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GTI Data Protection Policy

The purpose of this document (“GTI Data Protection Policy”) is to inform the public of how GTI Group members made up of GTI Capital, GTI Microfinance Bank, GTI Securities, GTI Asset Management and Trust, GTI Trade Desk, GTI Trading Floor, GTI Finance Academy and other GTI affiliates and related companies which the group has substance interest collectively referred to as GTI Group, manages Personal Data (as defined below) which is subject to the Nigeria Data Protection Regulation 2019.

 

The public is expected to read this Data Protection Policy so that you know and understand the purposes for which we collect, use and disclose Personal Data.

 

Contents

  1. GTI Group Status
  2. Consent
  3. Personal Data
  4. Collection of Personal Data
  5. Purpose for the Collection, Use and Disclosure
  6. Disclosure of Personal Data
  7. Use of Cookies and Related Technologies
  8. Data Security
  9. Third-Party Sites
  10. Data Retention
  11. Children Privacy
  12. Your Rights
  13. Contacting Us, Feedback, Withdrawal of Consent, Access and Correction of Personal Data

Consent

By interacting with us, filling out forms/registers (both online and offline), submitting information to us, or signing up for any products or services offered by us, the user agrees and consent to GTI Group, as well as our respective representatives and/or agents (“Representatives”) (the Companies and Representatives collectively referred to herein as “GTI Group”, “us”, “we” or “our”) collecting, using, disclosing and sharing amongst ourselves your Personal Data, and disclosing such Personal Data to the Companies’ authorised service providers and relevant third parties in the manner outlined in this Data Protection Policy.

 

This Data Protection Policy supplements but does not supersede nor replace any other consents you may have previously provided to GTI Group in respect of your Personal Data, and your consents herein are additional to any rights which any of the Companies may have at law to collect, use or disclose your Personal Data.

 

GTI Group may from time to time update this Data Protection Policy to ensure that this Data Protection Policy is consistent with our future developments, industry trends and/or any changes in legal or regulatory requirements. Subject to your rights at law, you agree to be bound by the prevailing terms of the Data Protection Policy as updated from time to time on our website http://www.gti.com.ng/Data-Protection-Policy. Please check regularly for updated information on the handling of your Personal Data.

Personal Data

In this Data Protection Policy, “Personal Data” refers to any data, whether true or not, about an individual who can be identified (a) from that data; or (b) from that data and other information to which we have or are likely to have access, including data in our records as may be updated from time to time.

 

Examples of such Personal Data you may provide to us include (depending on the nature of your interaction with us) your name, bank verification number, passport or other identification numbers, telephone number(s), mailing address, email address, transactional data and any other information relating to any individuals which you have provided us in any form you may have submitted to us (including in the form of biometric data), or via other forms of interaction with you.

Collection of Personal Data

Generally, we collect Personal Data in the following ways:

  • when you interact with us using our various social media platforms and/or through our online electronic messaging and chat option like Emails, Whatsapp etc;
  • when you enter into any agreement or provide other documentation or information in respect of your interactions with us, or when you use our services;
  • when you interact with our staff, including relationship managers and their assistants, example via telephone calls (which may be recorded), letters, fax, face-to-face meetings, electronic meetings and emails;
  • when your images are captured by us via closed-circuit television cameras (“CCTVs”) while you are within our premises, or via photographs or videos taken by us or our representatives when you attend events hosted by us;
  • when you use some of our services provided through online and other technology platforms, such as websites and apps, including when you establish any online accounts with us;
  • when you request that we contact you, or include you in an email or other mailing lists; or when you respond to our request for additional Personal Data, our promotions and other initiatives;
  • when you are contacted by, and respond to, our marketing representatives, agents and other service providers;
  • when we seek information about you and receive your Personal Data from third parties in connection with your relationship with us, for example, from referrers, business partners, external or independent asset managers, public agencies or the relevant authorities;
  • through physical access, internet and information technology monitoring processes;
  • in connection with any investigation, litigation, registration or professional disciplinary matter, criminal prosecution, inquest or inquiry which may relate to you or any Connected Person; and/or;
  • when you submit your Personal Data to us for any other reason.
  • When you browse our website and platforms, you generally do so anonymously but please see the section below on cookies. We do not, at our website and platforms, automatically collect Personal Data, including your email address unless you provide such information or login with your account credentials.

