary to deliver our services, comply with legal obligations, or protect the legitimate interests of our business and users.

Recipients of your information may include:

• Authorised employers and educational institutions
• Logistics providers
• Recruitment and partner organisations
• Regulators and government authorities where required by law
• Payment service providers and banking partners
• Auditors, insurers, and professional advisers
• Cloud hosting and technology vendors
• Courts or law enforcement agencies where required by law
• Identity verification providers

16Referral, Ambassador & Partner Programmes

Where you participate in Benmort’s referral, ambassador, affiliate, or partner programmes, we process information relating to your referral activity, programme participation, commission or incentive eligibility, payment records, and performance metrics.

This information is used solely for administering the relevant programme and fulfilling related contractual and legal obligations. It is not used for purposes unrelated to the programme without appropriate notice or consent.

17Marketplace Information Sharing

When you use the Benmort Marketplace, some of your information is necessarily shared between clients and service providers to enable projects to proceed. This may include profile information, project details, proposals, communications, invoices, ratings and reviews, and transaction records.

We encourage all Marketplace users to share only the information that is genuinely necessary for the project. Avoid including unnecessary personal or sensitive information in Marketplace communications or attachments.

18Benmort Pay Information

Benmort Pay requires processing of payment-related information to function effectively and lawfully. For payment facilitation services, we may process information needed to verify participants, facilitate authorised payments, administer the holding and release of funds, investigate disputes, prevent fraud, and comply with anti-money laundering, sanctions screening, and other legal obligations.

We may share relevant information with regulated financial institutions and payment service providers where necessary to complete authorised transactions. All such sharing is subject to appropriate contractual safeguards.

19International Data Transfers

Benmort operates across multiple jurisdictions, which means your personal information may be processed or stored in countries outside your country of residence. This may occur because our cloud infrastructure is located internationally, we engage international service providers, or we facilitate cross-border workforce mobility and educational services.

Where personal information is transferred internationally, Benmort will take reasonable steps to ensure appropriate safeguards are in place so that your information continues to receive an adequate level of protection consistent with applicable law.

20Retention of Personal Information

We keep your personal information only for as long as is reasonably necessary for the purpose for which it was collected. Retention periods vary depending on the nature of the service, contractual obligations, statutory requirements, regulatory expectations, and operational needs.

When information is no longer required, we will securely delete it, anonymise it, or otherwise dispose of it in accordance with our records management practices. We review retention periods periodically to ensure we are not keeping information longer than necessary.

21Your Privacy Rights

Subject to applicable law, you have a range of rights in relation to your personal information. We want you to know what they are and how to use them.

We may ask you to verify your identity before we respond to a privacy request. This is to protect your information from being accessed by someone else.

22Exercising Your Rights

To exercise any of your privacy rights, please submit a request through Benmort’s official support channels. We will aim to respond within the timeframe required by applicable law.

There are some circumstances in which we may be unable to fulfil a request. For example, where we are legally required to retain the information, where disclosure would adversely affect another individual’s rights, or where a recognised legal exemption applies. Where we decline a request, we will provide an explanation unless we are prohibited from doing so by law.

23Information Security

We take the security of your personal information seriously. Benmort maintains a programme of administrative, technical, and physical safeguards designed to protect personal information from unauthorised access, disclosure, loss, or destruction.

Our security programme may include:

• Role-based access controls
• Regular software updates and patch management
• Multi-factor authentication and password management
• Secure backup and disaster recovery
• Encryption of data in transit and at rest
• Employee confidentiality obligations
• Secure cloud infrastructure
• Security awareness training
• Firewall and endpoint protection
• Vendor security assessments
• Security monitoring and logging

While we take reasonable measures, no method of electronic transmission or storage is completely secure. Users should also take reasonable steps to protect their own accounts, devices, and credentials. If you believe your account has been compromised, please contact us immediately.

24Data Breach Management

Benmort maintains documented procedures for identifying, assessing, containing, and responding to personal data breaches. Where required by applicable law, we will investigate suspected incidents promptly, take reasonable steps to minimise potential harm, notify affected individuals where legally required, notify the relevant supervisory or regulatory authority, and document the incident and the corrective actions taken.

25Account Security

The security of your account is a shared responsibility. You agree to:

• Create and maintain strong, unique passwords for your Benmort account.
• Keep your login credentials strictly confidential and not share them with others.
• Notify Benmort immediately if you suspect any unauthorised access to your account.
• Log out from shared or public devices after using your account.
• Keep your account information accurate and up to date.

Benmort is not responsible for losses arising from a user’s failure to take reasonable steps to safeguard their account credentials.

26Children’s Privacy

Benmort’s services are generally designed for individuals who have the legal capacity to enter into binding agreements. We do not knowingly collect personal information from children where this is prohibited by applicable law.

