Privacy Policy

This Policy applies to your use of (regardless of means of access) our Services. You may access or use our Services through a mobile phone, tablet, or other consumer electronic device (each, a “Device”). This Policy stipulates the basis for the collection, use, and disclosure of personal information from users of our Services in line with the Nigeria Data Protection Act 2023, the Nigeria Data Protection Regulations 2019, and other relevant data protection laws that governs the collection and processing of personal information (collectively referred to as “Data Protection Laws”).

We may use Analytics as described elsewhere in this Privacy Policy and for research and commercial purposes, such as to improve our Services.

We may use Personal Information for the purposes described elsewhere in this Policy and internally for our general commercial purposes, including, among other things, to offer our products and services and also products and services of third parties that we think you might find of interest, but only i-investng.com and our third-party service providers involved in distributing the offers or providing the products or services will have access to your Personal Information. Our third-party service providers will only be permitted to use Personal Information for that intended purpose.

We may use your email address to respond to your inquiries and to provide you information about our Services. You may elect not to receive promotional emails from us either by “unsubscribing” to an email you receive from us or by contacting us as indicated below. If you unsubscribe from receiving emails from us, we may still send you non-promotional emails, such as emails about your i-investng.com account or our ongoing business relations, unless you withdraw your consent to receive electronic communications as provided in our Terms of Use.

We may use your Personal Information for the purpose of sending short message services or rich media messages or other multimedia messages to you, and can as well provide your Personal Information to third party service providers for the purpose of the foregoing. By accessing or using our Services, you consent to the use of your Personal Information as earlier described and as described elsewhere in this Privacy Policy.

We do not share your Personal Information with: (1) other financial companies for joint marketing purposes; (2) affiliated companies for their everyday business purposes; or (3) any third parties so they can market to you.

We may share your Personal Information with unaffiliated third parties: (1) if you request or authorize it; (2) if the information is provided to help complete a transaction for you; (3) if the information is provided to: (a) comply with applicable laws, Data Protection Laws, rules, regulations, governmental and quasi-governmental requests, court orders, or subpoenas; (b) enforce our Terms of Use or other agreements; or (c) protect our rights, property, or safety or the rights, property, or safety of our users or others (e.g., to a consumer reporting agency for fraud protection, etc.); (4) if the disclosure is done as part of a purchase, transfer, or sale of services or assets (e.g., in the event that substantially all of our assets are acquired by another party, your Personal Information may be one of the transferred assets); (5) if the information is provided to our third-party service providers to perform functions on our behalf (e.g., analyzing data, providing marketing assistance, providing customer service, processing orders, etc.); (6) for our everyday business purposes; or (7) as permitted by Data Protection Laws, applicable law or otherwise described in this Policy.

We may disclose Analytics with third parties as described elsewhere in this Privacy Policy and for our commercial purposes.

If you do not wish to receive offers or other notices from us in the future, you can “opt out” by contacting us as indicated at the end of this Policy or by following the “unsubscribe” instructions in any communication you receive from us. Please be aware that you are not able to opt out of receiving communications about your i-invest account or related transactions with us.

You must notify us of any change in your Personal Information by updating your i-invest account profile through our Services. Any changes will affect only future uses of your Personal Information.

Subject to Data Protection Laws, which might, from time to time, oblige us to store your Personal Information for a certain period of time, we will respect your wishes to correct inaccurate information. Otherwise, we will hold your Personal Information for as long as we believe it will help us achieve our objectives as detailed in this Policy.

You can ask us whether we are storing your Personal Information and you can ask to receive a copy of that Personal Information. Before sending you any Personal Information, we will ask you to provide proof of your identity. If you are not able to provide proof of your identity, we reserve the right to refuse to send you any Personal Information. We will respond as quickly as we can to your requests for details of Personal Information we hold about you.

Our Services may allow you to connect and share your actions, comments, content, and information publicly or with friends. We are not responsible for maintaining the confidentiality of any information you share publicly or with friends.

Our Services may also allow you to connect with us on, share on, and use third-party websites, applications, and services. Please be mindful of your personal privacy needs and the privacy needs of others, as you choose whom to connect with and what to share and make public. We cannot control the privacy or security of information you choose to make public or share with others. We also do not control the privacy practices of third parties. Please contact those sites and services directly if you want to learn about their privacy practices.

You can ask us to do various things with your Personal Information. For example, at any time you can ask us for a copy of your Personal Information, ask us to correct mistakes, change the way we use your information, or even delete it. We will either do what you have asked or explain why we cannot - usually because of a legal or regulatory issue.

You have the following rights in relation to our use of your Personal Information.