 

If you provide us with any Personal Data relating to a third party (for example, information of your spouse, children, parents, or a Connected Person), by submitting such information to us, you represent to us that you have obtained the consent of the third party to you providing us with his/her Personal Data for the respective purposes. “Connected Person” may include but is not limited to any beneficial owner, authorised signatory, director, shareholder, an officer of a company, partner or member of a partnership, settlor, trustee, beneficial owner, protector or grantor of trust, mandate holder, power of attorney holder, surety, third party security provider, provider of funds, founder and/or employee, the payee of designated payment, representatives, agents or nominees.

 

You should ensure that all Personal Data submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability to provide you with the products and services you have requested. You agree to inform GTI Group immediately of any change of facts or circumstances which may render any information or Personal Data previously provided inaccurate, untrue or incorrect and provide any information or documentation as GTI Group may reasonably require for verifying the accuracy of the updated information or Personal Data.

Purposes for the Collection, Use and Disclosure of Your Personal Data

Generally, GTI Group uses and discloses your Personal Data for the following purposes:

  • responding to, processing and handling your complaints, queries, requests, feedback and suggestions;
  • verifying your identity and customer due diligence;
  • managing the administrative and business operations of GTI Group and complying with internal policies and procedures (including but not limited to facilitating business continuity planning);
  • audit purposes;
  • verifying or confirming trade/investment orders or instructions from you or for your account (including but not limited to instructions on fund transfers or remittances);
  • facilitating business asset transactions (which may extend to any mergers, acquisitions or asset sales) involving any of the group members;
  • matching any Personal Data held which relates to you for any of the purposes listed herein;
  • resolving complaints and handling requests and enquiries;
  • preventing, detecting and investigating crime, including fraud and money-laundering or terrorist financing, and analysing and managing commercial risks (including but not limited to preventing and detecting loss of GTI Group proprietary and sensitive information);
  • project management;
  • providing media announcements and responses, for example in relation to complaints or lawsuits;
  • requesting feedback or participation in surveys, as well as conducting market research and/or analysis for statistical, profiling or other purposes for us to design our products, understand customer behaviour, preferences and market trends, and to review, develop and improve the quality of our products and services;
  • managing the safety and security of our premises and services (including but not limited to carrying out CCTV surveillance and conducting security clearances);
  • managing and preparing reports on incidents and accidents;
  • organising events, seminars or training;
  • complying with any applicable rules, laws and regulations, codes of practice or guidelines, obligations, requirements or arrangements for collecting, using and disclosing Personal Data that apply to GTI Group or that it is expected to comply, according to:

any law binding or applying to it within Nigeria existing currently and in the future;

 

any guidelines or guidance given or issued by any legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations of financial services providers within Nigeria existing currently and in the future;

 

any present or future contractual or other commitment with local or foreign legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations of financial services providers that is assumed by or imposed on GTI Group because of its financial, commercial, business, or other interests or activities in or related to the jurisdiction of the relevant local or foreign legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations;

  • to assist in law enforcement and investigations by relevant authorities;
  • in connection with any claims, actions or proceedings (including but not limited to drafting and reviewing documents, transaction documentation, obtaining legal advice, and facilitating dispute resolution), and/or protecting and enforcing our contractual and legal rights and obligations;
  • archival management (including but not limited to warehouse storage and retrievals); and/or
  • any other purpose relating to any of the above.

 

These purposes may also apply even if you do not maintain any account(s) with us or have terminated these account(s).

 

Also, GTI Group collects, uses and discloses your Personal Data for the following purposes depending on the nature of our relationship:

If you are a prospective customer:

evaluating your eligibility to open an account with us and your financial and banking needs and providing recommendations to you as to the type of products and services suited to your needs;

 

assessing and processing any applications or requests made by you for products and services offered by GTI Group;

 

and/or any other purpose relating to any of the above.

If you are a customer and/or holding an account with GTI Group or a Connected Person or an administrator, executor, liquidator, official assignee, receiver, judicial manager or other similar officials who have been so appointed in pursuant to bankruptcy or insolvency proceedings instituted in Nigeria or elsewhere in respect of a GTI Group customer or any security provider:

opening, maintaining or closing of accounts and our establishing or providing banking and trust services to you;

 

processing fund transfers or any other instructions provided concerning the account of a GTI Group customer;

 

where account or relationship managers or agents have been assigned to service your account or portfolio, using your telephone number(s) to contact you from time to time to take your instructions, and/or provide you with information, updates, or recommendations and/or in accordance with the terms and conditions of our agreement with you;

 

processing applications for and facilitating the daily operation of services and credit facilities provided to you or other persons or corporations for whom you act as surety or third party service provider;

 

conducting credit checks at the time of application for credit and at the time of regular or special credit reviews;