Where a specific service is designed for minors, personal information will only be collected or processed with the consent or authorisation required under applicable law. If we become aware that we have inadvertently collected personal information from a child unlawfully, we will take reasonable steps to delete or otherwise address it in accordance with legal requirements.

27Third-Party Websites & Services

Our platforms may contain links to third-party websites, applications, or services. Benmort does not control the privacy practices of those third parties and is not responsible for their content, security, or privacy policies.

We encourage you to review the privacy policy of any third-party service before submitting personal information to it. The presence of a link on our platform does not constitute an endorsement of that third party’s privacy practices.

28International Business Services

Some Benmort services involve international education, employment, consulting, recruitment, payments, or business partnerships. Where necessary to provide such services, personal information may be shared with overseas employers, educational institutions, immigration advisers or authorised representatives, licensing bodies, training organisations, foreign government agencies where legally required, and international service providers.

Such disclosures are limited to the information reasonably necessary for the requested service and are subject to appropriate legal or contractual safeguards where applicable.

29Business Transfers

If Benmort undergoes a merger, acquisition, investment transaction, corporate restructuring, sale of assets, or similar business event, personal information may be transferred as part of that transaction, subject to applicable legal requirements.

Any successor organisation will be expected to continue protecting personal information in a manner substantially consistent with this Privacy Policy. Where material changes to how your information is handled would result from such a transaction, we will provide appropriate notice.

30User Responsibilities

Protecting your privacy is something we work on together. As a user, you are responsible for:

• Providing accurate and truthful information when using our services.
• Updating your information when it changes so our records remain current.
• Protecting your account credentials from unauthorised access.
• Ensuring you have the necessary authority to share any third-party information you provide to Benmort.
• Using Benmort services responsibly, lawfully, and in accordance with these policies.

Please avoid submitting unnecessary sensitive personal information unless it is specifically required as part of the service you are using.

31Records Management

Benmort maintains records management practices designed to support legal compliance, operational efficiency, regulatory obligations, business continuity, audit requirements, and secure disposal of records. Records may be held in electronic or physical form depending on the nature of the information and applicable legal requirements.

32Automated Decision-Making

Benmort may use automated tools to assist with activities such as matching candidates with opportunities, identifying potentially fraudulent activity, recommending services, improving platform functionality, and workflow automation.

These tools are intended to support operational efficiency and are subject to appropriate human oversight where decisions could significantly affect individuals. Where required by applicable law, you may request additional information about significant automated decisions affecting you, and in some cases may request that a human reviews the decision.

33Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in applicable law, regulatory guidance, business operations, technology, security practices, or service offerings.

Where material changes are made, we will take reasonable steps to notify you through appropriate channels, such as our website, email, or platform notifications. The updated Privacy Policy becomes effective on the published effective date. Your continued use of Benmort services after that date constitutes acceptance of the revised Policy.

34Contact Us

If you have questions, requests, or concerns regarding this Privacy Policy or our privacy practices, please get in touch through our official support channels. Where Benmort has appointed a Data Protection Officer or designated privacy contact, enquiries may also be directed to that individual using the published contact details.

We aim to acknowledge all privacy-related enquiries within 5 business days and to respond fully within the timeframe required by applicable law.

35Complaints

If you believe your personal information has been handled in a way that is inconsistent with this Privacy Policy or applicable law, we want to hear from you. Please submit a complaint through our official support channels. We will acknowledge and investigate complaints within a reasonable period and work to resolve them fairly and promptly.

If you remain dissatisfied with our response, you may have the right to escalate your complaint to the appropriate supervisory or regulatory authority under applicable data protection law.

36Governing Law

This Privacy Policy shall be interpreted in accordance with the laws applicable to the relevant Benmort contracting entity, unless mandatory data protection legislation in your jurisdiction requires otherwise. Nothing in this Privacy Policy limits any rights granted to individuals under applicable data protection laws.

37Severability

If any provision of this Privacy Policy is determined to be invalid, unlawful, or unenforceable by a court or competent authority, the remaining provisions shall continue in full force and effect.

38Entire Privacy Policy

This Privacy Policy should be read together with the following Benmort Connect documents:

• Benmort Connect General Terms of Use
• Acceptable Use Policy
• Cookie Policy
• Applicable business unit Terms and Conditions
• Data Processing Addendum (where applicable)
• Any specific privacy notices provided for particular services

Where a specific business unit requires additional privacy disclosures, those disclosures supplement — but do not replace — this Privacy Policy.

SCHEDULE 1 — PERSONAL INFORMATION BY BUSINESS UNIT

This Schedule provides an overview of the typical categories of personal information processed by each Benmort Connect business unit. This is illustrative rather than exhaustive; the specific information processed in any engagement depends on the nature of the service provided.