1. Introduction
Kaoko Green Energy Solutions ('Kaoko', 'we', 'us', or 'our') is a Namibian clean-energy startup developing green hydrogen-based clean cooking technologies, independent power producer (IPP) infrastructure, and Power-to-X solutions under the SKORPIoN Alternative Fuels project. To facilitate international capital raising, Kaoko operates through Kaoko GES Holdings, Inc., a holding company incorporated in the State of Delaware, United States.
This Privacy Policy describes how we collect, use, store, and protect personal information when you visit our website, engage with our investor relations processes, or otherwise interact with us digitally. It applies to all individuals who interact with Kaoko regardless of their location.
We are committed to handling personal information with transparency and care, and to complying with applicable data protection laws across the jurisdictions in which we operate — including Namibia, the United States, and, where relevant, the European Union.
2. Who We Are
The data controller responsible for your personal information is Kaoko Green Energy Solutions, headquartered in Windhoek, Namibia. For investor-related processing connected to our Delaware holding structure and international capital markets activities, Kaoko GES Holdings, Inc. may also act as a data controller.
Where we engage third-party service providers to process data on our behalf — such as virtual data-room platforms, cloud infrastructure providers, or communication tools — those providers act as data processors under written agreements that bind them to equivalent privacy obligations.
Privacy Officer Contact: privacy@kaoko.energy
3. Information We Collect
3.1 Information You Provide
We collect personal information when you voluntarily submit it to us, including your name, job title, organisation, email address, telephone number, and business address when you complete a contact or inquiry form. For investor-related interactions, we may also collect investor classification details, jurisdiction of residence, accredited investor declarations, and Know Your Customer documentation as required by applicable securities regulations. We retain any correspondence, documents, or messages you send us.
3.2 Information Collected Automatically
When you visit our website, our hosting infrastructure may collect certain technical data automatically. This includes your IP address (which may be pseudonymised), browser type, operating system, referring web page, pages visited, and timestamps. This information is used for security monitoring and to understand how our website is being used.
3.3 Information From Third Parties
In the context of investor onboarding and due diligence, we may receive information about you from background-check providers, financial intermediaries, transaction advisors, or co-investors who have obtained your consent to share your details with us. We may also reference publicly available professional information from platforms such as LinkedIn where you have made your profile public.
3.4 A Note on the AI Era
We operate in an era where artificial intelligence is increasingly embedded in digital services, data analysis, and business workflows. Kaoko takes this context seriously. We do not use AI systems to make automated decisions about individuals — including investor assessments, access approvals, or any determination that has a legal or similarly significant effect on you. Where AI-assisted tools may be used on our platform to help visitors navigate project information or answer general inquiries, those interactions are clearly disclosed and are informational only. Kaoko remains responsible for all decisions affecting individuals. We select and work with technology providers who uphold responsible AI standards, and we monitor AI tools for accuracy, bias, and compliance with applicable data protection law. Your data will never be used to train third-party AI models without your explicit consent.
4. Legal Basis for Processing
We process personal data only where we have a valid legal basis. We rely on contractual necessity where processing is required to fulfil an investor agreement or respond to a service request. We rely on legitimate interests for website security monitoring and basic analytics, where those interests are not overridden by your rights. We rely on legal obligation where processing is required under anti-money-laundering, Know Your Customer, or securities disclosure regulations. Where we send marketing communications or place non-essential cookies, we rely on your consent, which you may withdraw at any time without affecting the lawfulness of prior processing.
5. How We Use Your Information
We use personal information for the following purposes:
• To communicate project updates, respond to investor inquiries, and facilitate due diligence and data-room access in connection with Kaoko's capital-raising activities.
• To verify the identity and accreditation status of prospective investors as required under applicable securities and financial regulations.
• To operate and maintain the security of our website and digital infrastructure.
• To understand how visitors use our website and improve its content and performance through aggregated, pseudonymised analytics.
• To respond to contact form submissions, press inquiries, and partnership proposals.
• To comply with our legal and contractual obligations, enforce our Terms of Use, and cooperate with regulatory or legal proceedings.
6. Sharing of Personal Information
We do not sell, rent, or commercially license personal information to third parties under any circumstances.
We may share your information with service providers who assist us in operating our business, including cloud hosting providers, virtual data-room platforms, email infrastructure services, and cybersecurity tools. All such providers are bound by written data processing agreements. We may also share information with financial advisors, legal counsel, and technical advisors engaged in Kaoko's fundraising transactions, under strict confidentiality obligations. Where you are a named party to a transaction, relevant information may be shared with development finance institutions or co-investors with your knowledge.
We will disclose personal information to regulatory authorities, tax bodies, securities regulators, or law enforcement where required by law or court order. In the event of a merger, acquisition, or corporate restructuring involving Kaoko or its holding entities, personal information may be transferred to the successor entity subject to equivalent privacy protections.