 

facilitating or processing your application for investment products and/or other services offered by GTI Group and its business partners;

 

carrying out client reviews, for example, annual reviews of your portfolio;

 

to establish your financial situation, risk profile, investment experience and investment objectives to help you consider the suitability of the products you have invested or intend to invest;

 

providing internet banking services (including but not limited to carrying out special handling requests for PIN mailers and tokens);

 

networking to maintain customer relationship;

 

providing client servicing (including but not limited to responding to individual requests by customers, mailing services, reconciliation services and providing customer satisfaction);

 

facilitating the transfer of funds within GTI Group accounts or from GTI Group accounts to external banking accounts and vice versa;

 

administering exceptional approvals, fee adjustments or waivers;

 

dealing with and designing investment products (for example, bonds, derivatives, equities, funds);

 

registering the pledge or charge that you or the surety or the third party security provider has granted in favour of GTI Group as security for the credit facilities granted by GTI Group to you;

 

administering credit and debit cards (including but not limited to processing card applications, transactions and credit limit approvals);

 

providing cheque deposits and issuance services;

 

determining and collecting amounts owed by you or the borrower for whom you act as surety or third party security provider or those providing security or acting as surety for your liabilities and obligations;

 

enabling any Company or third party to perform the functions that GTI Group may have outsourced to it concerning the management of your account or transactions;

 

enabling an actual or proposed assignee of GTI Group, or participant or sub-participant or transferee of GTI Groups’ rights, liabilities or obligations in respect of (1) you or (2) a security provider who provides security or acts as surety for your liabilities and obligations to evaluate the transaction intended to be the subject of the assignment, participation, sub-participation or transfer; and/or

 

any other purpose relating to any of the above.

 

If you are an employee or agent of a referrer or other intermediary:

marketing services and products;

 

processing commission remuneration;

 

performing due diligence and reference checks; and/or

 

any other purpose relating to any of the above.

 

If you are an employee, officer or owner of an external service provider or vendor outsourced or prospected by GTI Group;

managing project tenders or the supply of goods and services;

 

processing and payment of vendor invoices;

 

complying with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities (which includes disclosure to regulatory bodies or audit checks); and/or

 

any other purpose relating to any of the above.

 

If you are a party or counterparty to a transaction (for example, a beneficiary of a fund transfer or payment):

providing cash, payment and transactional services (including but not limited to the execution, settlement, reporting and/or clearing of the relevant transaction); and/or

 

any other purpose relating to any of the above.

If you sit on the GTI Group Board of Directors:

facilitating appointment to the Board (including but not limited to managing the publication of directors’ statistics on annual reports and circulars);

 

complying with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities (including but not limited to disclosures to regulatory bodies or conducting due diligence);

 

administrative matters (including but not limited to the maintenance of statutory registers and lodgement of directors’ fee);

 

any other purpose relating to any of the above.

Also, where permitted under the regulation, GTI Group may also collect, process, use and disclose your Personal Data for the following purposes (which we may describe in our documents and agreements as “Additional Purposes” for the handling of Personal Data):

providing or marketing services, products and benefits to you, including promotions, loyalty and reward programmes;

 

matching Personal Data with other data collected for other purposes and from other sources (including third parties) in connection with the customisation, provision or offering of products and services, marketing or promotions, whether by GTI Group or other third parties;

 

sending you details of products, services, special offers and rewards, investment or research reports or guides, either to our customers generally, or which we have identified may be of interest to you; and/or

 

conducting market research, understanding and analysing customer behaviour, location, preferences and demographics for us to offer you products and services as well as special offers and marketing programmes which may be relevant to your preferences and profile.

 

If you have provided your telephone number(s) and have indicated that you consent to receive marketing or promotional information via your telephone number(s), then from time to time, GTI Group may contact you using such telephone number(s) (including via voice calls, text, or other means) with information about our products and services (including discounts and special offers).

 

In relation to particular products or services or your interactions with us, we may also have specifically notified you of other purposes for which we collect, use or disclose your Personal Data. If so, we will collect, use and disclose your Personal Data for these additional purposes as well, unless we have specifically notified you otherwise.

