Fuzu Service Terms — Nigeria Addendum

This Nigeria Addendum ("Addendum") forms part of the Fuzu Service Terms (the "Global Terms") and applies to Users who access or use the Service from Nigeria, Users who direct Content to Nigeria, Employers and other Business Users registered or operating in Nigeria, and any other engagement that falls within the scope of Nigerian law.

The Global Terms apply in full to Nigerian Users. Where there is a conflict between the Global Terms and this Addendum on a matter specifically addressed in this Addendum, this Addendum prevails. Capitalised terms used in this Addendum have the meanings given in the Global Terms unless defined otherwise here.

The Service is operated globally by Fuzu Ltd, a company registered in Helsinki, Finland (business ID FI25462252). For Nigeria-related matters, Fuzu Nigeria Ltd, a company registered in Nigeria with the Corporate Affairs Commission under registration number 185795 and registered address at 48, Awolowo Road, Ikoyi, Lagos State, Nigeria (the "Local Affiliate"), operates as the local contracting party in respect of Nigeria-specific commercial agreements and as the local data controller in respect of Nigerian operations of the Service (as further described in the Privacy Policy — Nigeria Addendum).

Where a Local Affiliate is the contracting party (for example, under a Nigeria-specific commercial agreement, employer subscription, or local services arrangement), this will be stated in the relevant order form or commercial agreement, and references to "Fuzu" in such arrangements include the Local Affiliate.

Local contact details:

• Local support: www.fuzu.com/nigeria/contact or support@fuzu.com
• Local complaint contact: legal@fuzu.com

3.1 Applicable law

To the extent that Fuzu processes personal data of Users in Nigeria or in the course of operating the Service in Nigeria, Fuzu complies with the Nigeria Data Protection Act, 2023 (the "Nigeria DPA"), the Nigeria Data Protection Regulation, 2019 (to the extent it remains in force), and the standards, guidance, and directives issued by the Nigeria Data Protection Commission (the "NDPC"). The Privacy Policy — Nigeria Addendum sets out further information about Fuzu's processing of personal data of data subjects in Nigeria.

3.2 NDPC registration, DPCO and Data Protection Officer

Fuzu Nigeria Ltd is the local data controller for Nigerian operations and is responsible for NDPC registration and engagement of a licensed Data Protection Compliance Organisation ("DPCO") where required by the Nigeria DPA. Registration details and DPCO engagement will be set out in the Privacy Policy — Nigeria Addendum once confirmed.

Fuzu Nigeria Ltd has appointed a Data Protection Officer for Nigeria, contactable at privacy@fuzu.com.

3.3 Rights of data subjects in Nigeria

Data subjects in Nigeria have the rights set out in Part VI of the Nigeria DPA. These rights are described in detail in the Privacy Policy — Nigeria Addendum.

3.4 Cross-border transfers

Personal data of Users in Nigeria may be transferred outside Nigeria as described in the Privacy Policy — Nigeria Addendum, in accordance with Part IX of the Nigeria DPA and the NDPC's directives on cross-border data transfers.

3.5 Complaints to the NDPC

Users in Nigeria have the right to lodge a complaint with the NDPC via ndpc.gov.ng or to the NDPC at its current registered address. Users are encouraged to contact Fuzu first using the contact details above so that Fuzu may attempt to address the matter directly.

4.1 Compliance by Employers

Employers and other Business Users using the Service in connection with recruitment in Nigeria must comply with applicable Nigerian employment and labour law, including the Labour Act (Cap. L1, Laws of the Federation of Nigeria, 2004); the Employee's Compensation Act, 2010; the Pension Reform Act, 2014; the National Industrial Court Act, 2006; the National Health Insurance Authority Act, 2022; and any regulations, guidelines, or directives made under those laws or by the Federal Ministry of Labour and Employment.

4.2 Anti-discrimination

Employers and other Business Users using the Service in Nigeria must comply with the anti-discrimination provisions of the Constitution of the Federal Republic of Nigeria, 1999 (as amended), the Discrimination Against Persons with Disabilities (Prohibition) Act, 2018, the HIV and AIDS (Anti-Discrimination) Act, 2014, and the Violence Against Persons (Prohibition) Act, 2015 (where applicable). Employers must not discriminate against any User or Candidate, directly or indirectly, on grounds including ethnic group, place of origin, sex, religion, political opinion, disability, health status, age, or other status protected by Nigerian law, except where the distinction is justified by an inherent requirement of the position and is otherwise permitted by law.

