Legals

Cookie Policy

Kula is committed to ensuring the privacy and security of your personal data. This Cookies Policy explains how we use cookies on our website and digital platforms in compliance with the Mauritian Data Protection Act (2017) and other applicable regulations. By using our website, you consent to our use of cookies as described in this policy.

What Are Cookies?

Cookies are small text files stored on your device (computer, tablet, or mobile) when you visit a website. They help websites remember your actions and preferences over time to enhance your browsing experience.
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Users have the right to accept or reject cookies, except for those classified as essential for the website’s functionality.

Types of Cookies We Use

We use the following categories of cookies on our website:

1. Essential Cookies

These cookies are necessary for the operation of our website and cannot be disabled. They support core functions such as security, network management, fraud prevention, and accessibility.

2. Analytical/Performance Cookies

These cookies help us understand how users interact with our website, enabling us to improve functionality and performance. They collect anonymous data about website visits, popular pages, and potential errors.

3. Functionality Cookies

Functionality cookies enable us to remember user preferences, such as language settings, login details, and personalization choices, to provide an enhanced experience.

4. Targeting/Advertising Cookies

These cookies collect data about your browsing activity to show you relevant advertisements. They may also limit how often you see certain ads and measure the effectiveness of advertising campaigns.

We do not sell personal data to third parties.

How to Manage Cookies

You can control or disable cookies through your browser settings. Most browsers allow you to:

- Accept or reject all cookies
- Delete stored cookies
- Block specific types of cookies

For instructions on managing cookies, refer to your browser’s official support pages:

- Google Chrome: https://support.google.com/chrome/answer/95647

- Mozilla Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences

- Microsoft Edge: https://support.microsoft.com/en-us/microsoft-edge/view-cookies-in-microsoft-edge-63947406-40ac-c3b7-295b-1c44d5161da3

- Apple Safari: https://support.apple.com/en-gb/guide/safari/sfri11471/mac

Important Note:

Disabling cookies may affect website performance and limit certain features.

Data Protection and Compliance

Kula adheres to the Mauritian Data Protection Act (2017) and international best practices. We ensure:

- Lawful collection and processing of cookie data.
- No transfer of personal data outside Mauritius without appropriate safeguards.
- Transparent use of cookies, with user control over non-essential cookies.

For more details, see our Privacy Policy

Data Retention

Cookies are retained for varying periods depending on their purpose:

- Session cookies: Expire when you close your browser.
- Persistent cookies: Remain on your device for a set duration (e.g., 6–12 months) unless deleted manually.

Updates to This Cookies Policy

We may update this Cookies Policy from time to time to reflect changes in our practices, legal requirements, or operational needs. Updates will be posted on our website.

For any questions or concerns regarding our use of cookies, please contact us on this form.
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At KulaDAO, we are committed to respecting and protecting your privacy. This Privacy Policy outlines how we collect, use, store, and share your personal information when you interact with our website, platform, services, or community.

We process your data in accordance with the Mauritian Data Protection Act (2017) and other applicable international data protection laws, ensuring that your information is handled with transparency, fairness, and care.

Information We Collect

We may collect and process the following categories of personal data:

- Identity Information: including your name, username or similar identifier.
- Contact Information: such as email address, telephone number, or social media handles.
- Technical Information: including IP address, browser type and version, time zone setting, operating system, and other technology on the devices you use to access our services.
- Usage Data: such as information about how you use our website, services, and community platforms.
- Communication Data: including your correspondence with us or content you share via community channels.
- KYC/AML Information: where required for compliance with legal obligations or onboarding to regulated services.

How We Use Your Information

Your information may be used for the following purposes:

- To provide access to our services and maintain secure operations.
- To communicate with you regarding updates, support, or community notices.
- To comply with legal, regulatory, and compliance obligations, including anti-money laundering (AML) and know-your-customer (KYC) requirements.
- To improve our platform, products, and community experience.
- To detect, investigate, and prevent fraud, abuse, or security threats.

We will not sell your personal information or use it for profiling without your explicit consent.

Legal Basis for Processing

Your information may be used for the following purposes:

- Consent: where you have provided clear permission for us to process your data for specific purposes.
- Contractual Necessity: where processing is required to fulfil our obligations to you.
- Legal Obligation: where required under applicable laws and regulations.
- Legitimate Interests: where it is in our interest to improve services, enhance security, or protect against misuse, and where such interests are not overridden by your rights.

