Fragvest

Last Modified: April 01, 2024

1. Introduction

Welcome to Fragvestment Limited (“We” “Us” “Our” or “Fragvest”) Privacy Policy (the “Policy”). We understand how important your personal information is to you and we are committed to protecting your personal information. This Policy provides information about how we collect, use and share your personal information. Please read the Policy to the end to understand how we process your personal information.

2. Data Protection Officer (DPO)

Fragvest has, in compliance with the Data Protection Act of 2023, appointed a Data Protection Officer (DPO) to guide and manage our processing activities. If you have any questions or issues regarding this Notice, kindly contact our Data Protection Officer (DPO) at support@fragvest.com.

3. Information We Collect About You

Personal information is any information that identifies or can identify you. The personal information we process about you depends on your interaction with us. For the services we render, we process the following information:

Signup information: When you sign up for our services, we will collect your personal information such as your name, email address, phone number, permanent home address, bank verification number, Identification card, identification number, and payment details.
Recruitment information: When you apply to work with us or we call for applications from potential candidates, we will collect the following information: your name, phone number, email address, curriculum vitae, and cover letter.
Marketing/communication information: We use this information to respond to your inquiries and market our products and services to you. They include phone numbers, call logs, email addresses, email content, and social media content.
Technical information: When you visit our website or mobile application (the “Platform”), our servers may automatically log the information provided by your web browser. The information includes your device's internet protocol (IP) address, your browser type and version, the pages you visit, the time and date of your visit, the time spent on each page, the location, and other details about your visit.
Financial information: When you invest on our Platform, we may process your financial information to facilitate payment.
Other information: We collect your information for judicial proceedings. The information collected will depend on the nature of the case.
Information About Other People: Where you provide information to us about any person other than yourself, your next-of-kin, heirs, your advisers, or your suppliers, it is your responsibility to ensure that the person understands how their information will be processed, and obtain the person’s consent before disclosing the information to us and for you to allow us and our service providers to use it. Where the consent of the person cannot be reasonably obtained, you must ensure that you have legal bases for sharing the information with us.
Special Categories of Data: We do not collect any other special categories of data about you (this includes details about your health, race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, and genetic data). Nor do we collect any information about criminal convictions and offences.

4. Children’s Information

Upon the creation of a Child’s Account, you will be required to provide consent to our collection, use, and disclosure of your child’s personal information in connection with that Child’s Account. We won’t require you or your child to provide more information about your child than is reasonably necessary. Information collected from children (including personal information and information collected automatically) shall not be used or disclosed for third-party or behaviorally targeted advertising. We do not sell or rent children’s personal information, including to marketers, advertisers, or any other third parties. We use children’s information in the following ways:

To provide our Services,
Process transactions,
Verify the identity of the child,
Respond to requests and communicate effectively,
Perform analytics about how our Services are utilized,
Improve our businesses,
For security and safety purposes,
To prevent fraud,
As required by law or contract,
To enforce our terms and account agreements, and
For any other use that we disclose to you in connection with the Child’s Account.

Where permissible, we may also use children’s data that has been collected on an aggregate or anonymous basis (meaning that your child is not identified) for various business purposes.
Please be aware that by opening a Child’s Account, you are consenting to your child viewing our normal marketing messages that may be displayed to all Accounts.
We may share children’s personal information with our affiliates and other third parties where necessary and permitted. For example, we may share their information with our service providers and our affiliates in connection with corporate transactions; to comply with legal requirements; to enforce our terms and other rights and policies; to address fraud, security, or technical issues; to respond to an emergency; or where it is otherwise necessary to protect our customers or third parties.
Parents and legal guardians have the legal right to review the personal information we have collected from their child; refuse to allow further use or collection of personal information from their child; and delete the personal information we have collected from their child on the Platform (unless we are required by law to retain it). However, if you decide that you don’t want us to use or collect your child’s personal information, or you ask us to delete it, we may have to close the Child’s Account.

5. Sources We Collect Your Data From

We use different methods to collect personal data from you and they include:

Direct interactions: You may give us your data when you sign up on our Platform for our Services, communicate with us, or create a wallet account with us.
Automated technological interactions: We collect these personal data as you interact with our Platform. These include personal data about your devices, your activities on our Platform, and location data. We collect this personal data with cookies, server logs, and other similar technologies.
Third parties or publicly available sources: We may receive personal data about you from various third parties and public sources available to us such as your financial institution, open government sources, and agencies amongst others.

