maintain a data processing schedule and record, showing lawful purposes for each activity. 49. That as ODPC and TFH corresponded on the Data Protection Impact Assessment (DPIA), the ODPC was processing TFH GmbH’s application for registration as a data controller and a Certificate of Registration Serial No. 00379 dated 15th September, 2022 was issued to TFH GmbH, valid for 24 months. 50. That vide an email dated 14th September 2022, Bowmans informed ODPC that its Clients would proceed with processing sensitive personal data of Kenyans despite ODPC’s directive issued on 23rd June 2022 to restrict processing until either 60 days lapsed or a lawful basis was provided. 51. Further, that by a letter dated 10th November 2022, Bowmans responded to the ODPC’s 5th September 2022 letter, enclosing a letter from TFH US (referenced to be trading as Worldcoin) alongside a data processing schedule and record of processing activities prepared by TFH US. However, that TFH US failed to demonstrate an existing legal obligation for data processing, as no specific KYC details or legislative provisions were provided as requested in the ODPC’s letter dated 23rd June 2022; to justify legitimate interest for processing sensitive personal data by third parties, with the justification also failing to meet the requirements under Section 30(1)(b)(vii) and 45 of the Data Protection Act. Page 20 of 84

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