Data Retention

We retain personal data only for as long as is necessary to fulfil the purposes outlined above, or to meet legal, accounting, or regulatory requirements. Please refer to the Data Protection and Retention Disclosure.

Data Sharing and Transfers

We may share your information with:

- Affiliated entities within the Kula Group structure.
- Third-party service providers performing services on our behalf (e.g., cloud hosting, analytics, compliance support).
- Regulators, law enforcement agencies, or legal advisors, as required by law or in the protection of our legal rights.

Where data is transferred outside Mauritius, we ensure appropriate safeguards are in place in accordance with applicable legal requirements.

Your Rights

Subject to applicable law, you have the right to:

- Access the personal data we hold about you.
- Request correction of inaccurate or incomplete data.
- Request deletion or restriction of your data under certain circumstances.
- Object to processing where we rely on legitimate interests.
- Withdraw consent at any time where processing is based on consent.
- File a complaint with a supervisory authority if you believe your rights have been violated.

To exercise your rights, please contact us on this form.

Data Security

Subject to applicable law, you have the right to:

We employ robust technical and organisational measures to protect your personal data from unauthorised access, loss, alteration, or misuse. These include encryption, access controls, and regular security assessments.

Despite our efforts, no system is immune to risks. We encourage users to take steps to protect their information, including the use of strong passwords and secure internet connections.

Cookies and Tracking

Our website uses cookies to improve user experience and understand usage patterns. For more information, please see our Cookie Policy.

Updates to this Policy

This Privacy Policy may be updated from time to time to reflect changes in legal obligations, technology, or our practices. We will notify users of material changes through appropriate channels.

If you have any questions or concerns regarding this policy or your personal data, please contact us on this form. Your query will go to the Data Protection Officer.

Terms and Conditions

Will be updated soon..

Kula Community Guidelines

Introduction

These guidelines are designed to foster a welcoming, inclusive, and secure community where members can engage respectfully and constructively.

Establishing clear guidelines helps ensure:

- A positive and respectful environment for all participants.
- Protection against potential risks and threats.
- A culture of respect, openness, and meaningful dialogue.

By adhering to these principles, we strengthen our community and promote responsible participation.

Safety and Protection

1. Secure Your Online Presence

- Use a strong, unique password for all accounts.
- Enable two-factor authentication (2FA) whenever possible.
- Keep your operating system, browser, and software updated.
- Avoid using public Wi-Fi or shared computers for sensitive transactions.
- Install reputable antivirus software and update it regularly.

2. Be Cautious with Transactions

- Verify authenticity before engaging in any cryptocurrency transactions.
- Be wary of unsolicited requests for personal or payment information.
- Never share private keys, passwords, or recovery phrases.
- Regularly monitor your accounts for suspicious activity.

3. Protect Your Cryptocurrency

- Store assets in a hardware wallet or a reputable software wallet.
- Use multi-signature wallets for added security.
- Set up cold storage for long-term holdings.
- Regularly back up and securely store wallet keys.

4. Recognize and Avoid Phishing Scams

- Be cautious of emails, messages, or calls requesting sensitive information.
- Verify communication by contacting the entity directly through official channels.
- Never respond to unsolicited messages that request payment or sensitive data.

5. Report Suspicious Activity

- Report phishing attempts, fraud, or security breaches to authorities.
- Alert Kula’s support team at hello@kuladao.io
- Share security insights with the community to help prevent attacks.

Community Guidelines

1. Respect Others

- Treat all community members with kindness, empathy, and dignity.
- Harassment, discrimination, or abuse will not be tolerated.

2. Encourage Open Discussions

- Be open to diverse perspectives and constructive debate.
- Avoid dismissive or inflammatory language.

3. Maintain Civility

- Use respectful language in all interactions.
- Do not spread misinformation, rumors, or personal attacks.

4. Follow Community Rules

Abide by moderation decisions and community standards.

5. No Self-Promotion

Do not promote personal projects/services without approval.

6. No Spamming

Avoid irrelevant, excessive, or repetitive content.

7. Moderators’ Discretion

Moderators have the final say in enforcing rules and removing content.

Consequences for Violations

1. Warning

A reminder to correct behaviour.

2. Content Removal

Deletion of posts/comments that violate guidelines.

3. Ban

Temporary or permanent suspension of an account.

If you experience harassment, report it to Kula moderators immediately using this form.