7. Data Retention
We retain personal information only for as long as necessary to fulfil the purposes described in this Policy or as required by applicable law. Investor KYC and onboarding records are retained for seven years from the end of the investment relationship in compliance with anti-money-laundering regulations. Contractual correspondence is retained for the duration of the contract plus six years. Contact form submissions are retained for three years unless the relationship develops further. Website analytics data is retained for no more than twenty-six months, with pseudonymisation applied after fourteen months. Security and access logs are retained for twelve months.
8. International Data Transfers
Kaoko is headquartered in Namibia and operates a Delaware holding structure. Personal data may therefore be transferred to and processed in Namibia, the United States, and other jurisdictions where our service providers operate. For transfers involving individuals in the European Economic Area or the United Kingdom, we apply appropriate safeguards including the Standard Contractual Clauses adopted by the European Commission or equivalent mechanisms. For transfers from Namibia, we comply with applicable ICT regulatory requirements and the principles reflected in Namibia's draft data protection framework.
9. Your Privacy Rights
Depending on your jurisdiction, you may have rights in relation to your personal data. You may request access to the personal information we hold about you and receive a copy of it. You may ask us to correct inaccurate or incomplete data. You may request deletion of your data where there is no overriding legal obligation to retain it. You may ask us to restrict processing in certain circumstances, for example while accuracy is contested. Where processing is based on consent or contract, you may request that we provide your data in a portable, machine-readable format. You may object to processing carried out on the basis of our legitimate interests. You may withdraw consent at any time for processing activities that rely on it.
To exercise any of these rights, please contact privacy@kaoko.energy. We will respond within thirty days. We may ask you to verify your identity before acting on a request.
If you are dissatisfied with how we handle your data, you have the right to lodge a complaint with the competent supervisory authority in your jurisdiction. In Namibia, this is the Namibia Communications Commission. In the EU or EEA, this is the data protection authority in your member state of residence.
10. Cookies
Our website uses cookies to support core functionality and to understand how visitors engage with our content. Strictly necessary cookies are placed automatically as they are required for the website to function. All other cookies — including analytics cookies — require your consent, which you can provide or withdraw through our cookie preference centre in the website footer.We do not place advertising or marketing cookies.
We do not allow third-party advertisers to track your behaviour on our website.
11. Security
We take appropriate technical and organisational measures to protect personal information against unauthorised access, alteration, disclosure, or destruction. All data transmitted via our website uses TLS encryption. Sensitive data at rest, including investor records, is encrypted. We apply role-based access controls and require multi-factor authentication for internal systems and data-room access. We maintain a documented data breach response plan and are able to notify relevant supervisory authorities within seventy-two hours of becoming aware of a breach requiring notification.
No method of transmission over the internet is completely secure. While we apply robust controls, we cannot guarantee absolute security.
12. Children's Privacy
Our website and services are directed exclusively at businesses and professional investors. We do not knowingly collect personal information from individuals under the age of eighteen. If you believe a minor has submitted information to us, please contact privacy@kaoko.energy and we will promptly delete it.
13. Third-Party Websites
Our website may contain links to external websites including development finance institution portals, government energy agency pages, and partner organisation sites. Kaoko is not responsible for the privacy practices of those third parties. We encourage you to review their privacy policies before providing any personal information to them.
14. Namibian Legal Framework
Kaoko respects the constitutional right to privacy enshrined in Article 13 of the Namibian Constitution. We process data from Namibian residents in accordance with the Electronic Transactions and Cybercrime Act (No. 42 of 2019) and applicable sector regulations. As Namibia's data protection legislative framework continues to develop, including the anticipated enactment of comprehensive personal information protection legislation, Kaoko will update this Policy to ensure ongoing compliance.
15. U.S. Privacy Considerations
Kaoko GES Holdings, Inc. is incorporated in Delaware. In connection with U.S. investor activities, we comply with applicable U.S. securities laws including Regulation D under the Securities Act of 1933, which requires collection and retention of investor accreditation information. We do not sell personal information. California residents who interact with Kaoko have rights under the California Consumer Privacy Act and California Privacy Rights Act, including the right to know what personal information we hold, the right to request its deletion, and the right to opt out of its sale. U.S. investor records are retained in accordance with SEC recordkeeping requirements and applicable state law.
16. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, technology, or applicable law. Where changes are material, we will provide notice by posting a prominent update on our website for at least thirty days before the change takes effect and, where appropriate, by notifying registered users by email. The effective date at the top of this document will be updated accordingly. Continued use of our website after that date constitutes acceptance of the revised Policy.
17. Contact
For any questions about this Privacy Policy or to exercise your rights, please contact our Privacy Officer:
Email: privacy@kaoko.energy
General inquiries: info@kaoko.energy
Website: kaoko.energy
Address: Kaoko Green Energy Solutions, Windhoek, Namibia
Investor inquiries: investors@kaoko.energy | Kaoko GES Holdings, Inc., Delaware, USA
Approved by: Sakaria Nalusha
Interim Chief Executive Officer
Kaoko Green Energy Solutions | Kaoko GES Holdings, Inc.
Windhoek, Namibia | April 2026