Asset & Resource Management Holding Company Limited and its subsidiaries (hereinafter called “the ARM Group”/ “We”/ “Our”) treats personal information of users (“Users”/ “You”/ “Your”) of the ARM Website “www.premiumwealth.arminvestmentmanagers.com” and its other digital platforms (hereinafter called the “Site”) as private and confidential.
This Policy applies to usage of the Site as well as information contained on the Site, particularly, information related to products and services offered by the ARM Group.
The ARM Group is committed to ensuring that Your privacy is protected. Should We ask You to provide certain information by which You can be identified when using this Website, then You can be assured that it will only be used in accordance with this Policy.
What we collect
We may collect the following Personal Data:
Personal identification information – We collect and use information about You to administer Our business. Information collected shall include
· Your contact information such as Name, contact address, email addresses, gender, and telephone numbers and details of next of kin;
· Demographic information;
· Occupation, Career history, professional background and other CV related information;
· International and National passport, driving license or any other form of proof of identification;
· Transactional data, including financial details, your photograph; and
· And any other information We may deem necessary and which may be determined by extant Nigerian laws and regulations.
We may collect personal identification information from you in a variety of ways, including, but not limited to, when you visit our Site, register on the Site, make payments for our products and services, subscribe to Our newsletter, respond to a survey, or fill out a form, and in connection features or resources made available on our Site.
Non-personal identification information – This is information received whenever You interact with Our Site. Non-personal identification information may include:
· Unique IDs such as your mobile device identifier or cookie ID on your browser;
· IP address and information that maybe derived from IP address, such as geographic location; and
· Information about a device you use, such as browser, device type, operating system and the internet service providers utilized.
Other information relevant to customer surveys and/or offers
Why we collect your Personal Data
All Personal Data which we collect, and process is justified by lawful processing on the legitimate basis that:
· You have given consent to the processing;
· Processing is necessary for the performance of a contract to which you are a party or take steps to enter into a contract;
· Processing is necessary for compliance with a legal and regulatory obligations to which we are subject;
· Processing is necessary in order to protect your vital interests or another natural person; and
· Processing is necessary for the performance of a task carried out in the public interest.
What we do with the information we gather?
We require this information to understand your needs, and provide you with better service, particularly with regard to the following:
· Internal record keeping;
· To respond to your enquiries about the ARM Group;
· To improve our products and services;
· To improve customer service delivery;
· To send promotional emails about new products, special offers or other information which we think you may find interesting using the email address which you have provided;
· To contact you occasionally for market research purposes. We may contact you by email, phone, fax or mail;
· To deliver technical and functional management on our site;
· To provide specific services in accordance with an agreement you are entering, or have entered into with us;
· To manage the security of our sites, networks and systems;
· To comply with applicable laws and regulations and to operate our business;
· To run a promotion, contest, survey or other site features; and
· To improve our Site through feedback you provide on our products and services.
The ARM Group will not share with other parties, information which you may provide when using the Site, except to the extent necessary to provide services to you, further, to obtaining your consent.
With your express consent, we will share your personal data among subsidiaries within the ARM group, only to the extent of your permission, and which is necessary to provide services to you. In this case, your right to withdraw consent shall be exercisable at all times.
We may wish to share with you, information about our products and services which we think you may be interested including those of our subsidiaries. If you have agreed to receive marketing materials, you can always opt-out at a later date. You reserve the right at any time and at no cost to you, to stop us from contacting you for marketing purposes or giving your data to our subsidiaries
How we collect Personal Data
We collect information about you and any other party whose details you provide to us when you:
· Provide feedback on our products and services to improve our Site;
· Complete online forms;
· Take part in surveys;
· Interact with us using our social media platforms;
· Download information such as publications or participate in any other interactive areas that appear on our website or portals;
· Contact us offline, for example by telephone, SMS, email, post or any other means of communication;
· Access and use any of our websites or portals from your devices (including mobile devices) and applications; and
· Share Personal Data with third parties that are entitled to share that data, but in each case as permitted by applicable laws.
Where We Store Your Personal Data
The Personal Data that we collect from you will be transferred to and stored at destinations within Nigeria. By submitting your Personal Data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your Personal Data is treated securely and in accordance with this Policy.
Cookies are a kind of short-term memory for the web. They are stored in your browser and enable a site to ‘remember’ little bits of information between pages or visits. Cookies can be used by web servers to identify and track users as they navigate different pages on a website, and to identify users returning to a website. Cookies may be either “persistent” cookies or “session” cookies. A persistent cookie consists of a text file sent by a web server to a web browser, which will be stored by the browser and will remain valid until its set expiry date (unless deleted by the user before the expiry date). A session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
Our Website cookies
We use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on Your device until you delete them). We need the cookies to enable technical performance of Our websites and allow us to ‘remember’ the choices you make and your preferences (Functionality) and to allow us collect certain information about how You navigate the Sites (Performance/Analytical).
By this, we are able to understand which parts of Our websites are interesting to You and which are not, as well as what We can do to improve them.
Cookies do not contain any information that personally identifies You, but Personal Data that We store about You may be linked, by us, to the information stored in and obtained from cookies. The cookies used on Our website include those which are strictly necessary for access and navigation, cookies that track usage (performance cookies) and those used to remember your choices (functionality cookies). We may use the Personal Data We obtain from Your use of our cookies for the following purposes:
· To provide you with a better website experience by enabling us to monitor which pages You find useful and which you do not;
· To recognise Your computer and track you when You visit Our website;
· To retain investors’ email addresses and passwords when they log in to Our investment centre; and
· To analyse the use of Our website – such as how many people visit us each day.
