Privacy Policy

This Policy applies to all personal data processed by Finesse Capital in connection with its business operations. It covers clients, prospective clients, investors, website users, employees, job applicants, directors, shareholders, vendors, consultants, service providers and any other individual whose personal information is processed by us.

Depending on our relationship with you, we may collect the following categories of personal data:

• Identity data: full name, date of birth, gender, nationality, photograph, and government- issued identification (e.g., NIN, BVN, international passport, driver's licence).
• Contact data: residential and mailing address, email address, and telephone number.
• Financial data: bank account details, income and source of wealth information, investment objectives, risk tolerance, portfolio holdings, and transaction history.
• KYC/Due Diligence data: tax identification number, employment information, politically exposed person (PEP) status, sanctions screening results, and beneficial ownership information for corporate clients.
• Technical data: IP address, browser type, device identifiers, and usage data collected via our website or client portal.
• Communication data: records of correspondence, meeting notes, and call recordings where applicable.
• Any other information necessary to provide our services or comply with legal and regulatory obligations.

We collect personal data directly from you during account opening, client onboarding, investment advisory engagements, correspondence, telephone conversations, meetings and through our website. We may also obtain information from authorized representatives, employers, financial institutions, publicly available sources, regulators, credit reference agencies, identity verification providers, other third parties where permitted by law and automatically, through cookies and similar technologies when you use our website or digital platforms.

Our website and digital platforms use cookies and similar tracking technologies to recognize you, remember your preferences, and understand how our website is used. Further details on the types of cookies we use, their purposes, and how you can manage your cookie preferences are set out in our separate Cookies Policy, available on our website.

We process personal data to establish and manage client relationships; provide wealth management and investment services; perform client due diligence, know-your-customer (KYC) and anti-money laundering/counter-terrorist financing (AML/CFT) checks; assess suitability and risk tolerance; execute transactions; maintain records; respond to enquiries; recruit and manage employees; improve our products and services; detect fraud; protect our legal rights; and comply with applicable legal, tax and regulatory obligations.

We do not sell personal data. We may share personal data, on a need-to-know basis, with:

• Regulators and law enforcement, including the Securities and Exchange Commission, the Central Bank of Nigeria, the Nigerian Financial Intelligence Unit (NFIU), and the Nigeria Data Protection Commission (NDPC), where legally required.
• Service providers, such as custodians, correspondent banks, IT and cloud service providers, and professional advisers, under contractual confidentiality obligations.
• Screening and due diligence providers, such as sanctions and PEP database providers.
• Third parties, where we determine in good faith that disclosure is reasonably necessary to enforce our terms and conditions, protect our operations, or protect the rights, property, or safety of the Firm, our clients, or others.
• Successors, in the event of a merger, acquisition, reorganization, or sale of the Firm or its assets, in which case any and all personal information we collect may be transferred to the relevant third party as part of that transaction.

Information relating to your use of our website is not shared with third parties for their marketing purposes. We do not disclose information about your usage of our website except in the specific cases described in this Policy, and we do not share your information with any unaffiliated third party for marketing purposes unless you expressly give us permission to do so.

Where personal data is transferred outside Nigeria, we ensure appropriate safeguards are in place in accordance with the cross-border data transfer requirements of the NDPA.

Where personal data is transferred outside Nigeria, we will ensure that such transfers are carried out in accordance with the Nigeria Data Protection Act (NDPA) 2023. We will implement appropriate safeguards to protect the personal data, including contractual measures or other lawful transfer mechanisms where required.

We retain personal data only for as long as necessary to fulfil the purposes described in this Policy, including satisfying legal, regulatory, accounting, or reporting requirements. Client due diligence and transaction records are generally retained for a minimum of five (5) years after the termination of the business relationship, or longer where required by applicable law or ongoing regulatory investigation.

We implement appropriate technical and organizational measures to protect personal data against unauthorized access, loss, misuse, or alteration. These measures include access controls, encryption, staff training, and regular review of our security practices. While we take reasonable steps to protect your data, no system can be guaranteed completely secure.

Subject to applicable law, you have the right to:

• Access the personal data we hold about you.
• Request correction of inaccurate or incomplete data.
• Request erasure of your data. We may continue to retain such data, in whole or in part, where there are valid legal, regulatory, or operational reasons to do so.
• Object to or restrict certain processing, including direct marketing. We may continue to process your data where there are valid legal, regulatory, or operational reasons to do so.
• Request that the data you have made available to us be provided to you in a structured, commonly used, and machine-readable electronic format, and/or request that such data be transmitted directly to a third party (data portability).
• Withdraw consent, where processing is based on consent, without affecting the lawfulness of processing before withdrawal.
• Lodge a complaint with the Nigeria Data Protection Commission (NDPC) if you believe your data protection rights have been violated.

To exercise any of these rights, please contact our Data Protection Officer using the details in Section 15 (Contact Us).

Keeping your information accurate and up to date is important to us. Depending on our relationship with you, you may have access to your account information, including account balances, transaction history, and similar information, through means such as account statements or client portals. If you discover any inaccuracy in your personal information, please promptly notify us by contacting our Data Protection Officer and provide any documentary evidence reasonably required to enable us to implement the necessary updates or corrections.

We may interact with users of various social media platforms, including Facebook, Twitter (X), LinkedIn, and Instagram. Please note that any content you post on such platforms, including pictures, information, or opinions, as well as any personal information you otherwise make available on those platforms (e.g., your profile), is subject to the terms and conditions and privacy practices of the applicable social media platform, and not to this Policy. We recommend that you review the privacy policies of any third-party platform before sharing personal information on it.

Our services are not directed at individuals under the age of 18. We do not knowingly collect personal data from minors except where required in the context of estate planning, trusts, or beneficiary designations, and only with appropriate parental or guardian consent.

We may update or revise this Privacy Policy from time to time, including on an ad hoc basis, to reflect changes in our practices, services, or legal requirements. The updated version will be posted on our website with a revised effective date. We encourage you to review this Policy periodically.

For questions regarding this Privacy Policy or the processing of your personal data, please contact the Data Protection Officer.