PRIVACY POLICY

This Privacy Policy sets out your privacy rights and how Split Custodian Limited (the “Company”, “us”, “our” or “we”) uses and protects any information that you give us when you use our Website and services, furthermore, you acknowledge that you have read and understood our Privacy Policy. This Privacy Policy may be revised from time to time, so ensure that you check our Website for the most up-to-date version.

This Privacy Policy outlines our commitment to safeguarding your personal data in accordance with Nigeria’s data protection laws. We collect and utilize personal information from our guests, employees, vendors, and other stakeholders. Personal Data includes any information that can identify an individual, such as names, addresses, phone numbers, identification documents, usernames, passwords, digital footprints, photographs, financial details, health information, and any other data related to products and services you purchase from us (collectively referred to as “Personal Data” or “Personal Information”). We ensure that your personal information is handled with care and confidentiality. This includes implementing security measures to protect against unauthorized access and ensuring that data is only retained for as long as necessary for the purposes outlined in this policy. By using our services, you expressly consent to the collection and processing of your Personal Data as described herein.

We use the personal data we collect to enhance and deliver our services effectively. By engaging with our website, and related digital platforms, you expressly consent to the collection and use of your Personal Data as described in this Privacy Policy. If you do not consent to this, you have the right to withdraw your consent at any time. Please note that withdrawing your consent may limit your use of our website and our ability to provide certain services to you. We encourage you to read this Privacy Policy thoroughly, as it outlines how we will process any personal data that we collect from you or that you provide to us. Your understanding and agreement are essential for us to serve you better while respecting your privacy.

THE INFORMATION WE COLLECT

When you use our website or services, we may collect certain types of information about you including the following:

a. Information you provide to us
We collect personal information about prospective clients and their beneficial owners or controllers as part of business development initiatives and our business acceptance process. This includes, but is not limited to, your Personal Data (such as your full name, nationality, phone number(s), email address, date of birth, home or office addresses, location, business interest and employment history.

b. Information collected automatically
This includes but is not limited to your IP address, browser type, mobile device ID, device type, operating system version, connection information, mobile network information, location derived from GPS-enabled services, information based on your usage of the service such as time, date and duration of your use, referral URLs, search terms and search history, browsing history and advertisement interactions.

c. Information we obtain from third parties
We may retrieve additional Personal Information about you from third parties and other identification/verification services such as your financial institution and payment processor. With your consent, we may also collect additional Personal Information in other ways including emails, surveys, and other forms of communication. We will not share or disclose your Personal Information with a third party without your consent except as may be required for the purpose of providing you with our services or under applicable legislation.

In providing you with our services, we may rely on third-party servers located in foreign jurisdictions from time to time, which as a result, may require the transfer or maintenance of your personally identifiable information on computers or servers in foreign jurisdictions. We will endeavour to ensure that such foreign jurisdictions have data protection legislation that is no less than the existing data protection regulations in force in Nigeria and your personally identifiable information is treated safely and securely.

WHY WE COLLECT YOUR INFORMATION

We collect your information to ensure your easy and seamless access to our services. We use the information we collect for the following purposes:

1. To enable us to provide you with a personalized experience of our product and services.
2. To communicate with you and provide you with information on our programmes and initiatives, such marketing content, newsletters and service updates. However, we will provide you with an option to unsubscribe if you do not want to hear from us.
3. To provide support services to you.
4. To analyse and implement your instructions.
5. To protect against illegal, malicious, and fraudulent activity.
6. To analyse and improve the quality of our services and offerings.
7. To facilitate your interactions with our social media platforms.
8. To analyse and learn about our users’ demographics, interests, and behaviour.
9. To identify and repair errors and bugs on our websites.
10. To facilitate dissemination of information about our services and our partners.
11. To facilitate updating of our internal records.
12. To consider your application for a position at our Firm and as part of our recruitment process.

We are committed to treating your information with the utmost confidentiality and only sharing with our third-party service providers involved in designing and providing our products and services.

SHARING YOUR INFORMATION WITH THIRD PARTIES

We may sometimes share the information we have collected from you with third parties. These third parties include our affiliates, subsidiaries, partners, third-party vendors and suppliers who render services for us or on our behalf and our professional advisers (such as our auditors, accountants etc.). We may share the information to facilitate the seamless delivery of our services or in compliance with applicable legal requirements and assisting law enforcement agencies by responding to requests for the disclosure of information in accordance with local laws.