6. What Do We Use Your Information For?

Any information we collect from you may be used in one of the following ways:

To personalize your experience (your information helps us to better respond to your personal needs)
To provide access to, maintain, and improve our services.
To provide our services and send you information related to our services.
To verify your identity.
To prevent fraudulent transactions.
To improve our website and services (we continually strive to improve our website and service offerings based on the information and feedback we receive from you).
To send you technical notices, updates, security alerts, support and administrative notifications.
To provide customer service: we process your personal information when you contact us to resolve any questions, or disputes, redeem your investment, or troubleshoot problems. Without processing your personal information for such purposes, we cannot respond to your requests and ensure your uninterrupted use of the Services.
To send periodic emails: The email address you provide may send you information about our plans and services and receive occasional company news, updates, related product or service information, etc. If at any time you would like to unsubscribe from receiving future emails, we include detailed instructions to unsubscribe at the bottom of each email.
To ensure network and information security; we process your personal information to enhance security, monitor and verify identity or service access, combat malware or security risks and comply with applicable security laws and regulations in our jurisdiction.
To administer a contest, promotion, survey, rewards, events or other site feature.

For any purpose that you provide consent; We will not use your personal information for purposes other than those purposes we have disclosed to you, without your permission. From time to time, and as enabled under the Nigerian Data Protection Act 2023, we may request your permission to allow us to share your personal information with third parties. In such instances, you may opt out of having your personal information shared with third parties or allowing us to use your personal information for any purpose that is incompatible with the purposes for which we originally collected it or subsequently obtained your authorization. If you choose to limit the use of your personal information, certain features or services may not be available to you.

7. Legal Bases for Processing Personal Information

We collect your contact information to execute the contract we have with you or take pre-contractual steps on your behalf. Our legal basis for processing this information is the performance of a contract between you and Fragvest.
We collect your communication information to respond to your queries and market our products. We rely on the performance of the contract to process your personal information for purposes of responding to your query. We rely on our legitimate interest to market our products and services to you.
We process your technical data to track traffic on our Platform and for the functionality of our Platform. We obtain your consent before processing this information.
We process your recruitment information to carry out employment exercises and other activities associated with recruitment. We rely on our legitimate interest to process this information.
We process your personal information to comply with legal requirements and our legal basis for processing your personal data is a legal obligation.
We process the information collected from our CCTV to monitor, prevent and protect our office and employees from fraud and security threats. We are relying on our legitimate interest to process this personal information. In addition, we are relying on substantial public interest as our ground for processing such biometric information.
We process your financial information to facilitate payment for services rendered.
We process your personal information to investigate, prosecute and defend our legal rights. We are relying on our legitimate interest to process this information.

Further Purpose
We will only process your personal data for the particular purposes for which we collect it. We will notify you and rely on an appropriate lawful basis if we intend to use it for another purpose and such further purpose is not compatible or incidental to the initial purpose.

8. Who Do We Share Your Personal Information With?

We may share your personal information with a third party to fulfil a contract between you and the third party or where you have authorized us to do so. We may also share your personal information with the following third parties:

Financial institution
Our partners
Regulators
Service providers
Judicial authorities

9. Third-Party Links

This Policy applies to our Platform only and does not cover third-party links. Our Platform may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share your personal information. We do not control these third-party websites and are not responsible for their privacy policy. When you leave our Platform, we encourage you to read the privacy notice of every website you visit.

10. Do We Transfer Your Personal Information Outside Nigeria?

In some instances, we may transfer your personal information outside Nigeria. We adopt appropriate transfer mechanisms and ensure that personal information is protected in the country or organization that receives your personal information. Kindly contact us to find out the country where we transfer your personal information and the safeguards we have adopted.

11. How Long Do We Keep Your Personal Information?

We will only retain your data for as long as is reasonably necessary to fulfil the purposes for which they were collected. We will also retain it where the law requires us to retain it and where we are required to assert or defend against legal claims. To learn more about our retention periods as established in our retention policy, kindly contact our DPO at support@fragvest.com

12. Data Security

We care about your personal information in our custody and have put in place organizational and technical measures such as Hypertext Transfer Protocol Secure (HTTPS), firewall, access-based controls, and antimalware to secure your personal information. We do not guarantee 100% protection, but we will strive to ensure maximum protection of personal information with us.

14. Your Legal Rights

You have certain rights under the law which we respect and adhere to and which can be exercised by you at any time. However, note that these rights are not absolute and may only apply in certain circumstances. Your rights are as itemized below:

Right to access your personal data;
Right to request correction of your personal data;
Right to request the erasure of your personal data;
Right to object to the processing of your personal data especially with regards to direct marketing;
Right to request the restriction of processing of your personal data pending the rectification of the accuracy of your personal data;
Right to request transfer of your personal data to another controller or you; and
Right to withdraw consent.

15. Right to Complaint

Kindly note that you have the right to make a complaint at any time to the Nigeria Data Protection Commission (NDPC), the Regulator for data protection in Nigeria (https://ndpb.gov.ng/) or approach the competent court of law to enforce your data protection rights. We would, however, appreciate the chance to deal with your concerns before you approach the NDPC, so please contact us in the first instance.

16. Changes to Our Privacy Notice

This Privacy Notice will be updated from time to time to reflect our processing activities and we will aim to notify you when this happens.

17. Contact Us

All comments, questions, access requests, complaints, and other requests regarding the Privacy Notice should be sent to our email at support@fragvest.com or call 09155555590. We may request additional details from you regarding your complaints and keep records of your requests and resolutions.