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Privacy Policy

Introduction

Thank you for choosing to be part of our community at Afrinvest (“company”, “we”, “us”, or “our”). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about our policy, or our practices with regards to your personal information, please contact us at dataprotection@afrinvest.com. When you visit our website (“Site”) and use our services, you trust us with your personal information. We take your privacy very seriously. In this privacy notice, we describe our privacy policy. We seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this privacy policy that you do not agree with, please discontinue use of our site and our services. This privacy policy applies to all information collected through our websites (www.afrinvest.com), our mobile application, and/or any related services, sales, marketing or events (we refer to them collectively in this privacy policy as the "Services").

Collection Of Information

We collect information you provide directly to us. For example, we collect information when you sign up to receive information about our products or services, create an account or profile, use interactive features of our products or services, participate in our surveys, communicate with us via third-party social media sites. We use your information to communicate with you, to update you on services and benefits, to better understand who uses our site and the pages they access so as to be able to improve the site and to help us understand your needs & interests and provide you with better services as well as for the purpose of fulfilling your requests to us.

Our Use of Your Personal Data

We use personal information collected for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests ("Business Purposes"), in order to enter into or perform a contract with you ("Contractual"), with your consent ("Consent"), and/or for compliance with our legal obligations ("Legal Reasons"). We indicate the specific processing grounds we rely on next to each purpose listed below. We use the information we collect or receive:

  • To send you marketing and promotional communications [for Business Purposes and/or with your Consent]. We and/or our third party marketing partners may use the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt-out of our marketing emails at any time (see the "Your Privacy Rights" below).
  • To send administrative information to you [for Business Purposes, Legal Reasons and/or possibly Contractual]. We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.
  • Fulfill and manage your onboarding/engagement [for Contractual reasons]. We may use your information In order for us to provide you with a service.
  • To respond to legal requests and prevent harm [for Legal Reasons]. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
  • For other Business Purposes. We may use your information for other Business Purposes with your consent, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Sites, products, services, marketing and your experience.

Who We Share Your Personal Data With

We only share and disclose your information in the following situations: Access your personal data Object to processing of your personal data Correct errors in your personal data Erase your personal data Export or transfer your personal data

  • Compliance with Laws. We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
  • Vital Interests and Legal Rights. We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
  • Vendors, Consultants and Other Third-Party Service Providers. We may share your data with third party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts. Unless described in this Policy, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes.
  • Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy policy. Affiliates include any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.
  • With your Consent. We may disclose your personal information for any other purpose with your consent.

Cookies and Other Tracking Technologies

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Policy (Link to cookie policy)

Our Retention/Storage of Your Personal Data

Our data retention periods are based on business needs and legal requirements. We store the information we collect about you for as long as is necessary for the purposes for which we originally collected it, or as needed to provide the products or services to you unless a longer retention period is required or permitted by applicable law. You may request that we delete your information but note that we may retain certain information as reasonably needed to comply with the law, meet regulatory requirements, or for legitimate purposes. We may also retain cached or archived copies of information about you for a certain period. We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our Sites is at your own risk. You should only access the services within a secure environment.

Your Rights

You have the right to:

  • Right of access – you have the right to request a copy of the information that we hold about you.
  • Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
  • Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
  • Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
  • Right of portability – you have the right to have the data we hold about you transferred to another organisation.
  • Right to object – you have the right to object to certain types of processing such as direct marketing.
  • Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.

Changes to Our Privacy Policy

We may update this privacy policy from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make changes to this privacy policy, we will notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information.

Terms & Conditions

Any person or group of persons who access or rely on this Website or the information contained herein does so at their own risk.

By accessing this Website You are deemed to have read and agreed to the following terms and conditions below. These terms and conditions become effective when you access this site for the first time. These Terms and Conditions are subject to change without notice, from time to time in our sole discretion. You are responsible for being familiar with the current version of these Terms and Conditions posted on the Website during each visit.

If you do not wish to be bound by these terms and conditions, do not access this website.

For purposes of these terms and conditions, “Client”, “You” and “Your” refers to you, the person accessing this Website and accepting the Company’s terms and conditions. “The Company”, “Ourselves”, “We” and “Us”, refers to Afrinvest (West Africa) Limited and its subsidiary companies “Afrinvest Securities Limited l” (ASL) and Afrinvest Asset Management Limited (AAML)“Party”, “Parties”, or “Us”, refers to both the Client and the Company, or either the Client or the Company.

