Privacy Policy

Last updated: November, 2024

This privacy policy (this “Policy”) explains how personal information is collected, used, stored, and disclosed by Parthian Partners Limited, (“i-investng.com,” “we,” “us,” and “our”). This Policy applies to consumer users (individually referred to as “you”) of our websites, applications, and other online services to which this Policy is posted (collectively, our “Services”). This Policy is part of our Terms of use By accessing or using our Services, you agree to this Policy and our Terms of Use. The provisions contained in this Policy supersede all previous notices and statements regarding our privacy practices with respect to our Services. If you do not agree to every provision of this Policy and our Terms of Use, you may not access or use our Services.

Application of this Privacy Policy

This Policy applies to your use of (regardless of means of access) our Services. You may access or use our Services through a mobile phone, tablet, or other consumer electronic device (each, a “Device”). This Policy stipulates the basis for the collection, use, and disclosure of personal information from users of our Services in line with the Nigeria Data Protection Act 2023, the Nigeria Data Protection Regulations 2019, and other relevant data protection laws that governs the collection and processing of personal information (collectively referred to as “Data Protection Laws”).

Information We Collect

Information You Provide Us

In general, you can visit https://www.i-investng.com"https://www.i-investng.com without telling us who you are or revealing any information about yourself. When you submit an inquiry via our Services or download our application and sign up, we may collect personal information from you, which may include your name, email address, mobile phone number, banking information, residential address, identity documents, signature and other information that identifies you (collectively, “Personal Information”). By providing your Personal Information to us, you expressly agree to our collection, use, storage, and disclosure of such information as described in this Policy.

 

We may also ask you to create login information for your i-invest account, such as a username and password. When you provide your mobile phone number, we may ask for your consent to receive text messages relating to our Services with the provided mobile phone number.

Information About Your Transactions

We collect Personal Information about your transactions with us and others.

Information From Third Parties

We also collect Personal Information about you from other sources. For instance, we may receive Personal Information about you from the federal government.

Information Automatically Collected

We (or our service providers acting on our behalf) may collect information about your use of our Services. This information may include Personal Information as well as statistical information that does not identify you (“Analytics”). Some Analytics may be correlated with Personal Information. When Analytics are, directly or indirectly, associated or combined with Personal Information, such Analytics will be considered Personal Information for purposes of this Privacy Policy.

Information that we automatically collect in connection with your access or use of our Services may include:

Device Information: We may collect Device-specific information (such as hardware model, operating system version, unique Device identifiers, and mobile network Information, including your mobile phone number). We may associate your Device identifiers or mobile phone number with your i-invest account.

Log Information: We may record or log information from your Devices, their software, and your activity accessing or using our Services. This information may include:

The Device’s Internet Protocol (“IP”) address.

Identification numbers associated with your Devices.

Device event information, such as crashes, system activity, and hardware settings.

Location preferences.

Date and time stamps of transactions.

System configuration information.

Other interactions with our Services.

Information Collected Through Cookies and Similar Technologies

We use cookies to personalize our Services for you and to collect aggregate information about usage of our Services. A cookie is a text file or other local storage identifier provided by your browser or associated applications. We use cookies for record-keeping purposes and to enhance the quality of your use of our Services. The cookies assign random, unique numbers to your Devices to enable our systems to recognize your Devices and to allow us to see how you use our Services. Additional general information about cookies and how they work is available at www.allaboutcookies.org

The cookies we use in connection with our Services include:

  • Session cookies: Session cookies are temporary cookies that expire and are automatically erased whenever you close your browser window. We use session cookies to grant users access to content and to enable actions they must be logged into their i-invest account to perform.
  • Persistent cookies: Persistent cookies usually have an expiration date in the distant future and remain in your browser until they expire or you manually delete them. We use persistent cookies to better understand usage patterns so we can improve our Services. For example, we may use a persistent cookie to associate you with your i-invest account or to remember your choices for our Services.
  • Third-party cookies: We permit certain third parties to place cookies through our Services to provide us with better insights into the use of our Services and user demographics and to advertise our Services to you. These third parties may collect information about your online activities over time and across different websites when you access or use our Services. For example, we utilize Google Analytics to analyze usage patterns for our Services. Google Analytics generates a cookie to capture information about your use of our Services, which Google uses to compile reports on website activity for us and to provide other related services. Google may use a portion of your IP address to identify its cookie, but this will not be associated with any other data held by Google. We may also permit third-party service providers to place cookies for our Services, as indicated above, to perform analytic or marketing functions where you are notified of them and you have consented to the usage. We do not control the use of such third-party cookies or the resulting information, and we are not responsible for any actions or policies of such third parties.
By accessing or using our Services, you consent to the placement of cookies on your Devices as described in this Privacy Policy. If you prefer not to receive cookies through our Services, you may control how your browser responds to cookies by adjusting the privacy and security settings of your web browser. Unless you set your browser settings to refuse all cookies, our system may issue cookies when you access or use our Services. If you set your browser settings to refuse all cookies, the performance of certain features of our Services may be limited or not work at all.

Do-Not-Track Signals

Do Not Track (“DNT”) is an optional browser setting that allows you to express your preferences regarding tracking by advertisers and other third parties. We do not use technology that recognizes DNT signals from your web browser.

How We Use Information

We may use Analytics as described elsewhere in this Privacy Policy and for research and commercial purposes, such as to improve our Services.


We may use Personal Information for the purposes described elsewhere in this Policy and internally for our general commercial purposes, including, among other things, to offer our products and services and also products and services of third parties that we think you might find of interest, but only i-investng.com and our third-party service providers involved in distributing the offers or providing the products or services will have access to your Personal Information. Our third-party service providers will only be permitted to use Personal Information for that intended purpose.

 

We may use your email address to respond to your inquiries and to provide you information about our Services. You may elect not to receive promotional emails from us either by “unsubscribing” to an email you receive from us or by contacting us as indicated below. If you unsubscribe from receiving emails from us, we may still send you non-promotional emails, such as emails about your i-investng.com account or our ongoing business relations, unless you withdraw your consent to receive electronic communications as provided in our Terms of Use.


We may use your Personal Information for the purpose of sending short message services or rich media messages or other multimedia messages to you, and can as well provide your Personal Information to third party service providers for the purpose of the foregoing. By accessing or using our Services, you consent to the use of your Personal Information as earlier described and as described elsewhere in this Privacy Policy.

How We Share Information

We do not share your Personal Information with: (1) other financial companies for joint marketing purposes; (2) affiliated companies for their everyday business purposes; or (3) any third parties so they can market to you.


We may share your Personal Information with unaffiliated third parties: (1) if you request or authorize it; (2) if the information is provided to help complete a transaction for you; (3) if the information is provided to: (a) comply with applicable laws, Data Protection Laws, rules, regulations, governmental and quasi-governmental requests, court orders, or subpoenas; (b) enforce our Terms of Use or other agreements; or (c) protect our rights, property, or safety or the rights, property, or safety of our users or others (e.g., to a consumer reporting agency for fraud protection, etc.); (4) if the disclosure is done as part of a purchase, transfer, or sale of services or assets (e.g., in the event that substantially all of our assets are acquired by another party, your Personal Information may be one of the transferred assets); (5) if the information is provided to our third-party service providers to perform functions on our behalf (e.g., analyzing data, providing marketing assistance, providing customer service, processing orders, etc.); (6) for our everyday business purposes; or (7) as permitted by Data Protection Laws, applicable law or otherwise described in this Policy.

We may disclose Analytics with third parties as described elsewhere in this Privacy Policy and for our commercial purposes.

Opt-Out Rights

If you do not wish to receive offers or other notices from us in the future, you can “opt out” by contacting us as indicated at the end of this Policy or by following the “unsubscribe” instructions in any communication you receive from us. Please be aware that you are not able to opt out of receiving communications about your i-invest account or related transactions with us.

Accessing Your Information

You must notify us of any change in your Personal Information by updating your i-invest account profile through our Services. Any changes will affect only future uses of your Personal Information.