Kula Financial Risk Warning Statement

Kula operates a blockchain-based governance system that integrates real-world assets within a structured, compliant framework. Participation in the Kula ecosystem involves financial and governance-related risks. Before engaging with the Kula platform, token holders, investors, and community members should carefully review the following risk considerations:

1. No Financial Returns or Guarantees

$KULA is a governance token, not an investment vehicle. Holding $KULA does not entitle holders to profits, dividends, or financial returns.
The value of $KULA is determined by governance participation and ecosystem adoption, not by speculative financial mechanisms.

2. Market and Liquidity Risks

The cryptocurrency and blockchain sectors are highly volatile. The price of $KULA may fluctuate due to market conditions, governance decisions, regulatory changes, or macroeconomic factors.
Liquidity for $KULA is not guaranteed. Token holders may experience challenges in buying or selling tokens, depending on market conditions and exchange availability.

3. Regulatory and Compliance Risks

Kula operates within a legally structured framework but has not yet received formal regulatory approval from any financial authority.
Regulatory changes in different jurisdictions may impact the availability, usage, or legality of $KULA and Kula’s governance framework.
Participants are responsible for ensuring compliance with local laws and regulations regarding digital assets and governance participation.

4. Smart Contract and Security Risks

Kula employs audited smart contracts to manage governance, treasury, and ecosystem participation. However, no system is entirely immune to bugs, exploits, or vulnerabilities.
Participants should be aware that blockchain transactions are irreversible, and any errors or security breaches may result in permanent loss of tokens or funds.

5. Governance and Decision-Making Risks

Governance decisions within Kula are made through the Protocol Improvement Proposal (PIP) and/or KulaDAO Improvement Proposal (KIP) process, which means token holders actively shape the ecosystem.
Decisions made through governance voting may not always align with individual interests, and governance changes may impact the functionality or utility of the token.

6. No Consumer Protections or Insurance

Digital assets, including $KULA, are not covered by traditional financial insurance schemes (e.g., Federal Deposit Insurance Corporation, Financial Services Compensation Scheme, or deposit protection programs).
There is no guarantee of asset recovery in case of security breaches, exchange failures, or smart contract vulnerabilities.

7. Risk of Loss

Participation in the Kula ecosystem requires an understanding of blockchain governance, asset risks, and decentralized decision-making.
Only engage with Kula if you fully understand the risks involved and are prepared for potential financial loss.

8. Wallet Security & Self-Custody Risks

Kula tokens ($KULA) may be stored in centralised exchange (CEX) accounts or self-custodied in private wallets.
Users are solely responsible for the security of their wallets, private keys, and seed phrases. Losing access to a wallet or exposing private keys may result in permanent loss of funds, with no possibility of recovery.
Kula does not provide support for lost or stolen wallets and cannot intervene in unauthorized transactions.
Smart contract interactions carry risks - users should verify contract addresses and avoid phishing attempts or malicious dApps that could compromise their tokens.

Final Disclaimer

This financial risk warning is for informational purposes only and does not constitute financial, legal, or investment advice. Participants should conduct their own due diligence and seek professional advice before engaging with Kula.

Disclosure Statement for Whistleblowing

At Kula, we are committed to fostering a culture of transparency, integrity, and accountability. This disclosure statement outlines our Whistleblowing Policy, which provides a safe and confidential mechanism for reporting concerns about unethical, illegal, or improper conduct. We encourage all employees, contractors, and stakeholders to speak up without fear of retaliation.

1. Our Commitment

We are dedicated to maintaining the highest standards of ethical conduct and compliance with laws and regulations. To achieve this, we:

- Encourage the reporting of any suspected wrongdoing in good faith.
- Prohibit retaliation against whistleblowers who report concerns honestly and responsibly.
- Ensure all reports are investigated promptly, thoroughly, and impartially.

2. What Can Be Reported

You can report concerns related to, but not limited to:

- Fraud, theft, or embezzlement.
- Bribery or corruption.
- Financial misconduct.
- Violations of laws or regulations.
- Discrimination or harassment.
- Health and safety hazards.
- Environmental violations.
- Any other unethical or illegal conduct.

3. How to Report

You can report concerns through the following channels:

- Compliance Officer: Directly to the designated Compliance Officer.
- Supervisor or Manager: To your immediate supervisor or a member of the Executive or Senior Executive Team.
- Kula Supervisory Court: If the concern involves the Compliance Officer or Executive Team, you may approach the Kula Court.
- Anonymous Reporting: Through our anonymous reporting hotline or online platform.

