Data Privacy Policy

Data Privacy Policy

1. Introduction

The protection, security and privacy of your personal information is important to us at NEM ASSET MANAGEMENT COMPANY LIMITED and to the way we conduct our business in compliance with extant laws on privacy, data protection and data security. The purpose of this Policy is to outline what information we may collect, how we use and safeguard that information and with whom we share it.

At NEM ASSET MANAGEMENT COMPANY LIMITED, we are committed to maintaining the highest standards of integrity in our business. In conducting our business, it is necessary to obtain, handle, process, disclose, transfer and store information about our clients. We take these activities seriously and seek to provide fair, secure and appropriate methods that are consistent with both generally accepted privacy ethics and standard business practices when carrying them out.

If you have any comments or questions about NEM’s ASSET MANAGEMENT COMPANY LTD Data Protection and Privacy Policy, please contact our Customer Support Team via info@nemasset.com

2. Personally Identifiable Information (PII)

Through our websites, we will not collect any personally identifiable information about you (e.g your name, address, telephone number or email address) unless you voluntarily provide it either by registration on our website, email, enquiry, survey etc. By using and/or submitting your personal information on our website, you consent to us using your personal information as described below. You also consent to us transferring your personal information where it is done in connection with us providing services to you or where it is necessary for us to fulfil our legal obligations.

By clicking on the “accept” button or by ticking the “accept” box, you are accepting and consenting to the practices, terms and conditions described in this Policy.

Note that you can withdraw your consent at any time. However, such withdrawal of consent would not affect the lawfulness of processing information based on consent given before its withdrawal.

3.  How does NEM ASSET collect your information

We collect the content, communication and other information you provide to us when you use any of our products and services. These include when you do the following:

1. Fill forms, questionnaires or surveys;
2. Provide debit card details (such as when purchasing products from us);
3. Contact us with an enquiry or ask us to provide you with information;
4. Register on our website or leave any comments or reviews;
5. Attend any of our promotional events;
6. Inform us of your marketing preferences; and/or communicate with us via social media websites, third party apps or similar information we collect about

4.  Information that is automatically collected

Regarding each of your visits to our website, office or the use of our products, we may collect the following information:

1. Technical information, including the Internet Protocol (IP) address used to connect your computer to the internet, your login information, browser type, time zone setting, browser plugin types and versions, operating system and platform;
2. Information about your use of our website (including date and time), details of transactions you carry out, interaction information, record of any correspondence between us and any phone number used to call our customer service number;
3. Information about your visit(s) from your IP address, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products or services you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks and mouseovers), and methods used to browse away from the information we receive from other sources

5. How does NEM ASSET use your information

We may use your information for any one or more of the following purposes:

1. To confirm your identity;
2. To maintain your personal profile;
3. To manage your account and keep you updated on all matters that concern your account;
4. To provide the services to you that you have requested, including processing transactions;
5. To contact you when necessary or appropriate in relation to the services being rendered or provided to you;
6. To tailor the content displayed to you;
7. To carry out our obligations arising from any contracts entered between you and us and to provide you with the information, products and services that you request from us;
8. To provide you with information about other services we offer that are similar to those that you have already purchased or enquired about;
9. To notify you about changes to our service;
10. To ensure that content from our product is presented in the most effective manner for you and for your computer;
11. For internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
12. To improve our product to ensure that content is presented in the most effective manner for you and for your device;
13. To enable you to participate in interactive features of our service, when you choose to do so;
14. To measure or understand the effectiveness of advertising and to deliver relevant advertising to you;
15. To make suggestions and recommendations to you and other users of our products, about services that may interest you or We will use the information provided by you, to provide you, or permit selected third parties to provide you, with information about services we feel may interest you.

If you are an existing customer, we will only contact you by electronic means (e- mail or SMS) with information about services similar to those, which were the subject of a previous investment transaction. If you are a new customer, and where we permit selected third parties to use your data, we or the third party will contact you by electronic means only if you have consented to it. If you do not want us to use your data in this way, or to pass your details on to third parties for any purposes, you may unsubscribe from promotional emails via a link provided in each email.

6. Disclosure of your Personal Information

We will usually not share your personal information with third parties without your consent. Where we need to disclose/transfer your personal information to another country, such country must have an adequate data protection law. We will seek your express consent where we need to send your personal information to a country without an adequate data protection law.