4.3 Recruitment licensing and overseas placements

Employers and other Business Users using the Service to operate as private employment agencies or to facilitate recruitment for overseas placements in Nigeria acknowledge that such activities may require licensing or authorisation from the Federal Ministry of Labour and Employment, the Nigerians in Diaspora Commission, or other competent Nigerian authorities. Fuzu and its Business Users will cooperate as required to ensure compliance with applicable licensing and authorisation requirements, and Fuzu may decline to facilitate engagements where the necessary compliance steps have not been completed.

Users considering overseas placements are advised to verify that the placing entity holds any licence or authorisation required under Nigerian law and that the engagement complies with applicable bilateral labour agreements, where relevant.

5.1 Applicable law

Nigerian Users who are consumers within the meaning of the Federal Competition and Consumer Protection Act, 2018 (the "FCCPA") have the rights granted by that Act in addition to any rights set out in the Global Terms. Nothing in the Global Terms or this Addendum limits any non-waivable right granted by Nigerian consumer-protection law.

5.2 Right to cancel and refunds

Where the FCCPA or related regulations grant a right of cancellation, refund, or remedy in respect of paid Services purchased by a Nigerian consumer, that right applies in addition to the consumer right of withdrawal set out in Section 20 of the Global Terms.

5.3 Complaints

Nigerian consumers may submit complaints to Fuzu using the local complaint contact in Section 2 of this Addendum or, in addition, to the Federal Competition and Consumer Protection Commission (FCCPC) or, where relevant, to a sector-specific regulator.

6.1 Payment methods

Fuzu may make available payment methods commonly used in Nigeria, including bank transfers, card payments, and mobile money or wallet services provided by payment service providers licensed by the Central Bank of Nigeria ("CBN") under the Banks and Other Financial Institutions Act, 2020 and the CBN's regulations on payment services. Use of any such payment method is subject to the terms of the relevant payment service provider in addition to the Global Terms.

6.2 Currencies and foreign exchange

Fees may be charged in Nigerian Naira (NGN), Euros (EUR), or US Dollars (USD), as indicated at the point of purchase. Cross-border payments from or to Nigeria are subject to the foreign-exchange rules administered by the CBN, including the rules in the CBN Foreign Exchange Manual and applicable circulars. Exchange-rate movements between order date and payment date are at the User's risk unless otherwise stated.

6.3 Taxes

Fees are stated exclusive of applicable taxes unless otherwise stated. Value Added Tax (VAT) administered by the Federal Inland Revenue Service (FIRS), and any applicable digital-economy tax, will be added to fees where required by law. Employers and other Business Users are responsible for their own PAYE, withholding tax, pension contributions, NHIA contributions, NSITF contributions, and other employer or recruiter tax and statutory obligations under Nigerian law in respect of any engagement of Candidates.

Employers and other Business Users that are companies registered in Nigeria represent and warrant that they are duly incorporated and in good standing under the Companies and Allied Matters Act, 2020, and that the persons accepting these Terms on their behalf are duly authorised to do so. Foreign Employers operating in Nigeria are responsible for ensuring that their activities in Nigeria comply with applicable rules on foreign direct investment, business registration, and tax registration.

The Global Terms are governed by Finnish law. Notwithstanding this, where a Nigerian consumer has rights under mandatory Nigerian law (including the FCCPA and the Nigeria DPA) that cannot be derogated from by agreement, those rights apply. A Nigerian consumer may bring proceedings against Fuzu in the courts of Nigeria where required by mandatory Nigerian law, in addition to any rights under the Global Terms.

For Business Users in Nigeria, the governing law and dispute-resolution provisions of the Global Terms apply unless otherwise agreed in writing. Disputes between Business Users in Nigeria and Fuzu may, where the parties agree in writing, be referred to arbitration in accordance with the Arbitration and Mediation Act, 2023, seated in The Lagos Court of Arbitration (LCA).

The Service is provided in English. The English version of these Terms and of this Addendum is the authoritative version.

For Nigeria-specific questions about these Terms, the Privacy Policy, or the Service, please contact Fuzu using the local contact details in Section 2 of this Addendum.