Reports should include as much detail as possible, such as the nature of the concern, the individuals involved, and any supporting evidence. Reports can be made anonymously, and confidentiality will be maintained to the extent possible.

4. Investigation Process

All reports will be:

- Acknowledged promptly.
- Investigated thoroughly and impartially.
- Resolved with appropriate corrective action.
- Kept confidential, with information shared only on a need-to-know basis.

Whistleblowers will be kept informed of the progress and outcome of the investigation, where possible, without compromising confidentiality or the integrity of the process.

5. Protection for Whistleblowers

We strictly prohibit retaliation or adverse treatment against individuals who report concerns in good faith. If you believe you have faced retaliation, you should report it immediately to the Compliance Officer or another member of management. Retaliation will not be tolerated and may result in disciplinary action, including termination of employment or contract.

6. Confidentiality

All reports will be treated with the utmost confidentiality. Information will only be disclosed to those who need to know to conduct the investigation or take corrective action.

7. Training and Awareness

We provide regular training to employees, contractors, and representatives to ensure they understand their rights and responsibilities under this policy. Senior Management is committed to promoting a culture of integrity, transparency, and ethical conduct.

8. Your Role

- Report concerns in good faith and with as much detail as possible.
- Do not attempt to investigate the concern yourself.
- Maintain confidentiality and avoid discussing the issue with colleagues or third parties unless required by law or the investigation process.

9. Contact Us

If you have any questions about this policy or wish to report a concern, please contact us using this form. Your query will be directed towards the Compliance Officer.

Disclosure Statement for Customer Complaints

At Kula, we are committed to providing exceptional service to our clients. However, we recognize that issues may occasionally arise, and we take all complaints seriously. This disclosure outlines our process for handling and resolving complaints in a fair, transparent, and timely manner.

Our Commitment

We strive to address all complaints promptly, impartially, and in accordance with applicable laws and regulations. Your satisfaction and trust are our top priorities, and we are dedicated to resolving any concerns you may have.

How to Lodge a Complaint

If you have a complaint, you can raise it through the following channels:

In Writing

Send an email to hello@kuladao.io.

Online

Submit your complaint through our website

Our Complaint Handling Process

1. Acknowledgment:

We will acknowledge receipt of your complaint within one week and provide you with a reference number for tracking purposes.

2. Investigation:

Your complaint will be assigned to a dedicated complaints handler who will conduct a thorough investigation. We will consider all relevant information and documentation to ensure a fair resolution.

2. Investigation:

Your complaint will be assigned to a dedicated complaints handler who will conduct a thorough investigation. We will consider all relevant information and documentation to ensure a fair resolution.

2. Investigation:

Your complaint will be assigned to a dedicated complaints handler who will conduct a thorough investigation. We will consider all relevant information and documentation to ensure a fair resolution.

3. Communication:

We will keep you informed of the progress of your complaint and provide an estimated timeline for resolution.

4. Resolution:

Once the investigation is complete, we will provide you with a written response detailing the outcome and any proposed resolution.

Escalation Process

If you are dissatisfied with the outcome or handling of your complaint, you may escalate it:

1. Internally:

Request a review by a senior manager or our designated complaints escalation team.

2. Externally:

Lodge a complaint with the relevant regulatory authority or ombudsman service.

Monitoring and Improvement

We monitor complaint trends and outcomes to identify areas for improvement and ensure compliance with regulatory requirements. All complaints are recorded and maintained for as long as legally required under the Mauritian Data Protection Act (2017)

Your Rights

- You have the right to lodge a complaint if you are dissatisfied with any aspect of our services.
- You have the right to a fair, transparent, and timely resolution process.
- You have the right to escalate your complaint if you are not satisfied with the outcome.

For further information about our complaints process or to lodge a complaint, please contact us using this form.

Disclosure Statement for Marketing Financial Products

Kula is committed to providing clear, fair, and transparent information about our financial products and services. In accordance with the Guidelines for Advertising and Marketing of Financial Products issued by the Financial Services Commission (FSC) of Mauritius, we adhere to the following principles:

1. Accuracy and Clarity

All information provided in our marketing materials is accurate, clear, and not misleading. We ensure that all terms, conditions, risks, and benefits of our financial products are disclosed in a manner that is easy to understand.

