Digicel Vendor/Supplier Privacy Notice

Introduction

At Digicel, we are committed to protecting the privacy and security of personal data.

This Privacy Notice explains how Digicel collects and processes personal data in connection with our relationship with potential or existing vendors, suppliers, contractors, and business partners (collectively, “Vendors”). It applies to individuals acting on behalf of Vendors, including owners, employees, officers, directors, contractors, and representatives (collectively “Authorised Representatives”).

1.            Data Controller

The entities listed in Table 2 below (collectively and individually, “Digicel”, "we", "us" or "our" in this privacy notice), are the data controllers of personal data processed during Digicel’s due-diligence, onboarding, contracting, and ongoing relationship management activities. The applicable Digicel data controlling entity for your personal data will depend on the relevant engagement, including the entity conducting the due-diligence or contracting process, and the jurisdiction in which services are proposed or delivered.  All entities listed are subsidiaries of the Digicel Group of Companies (“Digicel Group”).

We have a Group Privacy Team that handles enquiries relating to the privacy practices of the Digicel Group. If you would like to enquire about this privacy notice, our privacy practices or your legal rights, you may contact our Privacy Team using the details set out at Item 13 below.

2.            Scope of This Notice

Purpose of this Privacy Notice and When it Applies

This Privacy Notice applies to personal data collected from you as an Authorised Representative of a Vendor. It explains how Digicel processes your personal data during our due-diligence or onboarding exercises when you use or interact with our E&C Due Diligence Questionnaire or any other activity in support of the engagement between the Vendor and Digicel, including any background checks.

3.            The Data We Collect About You

Personal data, or personal information, means any information about an individual from which that person can be identified. Depending on your country or market, this definition may also extend to personally identifiable information for individuals who have been deceased for less than thirty (30) years. Personal data shall not be extended to or include any data where identifiable information has been removed (anonymous data) or where an individual cannot be identified by the data set.

Personal data is collected from all Authorised Representatives of our Vendors for the performance of a contract or to conduct the due-diligence process. We may collect, use, store and transfer different kinds of personal data about you, which we have grouped together below. The information we collect about you and how we collect it may vary depending on the services the Vendor provides and the country in which the vendor operates.

• Identity Data includes full name; copies of your photo identification card (and any personal information thereon, including date of birth, gender, tax registration number/ social security number or other global equivalents).

• Contact Data includes email address; telephone numbers.

• Job-related and (work) organisation Data includes company name; company address; occupation; job role/title; shareholdings; company tax registration number; company registration documents.

• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

• Other Data such as relationships with Digicel staff, exposure to sanctioned territories, politically exposed status, criminal history and any other information deemed necessary for any of the purposes noted under Section 4, which may be collected from our Internal and External Third Parties, as defined in the Glossary, with or upon your consent.

We do not intentionally seek to collect any Special Categories of Personal Data about you. Special Categories of Personal data may include details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data. We will update you if any of our processing activities will require the collection of any Special Categories of Personal Data and request your permission to do so.

If you fail to provide personal data

Where we need to collect personal data by law, pre-contracting due-diligence activities, or under the terms of a contract and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you.

4.            How is Your Personal Data Collected?

We use different methods to collect data from and about you including through:

• Direct Interactions, where information is collected directly from you, or your activities, with your consent, including when you complete our E&C Due Diligence Questionnaire or otherwise interact the Digicel team.

• Third Parties or Publicly Available Sources. We may receive and/or share any personal data about you deemed necessary for any of the purposes noted under Section 4. Generally, we receive or share your personal data from and/or with various public sources, and our Internal, External and Specific Third Parties, as defined in the Glossary, once we have your consent.

5.            How We Use Your Personal Data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data where:

• we need to perform the contract we are about to enter into or have entered into with you.

• It is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

• we need to comply with a legal obligation such as law enforcement disclosures or meeting regulatory obligations that are subject to strict internal policies and procedures (such as retention periods).

• you provide consent to the use of your information. Consent may be withdrawn at any time by notifying us or by terminating or cancelling the contract with us.

Purposes for Which We Will Use Your Personal Data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, which of the legal bases we rely on to do so, and where appropriate, what our legitimate interests are.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground(s) we are relying on to process your personal data where more than one ground has been set out in the table below.

Table 1: Purposes for use of your personal data

Marketing

Where applicable, we strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

We will get your consent before we share your personal data with any third party for marketing purposes.

Promotional Offers from Us

For some engagements with vendors, that involve a partnership or joint venture for the production and supply of goods and services, we may use the data we gather to form a view on what we think you, as an Authorised Representative, may want or need, or what may be of interest to your company. This is how we decide which products, services, solutions and offers may be relevant to enter into further engagements (we call this marketing).

You may receive marketing communications from us as an Authorised Representative of the company, for the Vendor, if you have requested information from us, and you have not opted out of receiving direct marketing communications.

Opting Out

You can ask us to stop sending you marketing messages at any time by following the opt-out links, directions on any marketing message sent to you, or via contact to an Agent or your Digicel Account Executive or other representative, to request to be removed from direct marketing email communications.

Where you opt out of receiving these marketing messages, this will not apply to any system or functional messaging regarding the performance of a contract with your company.

6.            Disclosures of Your Personal Data

We may share your personal data with the parties set out below for the purposes set out in the Table 1: Purposes for use of your personal data above.

• Internal Third Parties as set out in the Glossary.

•  External Third Parties as set out in the Glossary.

•  Specific Third Parties as set out on our Digicel Third-Party Providers List.

•  Third Parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

7.            International Transfers

We may share your personal data within entities throughout the Digicel Group of Companies.

Whenever we transfer your personal data out of the country of origin, however, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.

• Where we use certain service providers, we may use special contracts that ensure that an adequate level of protection through the use of technical and organisational measures.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data internationally.

8.            Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

9.            Data Retention

How Long Will You Use My Personal Data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Details of retention periods for different aspects of your personal data are available in our retention schedule which you can request from us by contacting us at privacy@digicelgroup.com.

10.          Your Legal Rights

In some countries and under certain circumstances, you have rights in relation to your personal data. You may have the right to:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

• If you want us to establish the data's accuracy.

• Where our use of the data is unlawful but you do not want us to erase it.

• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.

• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

If you wish to enquire about or exercise any of the rights set out above, visit our Privacy & Trust Centre or contact the Privacy Team at privacy@digicelgroup.com.

What We May Need from You

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time Limit to Respond

We try to respond to all legitimate requests within sixty (60) days. Occasionally, it could take us longer than sixty (60) days if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

11.          Glossary

i.      LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

 Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

 Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

ii.    THIRD PARTIES

 Internal Third Parties

Other companies in the Digicel Group may act as joint controllers or processors, and may provide IT and system administration services, and/or process personal data through leadership reporting. The list includes:

Table 2: List of Data Controllers/ Digicel Affiliates

External Third Parties

• Service providers acting as processors who provide IT and system administration services.

•  Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.

•  Relevant regulators and other authorities as required by law (that may be acting as processors or joint controllers), who may require reporting of processing activities in certain circumstances.

Specific Third Parties

Table 3: Specific Third Parties and their Services

12.          Changes to the Privacy Notice and Your Duty to Inform Us of Changes

We endeavour to keep our Privacy Notice under annual review. This version was last updated on 14 April 2026.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

13.          How to Contact Us in Relation to Our Privacy Practices

For all comments, concerns and complaints regarding this notice, our privacy practices, or to exercise your privacy rights, you may contact the Privacy Team via the following means:

• E-mail: privacy@digicelgroup.com

• Website: Privacy & Trust Centre