The efficient management and protection of our customer’s data is of utmost importance to us.
Thus, our quest to always maintain adequate security of any personal information collected by us from our valuable customers.
In line with the Nigerian Data Protection Regulation, 2019, it is your right, as our esteemed customer,
to know why we collect your personal information and withwhom we share such information in order to serve you efficiently, always.
Thank you for using CRL
Our mission is to bridge the gap between the investors and the Companies in which they havevarious investments.
To do that, we ensure that all your benefits and necessary information fromyour Company are adequately protected and
distributed to you based on information we collectfrom you. We only use that information where we have a proper legal basis for doing so.
This policy is to help you understand what information we collect, how we use it and what choicesyou have about it.
Because we are a data processing company, some of the concepts below are a little technical,
but we have tried our best to explain things in a simple and clear way.
We welcome your valuable suggestions on how to improve on this policy, as we are here to serve you.
Different Ways in which we collect your data.
When you give it to us or give us permission to obtain it
When you fill up various forms we have provided for different purposes, either downloaded fromour website and mailed to us or picked up physically and submitted at our corporate office, youvoluntarily share certain information including your name, physical address, email address, phonenumber, photos, BVNs, bank account details, and any other information you give us.
Our partners and other market players share information with us
We also get information about you and your investment activities outside CRL from our affiliates,
and other market operators that handle and process your investments, and other third parties we
work with. For example:
Central Settlement Clearing System share information with us about your stock trading
activities regularly for us to update your record with us in the Shareholders register.
Other Registrars may share your details with us when it involves regulatory transactions
like transfer of register or handling of some corporate actions.
Your stockbrokers also share some information about you with us whenever you assign
them to liaise with us in ascertaining your holdings or outstanding benefits.
What we do with the informationwe collect
We are committed to ensuring you rightly receive any benefit that belong to you from your
Company and timely distribution of any information from your Company to you is our paramount
objective. To do that, we use your information to provide and improve your experience, including:
Identify you as a bona fide shareholder and investor in any Company you claim.
Identifying that you are the rightful owner of the stock in our register.
Processing your current and outstanding benefits from your Company directly to your bankaccount.
Ensuring that you timely receive any information from your Company regarding anycorporate actions.
We have a legitimate interest for using your info in these ways. It is fundamental to what we do atCRL and necessary in order to make CRL and its features relevant to you.
We also have a legitimate interest in making CRL safe and improving our product features so youkeep finding the inspiration you want. We all benefit when we use your information to:
Work with law enforcement and regulators to keep CRL safe. We may get requests foraccount information from law enforcement or regulating authorities like the police orcourts. We only provide your information to them after we have painstakingly confirmedit is for public interest and we are mandated to do so.
Conduct analytics and research on who is using CRL and unclaimed funds analysis.
Advertise CRL products and services on how to serve you better to you via our websites oremail ads.
Send your details to CSCS or any authorized Capital Market Operators, for reconciliatorypurpose (such as when we are having differences in balances or mix-up in names)
Transferring your information
CRL is a regulated Capital Market Operator. By using providing us your details, you authorize us totransfer and store your information, for the purposes described in this policy. The privacyprotections and the rights of authorities to access your personal information in Nigeria may not beequivalent to those of other countries where you reside, for investors in diaspora. Thus, beforeyour information is transferred, we critically subject such to Nigerian Data Protection Regulationsand extensively, to any bilateral legally binding agreements between Nigeria and your country ofresidence.
Choices you have about your information
Our goal is to give you simple and meaningful choices regarding your information. If you have stockwith any Companies that we serve, the following can be done with your information directly. Forexample, you can:
- Change your Name at any time, by providing us the new name and verifiable evidences ofthe Change of name.
- Change your other details like physical address, email address, phone number, bankaccount details and signature mandates in our records, once the required documentationare provided.
How and when we share information
Your information with us can be shared in the following ways:
- Law enforcement agencies or government agencies. We only share information if webelieve that disclosure is reasonably necessary to comply with a law, regulation or legalrequest; to protect the safety, rights, or property of the public, any person, or CRL; or to detect, prevent, or otherwise address fraud, security or technical issues.
- Regulators or other market operators (CSCS, Registrars) may at any point also be provided your data for the purpose of reconciliation or database update.
How long we keep your information
We keep your information only so long as we need it to provide our services to you as an investorin our client Companies, fulfilling the purposes described in this policy. This is also the case foranyone that we share your information with and who carries out services on our behalf. When weno longer need to use your information and there is no need for us to keep it to comply with ourlegal or regulatory obligations (Usually 12 years, in line with SEC rules) , we will either remove it from our systems or depersonalize it so that we can't identify you.
How we make changes to this policy
We may change this policy from time to time and if we do, we will post any changes on this page.If you continue to provide us your details after those changes are in effect, you agree to the newpolicy. If the changes are significant, we may provide a more prominent notice or get your consent,as required by law.
Do you have a complaint or suggestion?
You can always reach us at firstname.lastname@example.org
(anytime) or call 01-4538671 or 01-4538674 (weekdays between 9.00am and 4.00pm).