2. Fair Representation

Our advertisements and marketing communications fairly represent the features, risks, and costs associated with our financial products. We do not exaggerate benefits or omit material information that could influence your decision.

3. Target Audience

Our marketing materials are designed to be appropriate for the intended audience. We take care to ensure that our communications are suitable for the knowledge, experience, and financial situation of the consumers we are addressing.

4. Risk Disclosure

All material risks associated with our financial products are clearly disclosed. We emphasize that past performance is not indicative of future results, and the value of investments may go up or down.

5. Compliance with Regulations

Our marketing practices comply with all applicable laws, regulations, and guidelines set forth by the FSC and other relevant authorities in Mauritius.

6. No Guarantees

We do not guarantee specific outcomes or returns unless explicitly stated and supported by contractual agreements. Any projections or forecasts are clearly labelled as such and are based on reasonable assumptions.

7. Consumer Responsibility

We encourage consumers to carefully read all product documentation, including terms and conditions, before making any financial decisions. If you have any questions or require further clarification, please contact us directly.

Contact Information

For more information about our financial products or services, or if you have any concerns about our marketing materials, please contact us using this form. Your query will be directed towards our Finance Officer.

Disclosure Statement for Fair Treatment of Customers

At Kula, we are committed to treating all our customers with fairness, integrity, and respect. Our Fair Treatment of Customers Policy reflects our dedication to ensuring that your interests are always prioritized in every interaction with us. Below, we outline the key principles and practices that guide our commitment to fair treatment:

1. Transparency

We provide clear, accurate, and comprehensive information about our products, services, and pricing to help you make informed decisions.

2. Fairness

Our products, services, and terms are designed to be fair and reasonable, ensuring that no customer is unfairly disadvantaged.

3. Non-Discrimination

We treat all customers, partners, and community members with respect and dignity without discrimination based on race, gender, age, religion, disability, or any other personal characteristic.

4. Compassionate Service

We take extra care to protect vulnerable customers, ensuring their needs are prioritized over profit. This includes providing additional support for those who may face challenges due to age, literacy, financial sophistication, or other personal circumstances.

5. Accessibility

We strive to make our products and services accessible to all customers, regardless of their personal circumstances or characteristics, to the extent permitted by law.

6. Data Security

We are committed to safeguarding your personal information in line with our Information Security Policy and applicable data protection laws, including GDPR.

7. Excellence of Service

We respond to complaints and feedback promptly and fairly, using your input to continuously improve our products, services, and customer interactions.

8. Responsiveness

We are here to help. Our team is trained to respond to your inquiries, concerns, and feedback with professionalism, empathy, and efficiency.

9. Prioritising Clients

Your needs come first. We place your interests above short-term business gains and are committed to a win-win approach in all our dealings.

10. Confidentiality

We respect your privacy and will only use your information for legitimate business purposes in compliance with applicable privacy laws and regulations.

Our Promise to You

We are dedicated to fostering long-term relationships built on trust, transparency, and mutual respect. Our zero-tolerance policy for discrimination, deception, or unethical practices ensures that your rights and dignity are always protected. We welcome your feedback and are committed to addressing any concerns promptly and fairly.

For more information about our Fair Treatment of Customers Policy, or if you have any questions or concerns, please contact us using this form. Your query will be directed towards our Compliance Officer.

Disclosure Statement for Market Offenses

At Kula, we are committed to upholding the highest standards of market integrity and ensuring compliance with the Mauritius Financial Services Commission (FSC) regulations and international best practices. Our Market Offences Policy reflects our dedication to promoting fair, orderly, and transparent virtual asset trading. Below, we outline the key principles and practices that guide our commitment to preventing market offences:

1. Prohibition of Market Abuse

We strictly prohibit all forms of market abuse, including insider trading, unlawful disclosure of material non-public information (MNPI), and market manipulation. Our zero-tolerance stance ensures that all employees, contractors, and associated individuals adhere to ethical market conduct.

2. Insider Trading

We prohibit the use of MNPI for personal gain or to benefit others. Our internal controls, including "Chinese walls" and information barriers, ensure that sensitive information is handled appropriately and not misused.

3. Unlawful Disclosure

We ensure that MNPI is only disclosed with proper authorization and in compliance with legal and regulatory requirements. Unauthorized disclosure, whether intentional or unintentional, is strictly prohibited.

4. Market Manipulation

We do not engage in practices that distort market prices, create false signals, or deceive investors. This includes avoiding fictitious trades, disseminating false information, or using manipulative algorithms.

