What is this Privacy Policy for?

AIICO Capital Ltd (“AIICO”, “we”, “us” or “our”) values your Personal Data and we are committed to protecting your privacy whenever you interact with us. Please read this Privacy Policy (the Policy) to understand our policies, processes and procedures regarding the processing of your Personal Data. AIICO is strongly committed to protecting your privacy during your interaction with our content, products and services. We want to provide a safe and secure environment for you. The purpose of this Privacy Policy is to tell you what kind of information we may gather about you when you visit our site, our offices or engage our services. It also enlightens you on how we may use that information, whether we disclose it to anyone, the choices you have regarding our use of this information, your ability to correct this information as well as your rights regarding the processing, use, dissemination and deletion of your Personal Data.

Our policy allows you to choose, subject to the requirements of the Investment and Securities Act and subsidiary legislations subsequently issued by the Securities and Exchange Commission and other relevant regulatory authorities and also in line with the provisions of the Nigeria Data Protection Regulation 2019, what kind of and how much information you provide to us and to control how we use whatever information you give us. Our goal is to provide you with a satisfying experience while allowing you to control your privacy and to give you a means to voice any questions or concerns you may have.

Consent

You accept this Privacy Policy and hereby give us consent to save, process and use your Personal Data to the extent as allowed by law when you provide us with details of your Personal Data or by clicking on the “accept” button. We may request for further consent in the event that your Personal Data is required to be transferred to a third party for marketing purposes or when it is to be further processed in a manner which would require your further consent.

You may withdraw your consent at any time before, during and after we process your Personal Data. Personal Data is any information that can be directly used to identify you and includes but is not limited to your name, address, telephone number, email address and any other information of like nature.

We may use your Personal Data where we have a legal basis to do so. The legal basis will depend on the purpose for which we have collected and is any of the following:

• a. either with your consent
• b. for compliance with a legal obligation to which we are subject;
• c. where it is necessary to perform contractual obligation, we have with you;
• d. where it is required for protection of your vital interests;
• e. when we have assessed that it is necessary for the purposes of the legitimate interests pursued by us or by a third party to whom it may be necessary to disclose information.
• f. where it is necessary for the performance of task or function carried out in the interest of the public.

We may also use your Personal Data to further develop the quality of our services.

The Personal Data that We Collect

We collect Personal Data that you give to us, for example, where you create an account with us, request for further information about our product, fill a form, apply for a job through our website or you subscribe to newsletters on our website.

We may also automatically collect some technical information when you visit our website such as the pages that you viewed. This information helps us understand customer interests and helps us improve our website.

What Purpose do We use your Personal Data for?

We may process your Personal Data to communicate with you (including sending marketing or promotional materials to you), provide you with further information about our products and how we can serve you better, respond to your purchase orders or requests, process your application for employment with AIICO or to fulfil our contractual obligations with you. We may also process your Personal Data to comply with provisions of applicable laws and whenever we have a lawful basis for doing so.

Who do we share your Personal Data with?

We respect your privacy and we limit disclosure of your Personal Data to third parties. We do not sell, give or trade any Personal Data that we obtain from you to any third party for data-mining or marketing purposes. However, we may share your Personal Data with companies within the AIICO Group, service providers engaged by us while providing our services to you, subject however to appropriate data security and protection. We may also share your information where there is a regulatory or statutory obligation to disclose such Personal Data in accordance with the provisions of applicable laws.

Security and Retention of your Personal Data

Your Personal Data is kept private and we make every effort to keep your Personal Data secure, including restricting access to your Personal Data with us on a need to know basis. We require our staff and any third parties who carry out any work on our behalf to comply with appropriate security standards to protect your Personal Data.

We take appropriate measures to ensure that your Personal Data is only processed for the minimum period necessary in line with the purposes set out in this Policy or as required by applicable laws, until a time it is no longer required or has no use. Once your Personal Data is no longer required, we destroy it in a safe and secure manner.