COOKIE POLICY

We use cookies to identify you as a User and make your user experience easier, customise our services, content and advertising; help you ensure that your account security is not compromised, mitigate risk and prevent fraud; and to promote trust and safety on our website. Cookies allow our servers to remember IP addresses, date and time of visits, monitor web traffic and prevent fraudulent activities.

Our cookies never store personal or sensitive information; they simply hold a unique random reference to you so that once you visit the site we can recognize who you are and provide certain content to you.

If your browser enables browser add-on permits, you have the choice to disable cookies on our website, however this may impact your experience using our website.

GOVERNING PRINCIPLES OF DATA PROCESSING

We process your information in accordance with the provisions of the Nigeria Data Protection Regulation (“NDPR”) and these principles:

1. Your Personal Data is collected and processed in accordance with specific, legitimate and lawful purposes (all of which are provided under section 2.2 of the NDPR 2019), provided that further processing may be done by archiving the data, subject to our retention period.
2. The data collected is adequate, accurate and without prejudice to the dignity of the human person.
3. The data collected is stored only for the period within which it is reasonably needed, or if your consent is withdrawn.
4. The data collected is secured against all foreseeable hazards and breaches such as theft, cyberattack, viral attack, dissemination, manipulations of any kind, damage by rain, fire or exposure to other natural elements.
5. We owe a duty of care to you in respect of the data we have obtained from you.

DATA SECURITY AND PROTECTION

We store the information collected from you while providing our services in a secure environment. We have implemented appropriate safeguards to protect against loss, unauthorized access, disclosure, misuse, and modification of your information. These measures are continuously updated to stay in line with current practices and realities.

Where we have authorized certain information such as username, password and/or PIN for you on our website, it is your responsibility to keep these details confidential.

DATA RETENTION PERIOD

We may retain Personal Information about the User, as long as it is necessary for business and/or legal purposes. Also, we may retain aggregated anonymous information indefinitely.

In addition, we may retain your information for an additional period as is permitted or required to, among other things, comply with our legal obligations, resolve disputes, and enforce agreements.

All Personal Information shall be destroyed by the Firm where possible. For all Personal Data and records obtained, used and stored by the Firm, we shall perform periodical reviews of the data retained to confirm the accuracy, purpose, validity and requirement to retain.

The length of storage of Personal Information shall, amongst other things, be determined by:

• the contract terms agreed between the Firm and the Data Subject or as long as it is needed for the purpose for which it was obtained; or
• whether the transaction or relationship has statutory implication or a required retention period; or
• whether there is an express request for deletion of Personal Data by the Data Subject, provided that such request will only be treated where the Data Subject is not under any investigation which may require the Firm to retain such Personal Data or there is no subsisting contractual arrangement with the Data Subject that would require the processing of the Personal Data; or
• whether the Firm has another lawful basis for retaining that information beyond the period for which it is necessary to serve the original purpose.

LINKS TO THIRD PARTY WEBSITES

Our website, products and services may contain links to other websites not subject to this Privacy Policy. When you access those websites, they may collect your Personal Information in accordance with their privacy and data collection policies. We are not responsible for the data collected by these third parties and you are advised to study their privacy policies as Split Custodian shall not be held liable for any breach of confidentiality by the third parties.

YOUR PRIVACY RIGHTS

By providing us with your Personal Information, you have certain rights in accordance with the provisions of the Nigeria Data Protection Regulation which include:

• the right to request for your Personal Data in our possession;
• the right to object to the processing of your Personal Data;
• the right to request transfer of your Personal Data to another organization;
• the right to request rectification and modification of Personal Information which we keep; and
• the right to request for the deletion of your Personal Data in our possession.

To exercise any of the rights listed here, please contact us through the details provided below. All such requests will be reviewed and considered in accordance with the provisions of the applicable data protection regulations.

You also have the right to opt-out of receiving the informative materials we send to our Users by clicking the “Unsubscribe” button found at the bottom of such emails. You also have the right to decline to provide your Personal Information when it is requested, however, certain services or all the services may be unavailable to you.

CONTACT DETAILS

If you have questions regarding your data privacy rights or would like to submit a related data privacy right request, please email us at info@Splitcustodian.com. Please allow up to 30 days for requests to be processed. The Firm reserves the right to charge a reasonable fee to process excessive or repeat requests.

If you have general questions concerning this Privacy Policy, please contact us at: info@Splitcustodian.com.

UPDATES TO THIS POLICY

We reserve the right to revise this Privacy Policy at any time to reflect changes in its operating, legal and regulatory environment. Any updated version of the Privacy Policy shall be posted on this website, and shall become effective as at the time it is posted.