You are strictly prohibited from unauthorized use of our systems or this Website, including but not limited to unauthorized entry into our systems, misuse of passwords, or misuse of any information posted to this Website.

Accuracy Of Information

While Afrinvest (West Africa) Limited attempts to ensure that the information on this Website is accurate, current, complete, fit for its intended purpose and compliant with the relevant Nigerian Legislation and regulations as at the time of access, this site and the online services are provided “as is”. Afrinvest (West Africa) Limited makes no representation or warranty, whether express or implied as to the accuracy, completeness or reliability of any information on this website.

Confidentiality

Information provided by you shall be kept confidential and not be used or disclosed in any manner incompatible with the purposes for which they are held. Notwithstanding, You acknowledge that we may disclose and transfer any information that you provide through this Website to (i) the Company, its affiliates, agents or information providers; or (ii) if we have a right or duty to disclose or are permitted or compelled to so disclose such information by law. You consent to the transmission, transfer or processing of such information to, or through, any country in the world, as we deem necessary or appropriate, and by using and providing information through this Website you agree to such transfers.

Monitoring by Afrinvest (West Africa) Limited and its subsidiaries.

Your use of the products and services on this Website may be monitored by the Company and the resultant information may be used by the Company for its internal business purposes or in accordance with the rules of any applicable regulatory or self-regulatory organization. Anyone using this Website expressly consents to such monitoring, tracking and recording.

Website content and materials

You are permitted to store, display, analyse, modify, reformat, and print the information made available to you via these services for your own use only. You are by no means, permitted to publish, transmit, or otherwise reproduce this information, in whole or in part, in any format to any third party without the express written consent of Afrinvest (West Africa) Limited. In addition, you are not permitted to alter, obscure, or remove any copyright, trademark or any other notices that are provided to you in connection with the information contained on this Website. The Company reserves the right, at any time and from time to time, in the interests of its own editorial discretion and business judgment to add, modify, or remove any of the information without recourse to You. These Terms and Conditions are not intended to, and will not, transfer or grant any rights in or to the information other than those which are expressly described herein, and all rights not expressly granted herein are automatically reserved by Afrinvest (West Africa) Limited or any third party providers from whom the Company has obtained the information. You are advised to read and abide by any revised or additional terms and conditions that may be posted on this service from time to time concerning information generated by the Company or obtained from specific third party providers. Such third party providers shall have no liability to you for monetary damages on account of the information provided to you via this service.

No warranties made as to security

Afrinvest makes no warranty whatsoever to you express or implied, regarding the security of the site, including with respect to the ability of unauthorized persons to intercept or access information transmitted by you through this service. Afrinvest also makes no warranty or representation, whether express or implied, that the information or files available on this Website are free of viruses, destructive materials or any other data or code which is able to corrupt, compromise, jeopardize, disrupt, disable, harm or otherwise impede in any manner the operation of a computer system, computer network or your hardware or software. You accept all risk associated with the existence of such viruses, destructive materials or any other data or code which is able to corrupt, compromise, jeopardize, disrupt, disable, harm or otherwise impede in any manner the operation or content of a computer system, computer network or your hardware or software.

No warranties; no responsibilities to update

Afrinvest makes no warranty, express or implied, concerning this service. The services provided by us are on an “AS IS” basis at your sole risk. The Company expressly disclaims any implied warranty of merchantability or fitness for a particular purpose, including any warranty for the use or the results of the use of the services with respect to their correctness, quality, accuracy, completeness, reliability, performance, timeliness, or continued availability. Neither Afrinvest nor any of its third party providers shall have any responsibility to maintain the data and services made available on this Web site or to supply any corrections, updates, or releases in connection therewith. Availability of data and services are subject to change without notice.

Please remember that past performance is not necessarily a guide to future performance, and that there can be no assurance that comparable results will be achieved. The value of units of securities and/or investments and the income from them can go down as well as up and investors may not get back the amount originally invested. Exchange rate changes may cause the value of investments made by offshore investors to rise or fall. For further details on any of the products mentioned on this Website, please read the relevant offering documents or prospectus.