Subject to Data Protection Laws, which might, from time to time, oblige us to store your Personal Information for a certain period of time, we will respect your wishes to correct inaccurate information. Otherwise, we will hold your Personal Information for as long as we believe it will help us achieve our objectives as detailed in this Policy.

You can ask us whether we are storing your Personal Information and you can ask to receive a copy of that Personal Information. Before sending you any Personal Information, we will ask you to provide proof of your identity. If you are not able to provide proof of your identity, we reserve the right to refuse to send you any Personal Information. We will respond as quickly as we can to your requests for details of Personal Information we hold about you.

Information You Share Socially

Our Services may allow you to connect and share your actions, comments, content, and information publicly or with friends. We are not responsible for maintaining the confidentiality of any information you share publicly or with friends.


Our Services may also allow you to connect with us on, share on, and use third-party websites, applications, and services. Please be mindful of your personal privacy needs and the privacy needs of others, as you choose whom to connect with and what to share and make public. We cannot control the privacy or security of information you choose to make public or share with others. We also do not control the privacy practices of third parties. Please contact those sites and services directly if you want to learn about their privacy practices.

Your Rights regarding your Data

You can ask us to do various things with your Personal Information. For example, at any time you can ask us for a copy of your Personal Information, ask us to correct mistakes, change the way we use your information, or even delete it. We will either do what you have asked or explain why we cannot - usually because of a legal or regulatory issue.

You have the following rights in relation to our use of your Personal Information.

  • The right to access your Personal Information: You are entitled to a copy of the Personal Information we hold about you and certain details of how we use it. Your Personal Information will usually be provided to you in writing unless otherwise requested. We may charge you a reasonable fee to cover the cost.
  • The right to rectification: We take reasonable steps to ensure that the Personal Information we hold about you is accurate and complete. However, if you do not believe this is the case, please contact us by using the details shown in your documentation and you can ask us to update or amend it.
  • The right to erasure: In certain circumstances, you have the right to ask us to erase your Personal Information, for example where the Personal Information we collected is no longer necessary for the original purpose or where you withdraw your consent. However, this will need to be balanced against other factors, for example according to the type of Personal Information we hold about you and why we have collected it, there may be some legal and regulatory obligations that preclude us from complying with your request.
  • Right to restriction of processing: In certain circumstances, you are entitled to ask us to stop using your Personal Information, for example where you think that the Personal Information, we hold about you may be inaccurate or where you think that we no longer need to process your Personal Information.
  • Right to data portability: You have the right to easily access and transfer your personal data between services. Upon request, we will provide you with a copy of your Personal Information in a structured, commonly used, and machine-readable format to facilitate this transfer. Where technically feasible, we can also directly transfer your data to a third-party service provider of your choice.
  • The right to withdraw consent: For certain uses of your Personal Information, we will ask for your consent. Where we do this, you have the right to withdraw your consent to further use of your Personal Information. Please note in some cases we may not be able to provide our services to you if you withdraw your consent.

Security

We take reasonable measures to protect Personal Information from unauthorized access, disclosure, alteration, or destruction. To enhance data protection, we may anonymize or pseudonymize your Personal Information:

  • Anonymization: When possible, we anonymize data, making it permanently untraceable to you. Anonymized data may be used for statistical, research, and other legitimate purposes, as it no longer identifies any individual.
  • Pseudonymization: In cases where full anonymization is not feasible, we use pseudonymization to replace personal identifiers with artificial identifiers, limiting exposure and enhancing security. This data remains protected by our privacy measures and is only accessible to authorized personnel.
These techniques help protect your Personal Information while enabling us to improve our Services. You retain the right to access or delete pseudonymized data, while anonymized data cannot be traced back to you and is exempt from such requests. We have and require our third-party service providers that receive Personal Information from us to have, a comprehensive written information security program that contains administrative, technical, and physical safeguards for our respective physical facilities and in our respective computer systems, databases, and communications networks that are reasonably designed to protect information contained within such systems from loss, misuse, or alteration. When your bank account information is transmitted via our Services, it will be protected by encryption technology, such as Secure Sockets Layer (SSL). No method of electronic transmission or storage is 100% secure. Therefore, we cannot guarantee absolute security of your Personal Information. You also play a role in protecting your Personal Information. Please safeguard your username and password for your i-invest account and do not share them with others. If we receive instructions using your i-invest account login information, we will consider that you have authorized the instructions. You agree to notify us immediately of any unauthorized use of your i-invest account or any other breach of security. We reserve the right, in our sole discretion, to refuse to provide our Services, terminate i-invest accounts, and to remove or edit content.