• The right to access your Personal Information: You are entitled to a copy of the Personal Information we hold about you and certain details of how we use it. Your Personal Information will usually be provided to you in writing unless otherwise requested. We may charge you a reasonable fee to cover the cost.
• The right to rectification: We take reasonable steps to ensure that the Personal Information we hold about you is accurate and complete. However, if you do not believe this is the case, please contact us by using the details shown in your documentation and you can ask us to update or amend it.
• The right to erasure: In certain circumstances, you have the right to ask us to erase your Personal Information, for example where the Personal Information we collected is no longer necessary for the original purpose or where you withdraw your consent. However, this will need to be balanced against other factors, for example according to the type of Personal Information we hold about you and why we have collected it, there may be some legal and regulatory obligations that preclude us from complying with your request.
• Right to restriction of processing: In certain circumstances, you are entitled to ask us to stop using your Personal Information, for example where you think that the Personal Information, we hold about you may be inaccurate or where you think that we no longer need to process your Personal Information.
• Right to data portability: You have the right to easily access and transfer your personal data between services. Upon request, we will provide you with a copy of your Personal Information in a structured, commonly used, and machine-readable format to facilitate this transfer. Where technically feasible, we can also directly transfer your data to a third-party service provider of your choice.
• The right to withdraw consent: For certain uses of your Personal Information, we will ask for your consent. Where we do this, you have the right to withdraw your consent to further use of your Personal Information. Please note in some cases we may not be able to provide our services to you if you withdraw your consent.

We take reasonable measures to protect Personal Information from unauthorized access, disclosure, alteration, or destruction. To enhance data protection, we may anonymize or pseudonymize your Personal Information:

• Anonymization: When possible, we anonymize data, making it permanently untraceable to you. Anonymized data may be used for statistical, research, and other legitimate purposes, as it no longer identifies any individual.
• Pseudonymization: In cases where full anonymization is not feasible, we use pseudonymization to replace personal identifiers with artificial identifiers, limiting exposure and enhancing security. This data remains protected by our privacy measures and is only accessible to authorized personnel.

We are committed to ensuring that all our employees and relevant third parties are adequately trained. We ensure that all staff involved in data processing undergo regular training on privacy and security. This training covers data protection principles, security protocols, incident response, breach notification requirements, and many more. By providing ongoing training and awareness campaigns, we aim to equip employees with the knowledge to handle personal data securely and in compliance with data protection laws. Additionally, we require third-party service providers to provide similar training for their staff who process personal data on our behalf.

These safeguards help protect your data from unauthorized access or misuse while it is being transferred internationally.

To ensure the security and compliance of your personal data, we conduct regular audits of all third-party vendors that handle or process personal information on our behalf. These audits assess vendors’ data protection practices, compliance with applicable privacy laws, and adherence to our security standards. We only work with vendors who meet our strict requirements for data protection and privacy.

Our Services are not directed, or intended to be attractive, to children under the age of 18. We do not knowingly collect Personal Information from children under the age of 18. If you are under the age of 18, do not use our Services or submit any information to us.

When you use our Services, you may be directed to other websites that are beyond our control. We may also allow third-party websites or applications to link to our Services. We are not responsible for the privacy practices of any third parties or the content of linked websites, but we do encourage you to read the applicable privacy policies and terms and conditions of such parties and websites. This Privacy Policy only applies to our Services.

In the event of a data breach affecting your personal data and leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, Personal Information, we shall within 72 (seventy-two) hours of having knowledge of such breach report the details of the breach to Nigeria Data Protection Commission. Furthermore, if the breach is likely to result in a significant risk to your rights, we shall within 7 (seven) days of having knowledge of the occurrence of such breach take steps to notify you without undue delay, providing details of the breach, its potential impact, and any necessary actions you should take.

We take all appropriate measures to prevent data breaches and respond swiftly to protect your personal data.

Your personal data may be transferred to and stored in countries outside of your country of residence, which may not have the same level of data protection laws as those in your jurisdiction. In such cases, we ensure that your personal data is adequately protected through appropriate safeguards, such as contractual agreements or other legal mechanisms, to ensure compliance with applicable data protection regulations.

Subject to applicable law, we may revise this Privacy Policy at any time and in our sole discretion. When we revise this Privacy Policy, we will post the revised version via our Services and will update the date at the top of this Privacy Policy. The revised Privacy Policy will be effective upon posting via our Services, unless otherwise set forth therein or as otherwise required by applicable law. You are free to decide whether or not to
accept a revised version of this Privacy Policy, but accepting this Privacy Policy, as revised, is required for you to continue accessing or using our Services. If you do not agree to the terms of this Privacy Policy or any revised version of this Privacy Policy, your sole recourse is to terminate your access and use of our Services. Except as otherwise expressly stated by us, your access and use of our Services is subject to the version of this Privacy Policy in effect at the time of access or use.

If you have any questions, comments, or concerns regarding these Terms or the Services, please contact us at enquiries@i-investng.com