Content not to be construed as a solicitation or recommendation Content on this Website is for informational purposes only without regard to any particular user’s investment objectives, financial situation, or means, and Afrinvest is not soliciting any action based upon it. Information is not to be construed as a recommendation; or an offer to buy or sell; or the solicitation of an offer to buy or sell any security, financial product, or instrument; or to participate in any particular trading strategy in any jurisdiction in which such an offer or solicitation, or trading strategy would be illegal. Certain transactions give rise to substantial risk and are not suitable for all investors.

No determination of suitability has been made; not all risks are disclosed; private advisors should be consulted
The fact that Afrinvest has made the data and services provided on this Website available to you constitutes neither a recommendation that You enter into a particular transaction nor a representation that any product described on this Website is suitable or appropriate for you. Many of the products described on this Website involve significant risks, and you should not enter into any transactions unless you have fully understood all such risks and have independently determined that such transactions are appropriate for you. Any discussion of the risks contained herein with respect to any product should not be considered to be a disclosure of all risks or complete discussion of the risks which are mentioned. You should not construe any of the material contained herein as business, financial, investment, hedging, trading, legal, regulatory, tax, or accounting advice nor make this service the primary basis for any investment decisions made by or on behalf of you, your accountants, or your managed or fiduciary accounts, and you may want to consult your business advisor, attorney, and tax and accounting advisors concerning any contemplated transactions.

Copyright notice

Copyright and other relevant intellectual property rights exist on all text relating to the Company’s services and the full content of this website.

Potential disruption of service

You shall be responsible for obtaining and maintaining all telephone, computer hardware, software, and other equipment needed to access and use this Website. Access to this Website may from time to time be unavailable, delayed, limited or slow due to, among other things:

  1. Hardware failure, including among other things, failures of computers (including your own computer), servers, networks, telecommunication lines and connections, and other electronic and mechanical equipment.
  2. Software failure, including among other things, bugs, errors, viruses, configuration problems, incompatibility of systems, utilities or applications, the operation of firewalls or screening programs, unreadable codes, or irregularities within particular documents or other content.
  3. Overload of system capacities.
  4. Damage caused by severe weather, earthquakes, wars, insurrection, riots, terrorism, civil commotion, act of God, accident, fire, water damage, explosion, mechanical breakdown or natural disasters.
  5. Interruption (whether partial or total) of power supplies or other utility of service.
  6. Strike or other stoppage (whether partial or total) of labour.
  7. Governmental or regulatory restrictions, exchange rulings, court or tribunal orders or other human intervention; or
  8. Any other cause (whether similar or dissimilar to any of the foregoing) whatsoever beyond our control.

If access to this Website is unavailable, delayed or limited or if this Website does not operate quickly and efficiently, you may be unable to transmit your instructions for transactions and other matters, or such instructions may not be promptly executed or you may be unable to retrieve information on a timely basis. If your operations are dependent on such communications with Us, and such communications are disrupted or delayed, you may suffer losses. Afrinvest shall not be liable for any such loss.

Links from this website

This service may provide links to certain Internet sites (the “Sites”) sponsored and maintained by third parties. Afrinvest is providing such links solely for convenience to You. Accordingly, Afrinvest makes no representations concerning the content of the Sites. We do not monitor or review the content of other party’s Sites which are linked to from this website. Opinions expressed or materials appearing on such Sites do not constitute an endorsement by us and should not be regarded as the publisher of such opinions or materials. Please be aware that We are not responsible for the privacy practices, or content, of these sites. We encourage You to be aware when you leave our site & to read the privacy statements of these sites. You should evaluate the security and trustworthiness of any other site connected to this site or accessed through this site yourself, before disclosing any personal information to them. The Company will not accept any responsibility for any loss or damage in whatever manner, howsoever caused, resulting from your disclosure to third parties of personal information.