We will communicate such duration we need to store your Personal Data for. Where this duration cannot be ascertained, the criteria to be used in determining such duration of retention will be communicated to you.

No sale of personal information

Under no circumstances will AIICO Capital Ltd sell or receive payment for disclosing your Personal Data. Ultimately, you are solely responsible for maintaining the secrecy of your passwords and/or any Personal Data in your possession. Be responsible whenever you are online.

Your Rights

AIICO collects Personal Data only for the purposes identified in this Policy and such information cannot be reused for another purpose that is incompatible with the original purpose.

The rights you can exercise with respect to your Personal Data with AIICO include but are not limited to the following:

• a) request for and access your Personal Data collected and stored by AIICO;
• b) withdraw consent to the processing of your Personal Data at any time. For example, you can withdraw your consent to receipt of our marketing or promotional materials or unsubscribe to our newsletters;
• c) object to automated decision making;
• d) request rectification and modification of Personal Data kept by AIICO;
• e) in certain circumstances, request for deletion of your Personal Data;
• f) be informed of and entitled to provide consent prior to the processing of Personal Data for purposes other than that for which the Personal Data were collected;
• g) request that AIICO restricts processing of your Personal Data;
• h) request for information regarding any specific processing of your Personal Data

Access and correction: Personal Data

If AIICO Capital Ltd holds your Personal Data, we will, where possible provide you with access to the information. We will also take reasonable steps to correct the information so that it is accurate, complete and up to date.

Access by 3rd Parties

In the course of providing services to you, we may share your Personal Data with trusted third parties. We provide only information they need to perform their specific services and we will work closely with them to ensure that your privacy is respected and protected at all times. In the event that we no longer require their services, any of your data held by them will be irrecoverably deleted.

For fraud management or in line with public interest, we may share information about fraudulent or potentially fraudulent activity in our system which may include sharing data about individuals with law enforcement bodies.

We may also be required to disclose your Personal Data to law enforcement, regulatory or government body upon a valid request to do so. These requests however will be assessed on a case-by-case basis and the privacy of our customers shall be considered.

Security

AIICO Capital Ltd shall ensure that Personal Data is stored securely using modern software that is kept-up-to-date.

Access to Personal Data shall be limited to personnel who need access and appropriate security measures shall be in place to avoid unauthorized sharing of information.

When Personal Data is deleted this will be done safely such that the data is irrecoverable.

Appropriate back-up and disaster recovery solutions shall be in place.

Breach/ Privacy Violation

In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to personal data, AIICO Capital Ltd shall within 72 (Seventy-Two) hours of having knowledge of such breach report the details of the breach to NITDA. Furthermore, we shall within 7 (Seven) days of having knowledge of the occurrence of such breach take steps to inform you of the breach incident, the risk to your rights and freedoms resulting from such breach and any course of action to remedy said breach.

If you feel that your data has not been handled correctly or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have a right to lodge a complaint with the National Information Technology Development Agency.

Cookies and Other Technologies.

When you visit our site, the pages that you look at and a short text file called a cookie, are downloaded to your computer. By visiting and using our website, you agree to our use of cookies in line with AIICO’s policies. For more details about Cookies, please read our Cookies Policy available through this link. Cookies allow a web server to transfer data to a computer or device for record keeping and other purposes.

We use cookies and other technologies to, among other things, better serve you with more tailored information and facilitate your ongoing access to the use of our website. If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to decline the use of cookies. However, if you do this, you may lose some useful functionality such as personalisation, “Keep Me Signed In” and “Remember Me” features. To learn more about cookies, please visit http://www.allaboutcookies.org/.

Changes to our Privacy Policy

Due to constant changes in technology and regulatory requirements, we may need to change our privacy policies or update this Policy from time to time. You will always be able to find the most recent version of our updated privacy policy on this site.

Contact & Communication

If you would like further information on this Policy, or to contact our Data Protection Officer, you may contact us at AIICO Capital Ltd, Plot PC 12, Churchgate Street, Victoria Island, Lagos or at [email protected]