5. Market Sounding

When conducting market soundings for new token issuances, we ensure that all parties involved provide consent and adhere to confidentiality obligations. We maintain detailed records of all market soundings and promptly inform parties when information is no longer considered confidential.

6. Detection and Reporting

We implement robust monitoring systems to detect potential market offences. Employees, clients, and stakeholders are encouraged to report suspicious activities through our whistleblower mechanisms. All reports are investigated promptly, and any confirmed offences are reported to the FSC and other relevant regulatory authorities.

7. Training and Awareness

We provide regular training to employees and stakeholders on market offences, information handling, and ethical market conduct. This ensures that everyone associated with Kula understands their responsibilities and complies with our policies.

8. Investigation and Enforcement

We conduct thorough internal investigations into any reported market offences and fully cooperate with external regulatory investigations. Corrective actions are taken to address any violations and prevent future occurrences.

Our Promise to You

We are dedicated to fostering an ethical culture that prioritizes investor protection and market integrity. By adhering to our Market Offences Policy, we ensure that all market activities are conducted with transparency, fairness, and compliance. If you have any questions or concerns about our market conduct, please contact us using this form. Your query will be directed towards our Compliance Officer.

Disclosure Statement for Information Security

At Kula, we are committed to maintaining the highest standards of information security to protect the confidentiality, integrity, and availability of your sensitive information. Our Information Security Policy reflects our dedication to safeguarding your data and ensuring compliance with applicable laws, regulations, and industry standards. Below, we outline the key principles and practices that guide our commitment to information security:

1. Confidentiality, Integrity, and Availability

We implement robust technical, administrative, and physical controls to protect your information from unauthorised access, disclosure, alteration, or destruction.

2. Information Classification

We classify information based on its sensitivity and apply appropriate security controls to ensure its protection. This includes adhering to the Mauritian Data Protection Act (2017) and EU GDPR requirements for personal data.

3. Access Controls

We restrict access to sensitive information based on the principle of least privilege, ensuring that only authorised personnel can access your data.

4. Encryption

We use encryption for data in transit and at rest to protect against unauthorised interception or disclosure.

5. Network and Endpoint Security

We employ firewalls, intrusion detection/prevention systems, antivirus software, and other security measures to protect against external threats and malware.

6. Secure Coding and Vulnerability Management

We follow secure coding practices and regularly address software vulnerabilities to mitigate risks.

7. Physical Security

We implement access controls, surveillance, and environmental measures to protect our physical facilities and assets.

8. Business Continuity and Disaster Recovery

We have plans in place to ensure the availability and resilience of critical systems and services in the event of a disruptive incident.

9. Incident Response

We maintain a robust incident response process to promptly detect, respond to, and mitigate information security incidents. This includes timely reporting and communication to relevant stakeholders.

10. Third-Party Security

We assess the security posture of third-party vendors/outsourced service providers and ensure they meet our information security requirements, including data protection and confidentiality.

11. Training and Awareness

We provide regular training to employees and stakeholders to raise awareness of information security risks and promote a culture of security.

Our Promise to You

We are dedicated to fostering an ethical culture that prioritizes investor protection and market integrity. By adhering to our Information Security Policy, we ensure that all market activities are conducted with transparency, fairness, and compliance. If you have any questions or concerns about our market conduct, please contact us using this form. Your query will be directed towards our Information Security Officer.

Disclosure Statement for Data Protection and Retention

At Kula, we are committed to protecting your privacy and ensuring the security of your personal data. This disclosure statement outlines how we collect, use, store, and protect your personal information in compliance with the Mauritian Data Protection Act (2017) and other applicable regulations. By using our services, you agree to the practices described in this statement:

1. Collection of Personal Data

We collect personal data to provide you with our services and to comply with legal and regulatory obligations. The types of personal data we collect may include but are not limited to:

- Identification information: Name, contact details, identification numbers, and nationality.
- Financial information: Transaction details and payment information.
- Technical information: IP addresses, device information, and browsing activity.
- Other information: Information provided through social media, testimonials, or surveys.

2. Use of Personal Data

Your personal data is used for the following purposes:

- To provide and improve our services.
- To comply with legal and regulatory requirements, including anti-money laundering (AML) and counter-terrorism financing (CFT) obligations.
- To communicate with you, including sending marketing materials (with your consent).
- To protect against fraud, unauthorized access, and other risks.