However, you agree that we have the right to share your personal information with:

1. Any member of our group, which means other subsidiaries in our group as defined under the Companies and Allied Matters Act, 2020,
2. Authorized employees of NEM Asset Management Company Limited only for the purpose of resolving issues associated with the use of our selected third parties including,business partners, suppliers or subcontractors for the performance of any contract we enter into with them;
3. Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to our advertisers, but we will provide them with aggregate information about our users. We may also use such aggregate information to help advertisers reach the kind of audience they want to target;
4. Analytics and search engine providers that assist us in the improvement and optimisation of our corporate and products

We may also share your personal information without your consent in any of the following situations:

1. If we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect the rights, property, or safety of NEM Asset Management Company Limited, our employees, contractors, clients, or others;
2. Where we are requested to provide information by authorized third parties or regulatory/governmental agencies investigating illegal activities;
3. In the event that we sell or buy any business or assets, in which case we will disclose your personal information to the prospective seller or buyer of such business or assets;
4. If NEM Asset Management Company Ltd or substantially all of its assets are acquired by a third party, in which case personal information held by it about its clients will be one of the transferred assets;
5. Where you register to attend any of our events including seminars and conferences which are sponsored by third parties and we are required to share your personal information with those third parties;

7.  Legal Basis for Processing of Personal Information

The legal basis for processing will depend on the purpose for which we have collected and use your personal information. The legal basis for processing is any of the following:

1. Consent: This will apply where you have provided your consent to the processing of your personal information for one or more specific purposes;
2. Performance of a contract: This will apply where processing is necessary for the performance of a contract to which you are a party or in order to take steps prior to entering into a contract with you;
3. Protection of vital interests: This is where processing is required for the protection of your vital
4. Compliance with Extant Laws: Where we are subject to a legal obligation and need to use your personal information for legal/regulatory purposes.
5. Public Interest: Where processing is necessary for the performance of a task or function carried out in the interest of the public.

8. Privacy by Design

When designing and implementing a new business or technological process involving the collection or use of personal information, we will take into consideration, among its other considerations, the need for structured privacy planning for this process. The Company shall collect only such information as is necessary for the execution of its business processes

9. Security

The Company adopts robust technological and procedural safeguards to protect personal information. Measures are in place to prevent unauthorized access, unlawful processing, and to guard against accidental loss, destruction, or damage.

Users are responsible for safeguarding the confidentiality of passwords used to access restricted areas of the website and should not disclose them to any third party. The Company has also adopted controls in line with global Information Security Management Systems (ISMS), supported by both digital and physical security measures, to prevent or mitigate data privacy breach incidents.

10. Where we Store your Personal Information

The data that we collect from you will be transferred to and stored at destinations within and outside Nigeria. By submitting your personal information, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

11. Retention of Information

Your personal information will not be retained for longer than the purposes for which it was processed unless a longer retention period is required or permitted by law.

12. Your Rights

The law gives you certain rights in respect of the information we hold about you. Below is a highlight of some of those rights. It is however not a complete, exhaustive statement of your rights in respect of your personal information.

1. Right to consent to this Privacy Policy and to withdraw your consent at any time you deemed fit
2. Right to a copy of the personal data we hold about you, as well as the information about what we do with it, who we share it with and how long we hold it. Charges may apply for excessive requests.
3. The right to freely transfer your data received from you
4. Right to have the information we hold about you corrected, if it is factually inaccurate. You may contact us for this
5. Right to the deletion of the information that we hold about you
6. Right to lodge a complain about the handling of your personal information with the Nigeria Data Protection Commission (hereinafter referred to as NDPC).
7. Right to ask us not to process your personal information for marketing. We will usually inform you (before collecting your personal information) if we intend to use your personal information for such purposes or if we intend to disclose your personal information to any third party for such purposes.

Where we do not act on your request to exercise any of your rights, we shall inform you within one month of the receipt of your request, of the reasons for not taking action and on the possibility of lodging a complaint with NDPC.

NDPC’s website (https://ndpc.gov.ng/) has a wealth of useful information in respect of your rights over your personal information. If you wish to exercise your rights, you may contact our office at info@nemasset.com.

13.  Changes to our Data Protection and Privacy Policy

Any changes or amendment we make to this Policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please visit this page frequently to see any updates or changes to this Policy.

14. Governing Law

This Data Protection and Privacy Policy is governed by the Nigeria Data Protection Act, 2023. All procedures, practices, and principles outlined herein are in compliance with the obligations and responsibilities imposed under this Act to ensure your personal data is processed lawfully, fairly, and transparently.

15. Contact

Questions, comments and requests regarding this Data Protection and Privacy Policy are welcomed and should be addressed to: info@nemasset.com or to our head office at 199, Ikorodu Road, Obanikoro, Lagos, Nigeria.