Accepting, Declining and Disabling Cookies
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but You can usually modify your browser setting to decline cookies if you prefer. However, this may prevent you from taking full advantage of the website. You can also disable cookies if You wish. However, this will affect the functionality of Our website and many other websites that You visit. Disabling cookies will usually result in also disabling certain functionality and features of this site. Therefore, it is recommended that you do not disable cookies.
Links to other websites
Controlling your Personal Data
You may choose to restrict the collection or use of your Personal Data in the following ways:
· If You have previously agreed to us using Your Personal Data for direct marketing purposes, You may change Your mind at any time by emailing us at firstname.lastname@example.org.
We will not sell, distribute or lease Your Personal Data to third parties unless we have Your permission or are required by law to do so. We may use Your Personal Data to send You promotional information about third parties which We think You may find interesting subject to your written permission to do so.
How we protect your Personal Data
We are committed to ensuring that Your Personal Data information is secure. In order to prevent unauthorised access or disclosure, We have put in place reasonable physical, electronic and managerial procedures to safeguard and secure the Personal Data We collect online.
In particular, We adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of Your personal transaction information and data stored on our Site.
Sensitive and private data exchange between the Site and its Users happens over a secured communication channel and is encrypted and protected. Transactions are also handled over a secure payment gateway. Also, the ARM Group has implemented appropriate technical, physical and organisational measures designed to protect Personal Data against accidental or unlawful destruction, accidental loss, damage, alteration, unauthorised disclosure or access, as well as all other forms of unlawful processing.
Retention of your Personal Data
We maintain Personal Data not longer than we need to use it in accordance with the ARM Group’s Data Retention Policy. In some circumstances, we may retain your Personal Data for longer periods if it is in accordance with regulatory, legal, tax or accounting obligations. The ARM Group has an established retention procedure it applies to records and Personal Data collected and stored. In all cases, where your Personal Data is no longer required or you request for deletion, we will ensure it is disposed of in a secure manner.
Sharing your Personal Data
We do not sell, trade, or rent Users Personal Data to others. We may share generic aggregated demographic information not linked to any Personal Data regarding visitors and users with our business partners, trusted affiliates and advertisers for the purposes outlined above. We will not disclose Your Personal Data to anyone outside the ARM Group without Your consent to do so unless one of the following circumstances applies:
1. With your consent
We will share Personal Data with companies, organizations or individuals outside of the ARM Group when We have your consent to do so. We shall obtain your consent before sharing of any sensitive Personal Data.
2. Processing of Personal Data of minors
Where we collect the Personal Data of a minor, we shall obtain the consent of a parent or guardian and we shall ensure that the purpose of processing or collecting the Personal Data is clear to both the minor and the parent or guardian.
3. For external processing
4. For legal reasons
We will share Personal Data with companies, organizations or individuals outside of the ARM Group if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:
· meet any applicable law, regulation, such as the Nigeria Data Protection Regulation (NDPR), legal process or enforceable governmental request.
· detect, prevent, or otherwise address fraud, security or technical issues.
protect against harm to the rights, property or safety of the ARM Group, our Users or the public as required or permitted by law.
Your acceptance of these terms
By using this Site, You signify Your acceptance of this policy. If You do not agree to this policy, please do not use Our Site. Your continued use of the Site following the posting of changes to this policy will be deemed Your acceptance of those changes.
Accessing and updating your Personal Data
Whenever You use Our services, We aim to provide You with access to Your Personal Data. If that Personal Data is wrong, We strive to give You ways to update it quickly or to delete it – unless We have to keep that Personal Data for legitimate business or legal purposes. When updating Your Personal Data, We may ask You to verify Your identity before We can act on Your request.
We shall, at your request, can confirm what Personal Data We hold about You and how such Personal Data is processed. The following Personal Data are available upon Your request.
· Contact details of the Data Protection Officer, where applicable;
· The purpose of the processing as well as the legal basis for processing;
· The categories of Personal Data collected, stored and processed;
· Recipient(s) or categories of recipients that the data is/will be disclosed to;
· Information about how We ensure transfer of Personal Data to a third party or international organisation is done securely. The Attorney General of the Federation will approve sending Personal Data to some countries because they meet a minimum standard of data protection. In other cases, We will ensure there are specific measures in place to secure your information;
· How long the data will be stored;
· Details of Your rights to correct, erase, restrict or object to such processing;
· Information about Your right to withdraw consent at any time;
· How to lodge a complaint with the supervisory authority, National Information Technology Development Agency (NITDA);
· Whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the Personal Data and the possible consequences of failing to provide such data;
· The source of Personal Data if it was not collected directly from you; and
· Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.
Your Rights as a Data Subject
At any point while we are in possession of or processing your Personal Data, You, the data subject, have the following rights:
· 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 Erased/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 (to be reused for Your own purposes)
· 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
· Right to Withdraw – You have the right to withdraw Your consent at any time
Dispute Resolution or Filing A Complaint
You acknowledge and agree that it is Your responsibility to review this Policy periodically and become aware of modifications. This Privacy Notice or Policy was last updated on February 25, 2021. The most up-to-date version can be found on this website.
Compliance with the Regulations
According to the Regulation, ARM Group shall notify NITDA within 72 hours of knowledge of a breach of security leading to accidental or unlawful destruction, loss, alteration unauthorized disclosure of, or access to your Personal Data.
If you feel that your Personal Data has not been handled correctly or you are unhappy with our response to any requests you have made to us regarding the use of your Personal Data, you have a right to lodge a complaint with the NITDA. The contact details are:
National Information Technology Development Agency
Tel: +234929220263, +2348168401851, +2347052420189
Contact details of the Data Protection Officer:
Contact Name: Abayomi Apoeso
Telephone: + 234 (1) 2701653