Privacy Policy
ANCHORIA ASSET MANAGEMENT LIMITED
PRIVACY POLICY FOR SEEDs by Anchoria Asset Management Limited
20221. DEFINITIONS
1.1. SEEDs by Anchoria AM is a product of Anchoria Asset Management Limited (AAML). 1.2. At AAML (“we”, “us”, “our” “AAM”, “Company”), we recognize your privacy is important. This Policy explains our privacy practices on the SEEDs by Anchoria AM App (the Platform). This Policy also explains what information we collect about our customers and how we use this information. This Privacy Policy is designed to be read in connection with the Platforms’ Terms of Use. By accessing or using the Platform, you hereby agree with the method of collection, use, disclosure and processing of your Personal Information as described in this Privacy Policy and the Terms of Use. 1.3. For clarity, “we,” “us,” “our,” the “Company” and AAM” refers to Anchoria Asset Management Limited. The “Services” refer to the use of any of the financial services or products on the Platform. “User,” “customer,” or “subscriber,” refers to consumers of the Services. “Personal Information,” or “Personal Data,” means any information that identifies or can be used to identify a user, directly or indirectly, including, but not limited to name, contact address, email address, gender, mobile number, means of identification, details of next of kin, photograph, employment details, bank details or and any other information We may deem necessary, and which may be determined by extant Nigerian laws and regulations.2. Consent for Collection, Use and Disclosure
2.1. Your use of the Platform and/or registration for the Services constitutes your consent to the terms of this Privacy Policy. If you do not agree, you can withdraw your consent at any time but please note that the Company will not be able to provide you with its Services. 2.2. The Company reserves the right to amend this Privacy Policy at any time. When it does, the Company will also revise the “last updated” date at the top of this Privacy Policy. 2.3. The Company will notify you by email regarding material changes to this Privacy Policy that will affect information collected from you in the future. However, the Company will not notify you in certain circumstances, such as in connection with investigation of a breach of an agreement, contravention of laws, an emergency where the life, health or security of an individual is threatened, the collection of a debt or in compliance with the request of a law enforcement agency or a court order. However, the Company may notify Users of such circumstances upon request by the User in permissible circumstances. 2.4. You may withdraw your consent for collection, use and disclosure at any time by sending an email using the Company’s contact details on the ‘Contact Us’ page on the Site. Please note that, if you withdraw your consent for collection, the Company may suspend its provision of Services to you. 2.5. By continuing to access and use the Services, you are deemed to have accepted the changes to the provisions of this Privacy Policy. 2.6. If you provide Personal Information of any third party to the Company, we assume that you have obtained the required consent from the relevant third party to share and transfer his/her Personal Information to us.3. Collection of Personal Information
All information supplied by Users of the Services as defined under the Terms of Use is covered by the provisions of the Constitution of the Federal Republic of Nigeria 1999 (as amended), Nigerian Data Protection Regulation 2019 (NDPR) and other extant laws and regulations regulating the use, collection, processing, and management of personal data. 3.1. Voluntarily Submitted Data: When you sign up for the Company’s Services, pay for a subscription, consult with our customer service team, send us an email, or communicate with us in any way, you are voluntarily giving us information that we process, including, but not limited to; name, username, email address, mobile number, IP address, credit card information, bank information, and purchase history. By submitting this information, you consent to its collection, usage, disclosure, and storage by us, as described in our Terms of Use and this Privacy Policy. 3.2. Automatically Collected Data: When you use the Services or browse any of our Platform, we may collect information about your visit, your usage of the Services, and/or your web browsing; which may include your IP address, operating system, device type, operating system, browser ID, browsing activity, and other information about how you interacted with our Mobile Application. We may collect this information as a part of log files or through the use of cookies or other tracking technologies. Our use of cookies is discussed more in our Cookie Policy accessible here. 3.3. Service Usage Data: We may receive information about how and when you use the Services, store it in log files or other types of files associated with your account, and link it to other information we collect about you. This information may include, for example, your IP address, time, date, browser used, and actions you have taken within the Mobile Application. This type of information helps us to improve our Services for both you and all of our users. 3.4. Cookie Data: The Site uses cookies. Cookies are text files containing small amounts of information which are downloaded to your device when you visit a website. Cookies are useful because they allow a website to recognize a User’s device. And, to do a lot of other tasks, you may see examples below. You can find more information about cookies at: allaboutcookies.org and youronlinechoices.eu. We use strictly necessary cookies, analytical/performance, functionality and targeting/advertising cookies on the Platforms. These cookies may allow:- i. Strictly necessary – us remember any of the features and services you use such as savings, fixed deposit, bill payment, tap and pay amongst others.