Limitation of liability

Afrinvest shall have no liability, contingent or otherwise, to You or to third parties, or any responsibility whatsoever, for the failure of any connection or communication service to provide or maintain your access to this service, or for any interruption or disruption of such access or any erroneous communication between the Company and You, regardless of whether the connection or communication service is provided by the Company or a third party service provider. Afrinvest shall have no liability, contingent or otherwise, to You or to third parties, for the correctness, quality, accuracy, timeliness, reliability, performance, continued availability, completeness or delays, omissions, or interruptions in the delivery of the data and services available on this website or for any other aspect of the performance of this service or for any failure or delay in the execution of any transactions through this service. In no event shall the Company be liable for any special, indirect, incidental, or consequential damages which may be incurred or experienced on account of You using the data or services made available on this Website, even where the Company has been advised of the possibility of such damages. Afrinvest shall have no responsibility to inform You of any difficulties experienced by the Company or third parties with respect to the use of the services or to take any action in connection therewith.Afrinvest shall have no liability, contingent or otherwise, to You or to third parties, or any responsibility whatsoever, for the failure of any connection or communication service to provide or maintain your access to this service, or for any interruption or disruption of such access or any erroneous communication between the Company and You, regardless of whether the connection or communication service is provided by the Company or a third party service provider. Afrinvest shall have no liability, contingent or otherwise, to You or to third parties, for the correctness, quality, accuracy, timeliness, reliability, performance, continued availability, completeness or delays, omissions, or interruptions in the delivery of the data and services available on this website or for any other aspect of the performance of this service or for any failure or delay in the execution of any transactions through this service. In no event shall the Company be liable for any special, indirect, incidental, or consequential damages which may be incurred or experienced on account of You using the data or services made available on this Website, even where the Company has been advised of the possibility of such damages. Afrinvest shall have no responsibility to inform You of any difficulties experienced by the Company or third parties with respect to the use of the services or to take any action in connection therewith.

Governing law

In the event any of the terms or provisions of these Terms and Conditions shall be held to be unenforceable, the remaining terms and provisions shall be unimpaired and the unenforceable term or provision shall be replaced by such enforceable term or provision as comes closest to the intention underlying the unenforceable term or provision. These Terms and Conditions shall be subject to any other agreements you have entered into with the Company. The user’s access to and use of the Website, and the terms of this disclaimer are governed by the laws of the Federal Republic of Nigeria without regards to the conflict of law provisions. You consent to the personal and exclusive jurisdiction of the courts located within Lagos State of Nigeria.

No waiver

The Company’s failure to exercise or enforce any right or provision of the Terms of Service shall not constitute a waiver of such right or provision or prevent a subsequent enforcement of that or any other right or provision. No waiver of any of the provisions of this or any Agreement shall be effective unless it is expressly stated to be such and signed by both Parties.

Termination and notification of changes

Afrinvest may in its sole discretion terminate, suspend and/or modify the contents of this Website with or without notice to you. The Company reserves the right to terminate, suspend and/or modify these conditions from time to time as it sees fit and your continued use of the site will signify your acceptance of any adjustment to these terms. You agree that Afrinvest, its affiliates or subsidiaries shall not be liable to you in the event that it chooses to terminate, suspend or modify this Website or your use of this Website. This Web site is hereby issued and approved by Afrinvest (West Africa) Limited which is authorised and regulated by the Securities and Exchange Commission © Afrinvest West Africa 2018. All rights reserved.

Afrinvest Complaint Management Policy

A complaint is an expression of dissatisfaction, made either orally or in writing, about the standard of service, actions or lack of action by Afrinvest (West Africa) Limited (“Afrinvest” or the “Company”) affecting an individual customer or group of customers.

Procedure

You shall be responsible for obtaining and maintaining all telephone, computer hardware, software, and other equipment needed to access and use this Website. Access to this Website may from time to time be unavailable, delayed, limited or slow due to, among other things:

  1. The Customer Service Centre is responsible for the coordination of the complaints policy and procedure, including the analysis of data.
  2. The Legal and Compliance Unit is responsible for overseeing the process of monitoring the progress of the complaint and any response made thereto.
  3. Overload of system capacities.
  4. Managers and Directors are responsible for the investigation of complaints directly related to their areas of operation.

Process for Complaint Handling

Complaints should be in writing detailing the nature of the complaint, addressed to the Legal and Compliance Unit and signed by the complainant, complete with the complainant’s contact details, his/her signature and date. Complaints can also be sent to the Company by filling the Complaint Form attached to this document as schedule. Get a detailed copy of the complaint policy and form here.

Contact Us

If you have any questions about this Privacy Policy, please email us at info@afrinvest.com or write us Afrinvest West Africa Limited, 27 Gerrard Road, Ikoyi, Lagos.

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