When transferring data outside Mauritius, we ensure that appropriate safeguards, such as standard contractual clauses, are in place to protect your information.

3. Data Sharing and Transfers

We may share your personal data with:

- Service providers: Third parties who assist us in delivering our services, such as cloud storage providers and marketing platforms.
- Regulatory authorities: When required by law or to protect public interest.
- Other third parties: With your consent or as necessary to fulfil contractual obligations.

4. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected or as required by law. For example:

- Customer and transaction data: Retained for as long as necessary to comply with legal obligations, resolve disputes, and enforce agreements.
- AML/CFT records: Retained for eight (8) years after the end of the business relationship or occasional transaction.
- Marketing data: Retained until you opt out or withdraw your consent.

5. Your Rights

You have the following rights regarding your personal data:

- Access: Request a copy of the personal data we hold about you.
- Rectification: Request corrections to inaccurate or incomplete data.
- Erasure: Request deletion of your data, subject to legal obligations.
- Restriction: Request restriction of processing under certain circumstances.
- Portability: Request your data in a structured, machine-readable format.
- Objection: Object to the processing of your data for direct marketing or other purposes.
- Withdraw Consent: Withdraw consent at any time, where processing is based on consent.

To exercise these rights, please contact us at disclosures@kuladao.io

6. Data Security

We implement robust technical and organizational measures to protect your personal data from unauthorized access, loss, or destruction. These measures include encryption, access controls, and regular audits. However, no system is completely secure, and we cannot guarantee absolute security.

7. Data Breaches

In the event of a data breach, we will notify the Mauritian Data Protection Office and affected individuals without undue delay, as required by law.

8. Changes to This Statement

We may update this disclosure statement periodically to reflect changes in our practices or legal requirements. Any updates will be communicated to you through our website or other appropriate channels.

If you have any questions about this disclosure statement or wish to exercise your rights, please contact us using this form. Your query will be directed towards our Data Protection Officer.

Disclosure Statement for Conflicts of Interest

At Kula, we are committed to maintaining the highest standards of integrity, transparency, and ethical conduct in all aspects of our business operations. As part of this commitment, we have established a robust **Conflicts of Interest Policy** to ensure that the interests of our clients and stakeholders are always prioritized.

Our Commitment

We recognize that conflicts of interest may arise during our business activities. A conflict of interest occurs when our interests, or those of our employees, directors, or affiliates, could potentially compromise the fair treatment of our clients or the integrity of our operations. We are dedicated to identifying, managing, and mitigating such conflicts to protect the interests of our clients and maintain trust in our services.

How We Manage Conflicts of Interest

1. Identification and Reporting

All employees, directors, and contractors are required to promptly disclose any actual, potential, or perceived conflicts of interest to the designated Compliance Officer. This includes personal, financial, or professional relationships that could influence decision-making.

2. Assessment and Mitigation

Each disclosed conflict is assessed on a case-by-case basis. Where necessary, we implement appropriate measures to manage or mitigate the conflict, such as:

- Disclosing the conflict to affected clients and obtaining their informed consent.
- Recusing individuals from decision-making processes where a conflict exists.
- Establishing internal controls, such as segregation of duties or information barriers, to prevent undue influence.

3. Transparency and Disclosure

In cases where a conflict cannot be fully mitigated, we will provide clear and comprehensive disclosures to affected clients. This ensures that clients are fully informed of the nature of the conflict and any potential risks before proceeding with a transaction or service.

4. Prohibition of Undue Influence

Employees are prohibited from engaging in activities or transactions that could create or appear to create a conflict of interest. This includes conducting business with family members, close friends, or related parties without prior approval.

5. Ongoing Monitoring and Training

We provide regular training to all staff on identifying and managing conflicts of interest. Additionally, we maintain a **Conflicts of Interest Register** to document and monitor all disclosed conflicts and the measures taken to address them.

Your Rights as a Client

- You have the right to be informed of any conflicts of interest that may affect the services we provide to you.
- You have the right to make informed decisions about whether to proceed with a transaction or service after being made aware of any conflicts.
- If you have any concerns about a potential conflict of interest, please contact us using this form.

For further information about our Conflicts of Interest Policy or to report a concern, please contact us using this form. Your query will be directed towards our Compliance Officer.

IEO Begins In

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Connecting financial empowerment with sustainable economic resilience.

Shaping a future built on shared prosperity.