 

GTI Group will collect and process your Personal Data in accordance with the legitimate purposes consented to by you provided that further processing may be done for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes as provided for in the Data Protection Regulation

Disclosure of Personal Data

GTI Group will take reasonable steps to protect your Personal Data against unauthorised disclosure. Subject to the provisions of any applicable law, your Personal Data may be provided, for the purposes listed above (where applicable), to the following entities or parties, whether they are located overseas or in Nigeria:

GTI Group related corporations and overseas branches and offices;

 

counterparties and their respective banks concerning transactions for your account including purchasing and selling of securities and investment products, fund transfers, payments, issuance of standby letters of credit, banker’s guarantees or letters of undertaking and drawing of payment instruments;

 

third party recipients of reference letters;

 

companies providing services relating to insurance and/or reinsurance to GTI Group;

 

insurers or brokers concerning the insurance products or services that you have applied for or purchased;

 

trustees, attorneys and asset managers appointed by you to manage your account held with GTI Group;

 

referrers who have referred you to GTI Group;

 

any person (1) who provides security or acts as surety for your liabilities and obligations to GTI Group or (2) for whom you act as surety or third party security provider;

 

agents, contractors, vendors, installers, or third-party service providers who provide administrative or operational services to GTI Group, such as courier services, telecommunications, information technology, payment, payroll, processing, training, market research, storage, archival, customer support investigation services or other services to GTI Group;

 

Our service providers: GTI Group use other companies, agents or contractors to perform services on our behalf or to assist us with the provision of our services and products to you, including:

infrastructure and IT service providers, including cloud storage for data, email archiving etc.

 

marketing, advertising and communications agencies.

 

credit reference agencies

 

external auditors and advisers.

 

offsite archival storage providers

In the course of providing such services, these service providers may have access to your personal information. However, we will only provide our service providers with personal information which is necessary for them to perform their services, and we require them not to use your information for any other purpose. We will use our best efforts to ensure that all our service providers keep your personal information secure.

agents, contractors, vendors or other third-party service providers in connection with marketing, products and services offered by GTI;

 

analytics, search engine providers or third-party service providers that assist us in delivering our products, services, websites and platforms as well as improving and optimising the same;

 

credit reporting agencies;

 

debt collection agencies;

 

your employers which are financial institutions, for their internal surveillance or monitoring purposes;

 

any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition or any debt or asset sale) involving any of the Companies;

 

credit companies and their respective service providers in respect of credit cards held by you;

 

our professional advisers such as our auditors and lawyers;

 

third parties who provide corporate advisory services or due diligence services in connection with you, any Connected Person or your account held with GTI Group;

 

relevant government regulators, government agencies/ministries, statutory boards or authorities or law enforcement agencies who have jurisdiction over GTI Group or any Company or any transaction entered into by you, such as the Securities and Exchange Commission (SEC), Central Bank of Nigeria (CBN), Nigerian Stock Exchange (NSE), Lagos Commodities and Futures Exchange (LCFE) and other exchanges for which we relate, as well as to comply with listing and other requirements or directions of these exchanges and/or any other relevant securities exchange;

 

any liquidator, receiver, administrator, judicial manager, trustees-in-bankruptcy, custodian or other similar officials who have been so appointed, pursuant to bankruptcy, winding-up or insolvency proceedings instituted in Singapore or elsewhere, in respect of you or your assets;

 

third parties who carry out registration of charge or pledge over the assets that you have pledged or charged to GTI Group;

 

corporate service providers or lawyers, who are appointed by you;

 

surveyors or valuers or other third parties in relation to assets which you will be charging or mortgaging to GTI Group;

 

financial institutions, brokerage houses, clearing houses, depository, depository agents, warehouses, managers, administrators, fund houses, registrars, custodians, external banks, the Central Depository, nominee banks and investment vehicles in relation to asset management and investment product settlement processing;

 

collection and repossession agencies concerning the enforcement of repayment obligations for loans;

 

third parties who organise promotional or marketing events, seminars or training;

 

any actual or proposed assignee of GT Group or participant or sub-participant or transferee of GTIs’ rights, liabilities or obligations in respect of (1) you or (2) a security provider who provides security or acts as surety for your liabilities and obligations to evaluate the transaction intended to be the subject of the assignment, participation, sub-participation or transfer;

 

any person to whom GTI Group or any of the Companies is under an obligation or otherwise required to make disclosure under the requirements of any law binding on or applying to GTI Group or any of the Companies, or any disclosure under and for the purpose of any guidelines or guidance given or issued by any legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations of financial services providers with which GTI Group or any of the Companies are expected to comply, or any disclosure in pursuant to any contractual or other commitment of GTI Group or any of the Companies with local or foreign legal, regulatory, governmental, tax, law enforcement or other authorities, or industry bodies or associations of financial services providers, all of which may be within or outside Nigeria and maybe existing currently and in the future; and/or

 

any other party to whom you authorise us to disclose your Personal Data to.