Privacy Policy

1. Scope

This policy applies to palmleafpartners.com and any pages, forms, or services made available under that domain. It does not cover any third-party site you may reach through outbound links, or any direct correspondence (email, postal mail, phone) initiated outside this website. Where DRC-specific operations require additional data handling — for example, the address-mapping pipeline run by UPTWB SAS — separate notices apply at the point of collection.

2. Information we collect

Information you give us directly

When you complete a contact or inquiry form on this website, you may provide:

• Your name and any organization you represent
• Your email address
• The subject and substance of your inquiry

Providing this information is voluntary. If you do not provide an email address, we cannot respond to your inquiry.

Information collected automatically

When you visit this website, our hosting provider (Vercel Inc.) may automatically log standard technical information, including your IP address, browser type, referring URL, and timestamps of requests. This information is used for security, abuse prevention, and basic operational telemetry. We do not currently use third-party analytics, advertising trackers, social-media pixels, or cookies that store identifying information.

Cookies

This website uses a single browser-storage entry (localStorage) to remember your selected language (English or French). No advertising, analytics, or cross-site tracking cookies are set.

3. How we use information

We use the information you provide to:

• Respond to your inquiry or partnership proposal
• Maintain a record of correspondence relevant to a potential or ongoing business relationship
• Comply with legal, regulatory, audit, or contractual obligations (including obligations under our MOU with SCPT and applicable OHADA and DRC law)
• Protect the security and integrity of this website and our operations

We do not sell personal information. We do not use the information you provide for marketing to unrelated third parties.

4. Sharing and disclosure

We may share information you provide with:

• Service providers who host or maintain this website and our internal systems (for example, our hosting provider and email service), bound by confidentiality and data-handling obligations
• Affiliated entities: UPTW USA, LLC and UPTWB SAS, where necessary for legitimate business coordination
• Government authorities or counterparties, where required by law or under the terms of a formal partnership (for example, SCPT under our MOU)
• Professional advisors (lawyers, auditors, accountants) bound by professional confidentiality
• Successor entities in the event of a merger, acquisition, or restructuring

5. International transfers

Palm Leaf Partners is headquartered in the United States. UPTWB SAS, our DRC operating partner, is established in the Democratic Republic of Congo. Information you provide may be processed in both jurisdictions. We rely on appropriate safeguards — including confidentiality undertakings between affiliated entities and contractual obligations with service providers — to protect your information when it crosses borders. If you are located in the European Economic Area, the United Kingdom, or another jurisdiction with restrictions on international data transfers, you should not submit personal information through this website unless you accept that it may be processed in the United States and the DRC.

EEA / UK representative (GDPR Art. 27 / UK GDPR Art. 27): Palm Leaf Partners LLC does not currently target individuals in the EEA or UK and does not maintain an EU- or UK-based representative. If you are an EEA or UK data subject and wish to exercise rights under the GDPR or UK GDPR, please contact [email protected]. If Palm Leaf Partners' activities later trigger an Art. 27 obligation, a designated representative will be appointed and disclosed in this section.

6. Retention

We retain inquiry information for as long as needed to respond, to maintain a record of the business relationship, and to meet legal, audit, and contractual obligations. When information is no longer needed, we delete or anonymize it. You may request earlier deletion at any time, subject to our legitimate need to retain limited records (for example, where required by law or to resolve a dispute).

7. Your rights

Depending on where you live, you may have rights to:

• Access the information we hold about you
• Correct inaccurate or incomplete information
• Delete information, subject to legal and contractual exceptions
• Object to certain uses of your information
• Restrict or port your information, where applicable
• Withdraw consent at any time, without affecting prior lawful processing

If you are in the European Economic Area or the United Kingdom, you also have the right to lodge a complaint with your national data protection authority. If you are a California resident, you have additional rights under the California Consumer Privacy Act, including the right to know what personal information we collect and the right not to be discriminated against for exercising your rights.

To exercise any right, email [email protected]. We will respond within a reasonable timeframe consistent with applicable law.

8. Security

We use reasonable technical and organizational measures to protect information you provide — including HTTPS in transit, hardened security headers (HSTS, X-Frame-Options, Content-Security-Policy directives), and limited access to inquiry data. No system is perfectly secure. We cannot guarantee that information transmitted to us will never be intercepted, lost, or improperly accessed.

9. Children's privacy

This website is not directed to children under 16. We do not knowingly collect information from children. If you believe a child has provided us with information, please email [email protected] and we will delete it.

10. Changes to this policy

We may update this policy from time to time. When we do, we will revise the "Effective date" above. Material changes will be highlighted on this page for a reasonable period before they take effect. Your continued use of the website after the effective date constitutes acceptance of the updated policy.

11. Contact us

Questions about this policy or our privacy practices:

Palm Leaf Partners LLC
[email protected]
For inquiries relating to data handled by UPTWB SAS in connection with DRC field operations, please use the same email and we will route your request appropriately.

This English version of the policy is the controlling version for legal purposes. Translations are provided for convenience.