- ii. Functionality – us to remember choices you make to improve your experience (such as your username, age classification etc.);
- iii. Advertising or targeting – third-party advertising companies to display advertisements more relevant to you and your interests. As part of their services, they will place a separate cookie on your computer to help them precisely target advertising to you. These third-party advertising companies do not collect personally identifiable information and;
- iv. Analytical or Performance – us or/and third-party partners collect anonymous information including but not limited to performance and website improvement. This may include web analytics, error management and testing designs.
4. Purposes for collecting Personal Information
We collect Personal Information for the following reasons: 4.1. For Promotional Purposes: This includes sending you emails relating to the merits of a product, service, brand or issue. You can stop receiving our promotional emails by following the unsubscribe instructions included in every email we send, or by adjusting your marketing preferences in your profile. This data is processed in accordance with consent under the NDPR and extant data protection laws. 4.2. For Billing Purposes: This includes sending you emails, invoices, receipts, notices of delinquency, and alerting you if we need a different credit card number. We use third parties for secure credit card transaction processing, and we send billing information to those third parties to process your orders and credit card payments. This data is processed in accordance with consent and third-party data processing contract requirements under the NDPR and extant data protection laws. 4.3. To Provide and Improve Our Services. This includes, for example, aggregating information from your use of the Services or visit to our Platforms and sharing this information with third parties to improve our Services. This might also include sharing your information with third parties to provide and support our Services. When we do have to share Personal Information with third parties, we take steps to protect your information by requiring these third parties to enter into a contract with us that requires them to use the Personal Information we transfer to them in a manner that is consistent with this policy. This data is processed in accordance with consent and third-party data processing contract requirements under the NDPR and extant data protection laws. 4.4. For Account and Support Communication: For example, we may inform you of subscription payment successes or failures, password reset attempts and other support-related functions. This data is processed in accordance with consent under the NDPR and extant data protection laws. 4.5. For Platform Alerts: For example, we may inform you of temporary or permanent changes to our Services, such as pricing changes, planned outages, new features, version updates, releases, abuse warnings, and changes to our Privacy Policy. This data is processed in accordance with the contract requirements under the NDPR and extant data protection laws. 4.6. For Legal Purposes: For example, complying with court orders, valid discovery requests, valid subpoenas, to prosecute and defend a court, arbitration, or similar legal proceeding. To respond to lawful requests by public authorities, including to meet national security or law enforcement requirements. To provide information to representatives and advisors, including attorneys and accountants, to help us comply with legal, accounting, or security requirements. This data is processed in accordance with legal obligation under the NDPR and extant data protection laws. 4.7. For Transfer Purposes: In the case of a sale, merger, consolidation, liquidation, reorganization, or acquisition. In that event, any acquirer will be subject to our obligations under this Privacy Policy, including your rights to access and choice. We will notify you of the change either by sending you an email or posting a notice on our Website. This data is processed in accordance with legal obligation under the NDPR and extant data protection laws.5. Limiting the Collection of Personal Information
The Company may limit its collection of Personal Information only to the extent that the information is unnecessary for the identified purposes. The Company does not direct the Platforms to, nor does it knowingly collect any Personal Information from persons under the age of eighteen (18 years). Consequently, the Company shall not be liable for any use or processing of Personal Information of persons under the age of 18.6. Disclosure of Personal Information
The Company will not disclose any of your Personal Information to anyone else, except:- 6.1. to its employees, independent contractors, subsidiaries, affiliates, consultants, business associates, service providers, suppliers and agents, acting on its behalf for any of the identified purposes;
- 6.2. if it has reason to believe that disclosure is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference (either intentionally or unintentionally) with the Company’s rights or property, other users of the Platforms, the Services, or anyone else that could be harmed by such activities;
- 6.3. in the event of business transfers which may occur when we sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, personal data may be part of the transferred assets; and
- 6.4. to respond to judicial process and provide information to law enforcement agencies or in connection with an investigation on matters related to public safety, as permitted by law, or otherwise as required by law.
