Introduction
At Cytonn Investments Management Plc (“Cytonn” or “We) value and respect your privacy and are committed to protecting your personal information. This Privacy Policy describes the basis by which we collect, use, transfer, disclose and process your personal data in order to maintain your account with us.
By accepting this Privacy Policy you are accepting and consenting to the practices described in this policy.
Information Collection and Use
We acknowledge that we may require certain information from you to serve you better and offer a superior user experience while using our services. Prior to collection, we shall request that you accept this data privacy policy. This information is collected and used in the following ways:
-
During Application - The data you submit when you open an account comprises, personally identifiable information such as Name, Email, Phone Number Identification number, date of birth, and phone number.
-
Data collected through the app permissions - Cytonn App will request your permission to access your contact list, files and images. Once this information is granted, the App can collect your contact list and upload images and files from your device. This data will enable us to provide a better user experience when sending money to your contacts instead of manually entering and typing the number which is prone to errors. Uploading image files will assist you in uploading proof of payment receipts whenever you make a bank deposit which in turn will assist us in verifying and validating your investments faster.
-
With regard to each of your visits to our site, we may automatically collect the following information:
- Technical information, including the Internet protocol (IP) address used toconnect your computer to the Internet, your login information, browser typeand version, time zone setting, browser plug-in types and versions, operatingsystem and platform;
-
Information about your visit, including the full Uniform Resource Locators(URL) clickstream to, through and from our site (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.
How We Use Your Personal Information Collected
We will use this information:
-
For Know Your Customer (KYC) purposes in compliance with laws and regulations.To manage risk, security and crime prevention which will include; Detection, prevention, investigation and reporting of fraud and money laundering; Security detection to verify your identity.
- to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
- to provide you with information about other products we offer that are similar to those that you have already purchased or enquired about;
- to provide you with information about products we feel may interest you;
- to notify you about changes to our products;
- to ensure that content from our site is presented in the most effective manner for you and for your computer.
- to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
- to allow you to participate in interactive features of our service, when you choose to do so;
- as part of our efforts to keep our site safe and secure;
- to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
- to make suggestions and recommendations to you and other users of our site about products that may interest you or them.
Disclosure of your information
We may share your personal information with any member of our group, which means our subsidiaries and affiliates in any part of the world.
We may share your information with selected third parties including:
- Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them;
- Analytics and search engine providers that assist us in the improvement and optimisation of our site;
- Credit reference agencies for the purpose of assessing your credit score only where this is a condition of us entering into a contract with you;
We may disclose your personal information to third parties:
- In the event that we sell or buy-back any products, solutions or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
- If Cytonn or substantially all of its business and/or assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets;
- If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of and other agreements; or to protect the rights, property, or safety of Cytonn, our customers, or others. This includes exchanging information with regulators, other companies and organizations for the purposes of fraud protection and credit risk reduction.
We may process all or part of the data availed to you by us by means of automated processing.
- Where your data is processed in the manner prescribed above, you shall have the right to request that that decision be reconsidered or a new decision be made not based solely on automated processing.
General inquiries
- If a user contacts us with a general inquiry, the user may need to provide us with personal information (including but not limited to; personal biodata and contact details).
- We will use this personal information to respond to the inquiry and track further correspondence.
- The information will also be used to compile statistics on response handling.
- This information is generalized and no individual names or personal information are retained or used for any other purpose.
Subscriptions
You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us.
Data Security
Our information security policies and procedures follow international standards, and are reviewed regularly and updated as necessary to meet our business needs, changes in technology, and regulatory requirements.
We ensure that the data we store is encrypted and our systems are audited periodically. The access to personal data is monitored, recorded and restricted to only those employees who need such access in the course of their work. We shall also integrate necessary safeguards into data processing by default.
Consumer Access and Data Portability
The client reserves the right to access their data at any given time. Any such request shall be made formally through Cytonn’s client services’ email- clientservices@cytonn.com. Cytonn shall comply with any such request within seven days of receipt of the request.Within these seven days, Cytonn will take necessary steps to verify the validity of the person and request using the personal information presented during registration either in writing or through a phone call.Upon receiving verifiable customer requests to receive their personal data, we shall take steps to promptly disclose and deliver the personal data requested in a portable and where technically feasible, in a readily usable format which can be easily transmitted to anotherentity.
Storage of personal data
We retain personal information for as long as we reasonably require it for legal or business purposes. In doing so, we take into account all applicable laws, contractual obligations, and the wishes of our customers. When we no longer need personal information, we securely delete or destroy it.
Your personal information may be transferred to, accessed from and stored in servers and facilities located in another country. Cytonn will take the necessary steps intended to ensure that the information continues to be protected wherever it is located.
Consent
You have the right to withdraw your consent for the use of any of your personal data that has been provided to us. You may do so by communicating your withdrawal to Cytonn using any of our communication platforms.
Access, Rectification and Deletion of your personal data
You may have access to your personal information upon your request, subject to any legal requirements in force at the time.
You have the right to request at any time that your data as stored by us be rectified or deleted, following which we will rectify or delete your data to the extent that shall is allowable by any applicable written law.
Filing a complaint
We are willing to hear and rectify any complaint that you have with regard to the handling of your personal data.
You also have the right to complain about the manner in which your personal data has been handled by us to any data protection regulator.