Training and Awareness

We are committed to ensuring that all our employees and relevant third parties are adequately trained. We ensure that all staff involved in data processing undergo regular training on privacy and security. This training covers data protection principles, security protocols, incident response, breach notification requirements, and many more. By providing ongoing training and awareness campaigns, we aim to equip employees with the knowledge to handle personal data securely and in compliance with data protection laws. Additionally, we require third-party service providers to provide similar training for their staff who process personal data on our behalf.

Data Protection Impact Assessment (DPIA)

To protect your privacy, we evaluate the potential impacts of data processing activities on your rights and freedoms. In compliance with the Data Protection Laws, we conduct Data Protection Impact Assessments (DPIAs) for processing activities that may pose significant privacy risks. This process allows us to identify and address risks before processing begins, implementing measures to protect your personal data. If any identified risks cannot be sufficiently mitigated, we will consult with the relevant supervisory authority, as required.

These safeguards help protect your data from unauthorized access or misuse while it is being transferred internationally.

Third-Party Vendor Audits

To ensure the security and compliance of your personal data, we conduct regular audits of all third-party vendors that handle or process personal information on our behalf. These audits assess vendors’ data protection practices, compliance with applicable privacy laws, and adherence to our security standards. We only work with vendors who meet our strict requirements for data protection and privacy.

Protecting Children’s Privacy

Our Services are not directed, or intended to be attractive, to children under the age of 18. We do not knowingly collect Personal Information from children under the age of 18. If you are under the age of 18, do not use our Services or submit any information to us.

Links to Third-Party Websites

When you use our Services, you may be directed to other websites that are beyond our control. We may also allow third-party websites or applications to link to our Services. We are not responsible for the privacy practices of any third parties or the content of linked websites, but we do encourage you to read the applicable privacy policies and terms and conditions of such parties and websites. This Privacy Policy only applies to our Services.

Breach Notification

In the event of a data breach affecting your personal data and leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, Personal Information, we shall within 72 (seventy-two) hours of having knowledge of such breach report the details of the breach to Nigeria Data Protection Commission. Furthermore, if the breach is likely to result in a significant risk to your rights, we shall within 7 (seven) days of having knowledge of the occurrence of such breach take steps to notify you without undue delay, providing details of the breach, its potential impact, and any necessary actions you should take.

 

We take all appropriate measures to prevent data breaches and respond swiftly to protect your personal data.

International Data Transfers

Your personal data may be transferred to and stored in countries outside of your country of residence, which may not have the same level of data protection laws as those in your jurisdiction. In such cases, we ensure that your personal data is adequately protected through appropriate safeguards, such as contractual agreements or other legal mechanisms, to ensure compliance with applicable data protection regulations.

Changes to our Privacy Policy

Subject to applicable law, we may revise this Privacy Policy at any time and in our sole discretion. When we revise this Privacy Policy, we will post the revised version via our Services and will update the date at the top of this Privacy Policy. The revised Privacy Policy will be effective upon posting via our Services, unless otherwise set forth therein or as otherwise required by applicable law. You are free to decide whether or not to
accept a revised version of this Privacy Policy, but accepting this Privacy Policy, as revised, is required for you to continue accessing or using our Services. If you do not agree to the terms of this Privacy Policy or any revised version of this Privacy Policy, your sole recourse is to terminate your access and use of our Services. Except as otherwise expressly stated by us, your access and use of our Services is subject to the version of this Privacy Policy in effect at the time of access or use.

How can I contact i-invest?

If you have any questions, comments, or concerns regarding these Terms or the Services, please contact us at enquiries@i-investng.com