7. DISCLOSURE OF PERSONAL INFORMATION
7.1. We may disclose your Personal Information in the circumstances set out below:
- As permitted or required by law;
- To regulatory authorities and government agencies in order to comply with applicable laws, regulations and rules;
- To our professional advisers and consultants;
- To service providers who provide services to us such as cloud computing, data analytics, marketing, advertising, payment processing, IT support and other similar services;
- To third parties in connection with a merger, acquisition, or sale of all or a portion of our assets;
- To enforce our Terms of Use or protect our rights, privacy, safety, or property, and/or that of our affiliates, you or others;
- With your consent, to any other person.
8. SECURITY OF PERSONAL INFORMATION
8.1. The security of your Personal Information is important to us. We maintain appropriate technical and organizational measures to protect your Personal Information against loss, misuse, unauthorized access, disclosure, alteration, and destruction.
8.2. While we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security as no method of transmission over the Internet, or method of electronic storage, is 100% secure.
9. RETENTION OF PERSONAL INFORMATION
9.1. We will retain your Personal Information for as long as necessary to provide the Services, comply with our legal obligations, resolve disputes, and enforce our agreements.
9.2. When your Personal Information is no longer required, we will securely delete or anonymize it in accordance with applicable laws.
10. COOKIES AND TRACKING TECHNOLOGIES
10.1. We may use cookies, web beacons, and other tracking technologies to collect information about your use of the Platform. This helps us to improve your user experience, analyze trends, and administer the Platform.
10.2. You can manage your cookie preferences through your browser settings. However, if you disable cookies, some features of the Platform may not function properly.
11. THIRD PARTY SERVICES
11.1. The Platform may contain links to third-party websites, applications, and services. We are not responsible for the privacy practices of these third parties, and we encourage you to read their privacy policies.
11.2. Any information you provide to third-party websites or services is governed by their privacy policies and not by this Privacy Policy.
12. CHILDREN’S PRIVACY
12.1. Our Services are not directed to individuals under the age of 18. We do not knowingly collect Personal Information from children under 18. If we become aware that we have collected Personal Information from a child under 18 without parental consent, we will take steps to delete such information.
13. YOUR RIGHTS
13.1. You have the following rights under applicable data protection laws:
- The right to access your Personal Information;
- The right to request correction of your Personal Information;
- The right to request deletion of your Personal Information;
- The right to object to processing of your Personal Information;
- The right to request restriction of processing of your Personal Information;
- The right to request transfer of your Personal Information; and
- The right to withdraw your consent at any time.
13.2. To exercise your rights, please contact us using the details provided in the “Contact Us” section below.
14. INTERNATIONAL DATA TRANSFERS
14.1. Your Personal Information may be transferred to, and maintained on, computers located outside of Nigeria where the data protection laws may differ. By providing your information, you consent to such transfer.
14.2. We will take all necessary steps to ensure your data is treated securely and in accordance with this Privacy Policy.
15. CONTACT US
15.1. If you have any questions about this Privacy Policy or our data protection practices, please contact us at:
Anchoria Asset Management Limited
[Insert Address]
Email: [Insert Email Address]
Phone: [Insert Phone Number]
16. GOVERNING LAW
16.1. This Privacy Policy shall be governed by and construed in accordance with the laws of the Federal Republic of Nigeria.