Eanvest Ltd, a private limited company having its office at 1B, Etim-Inyang Crescent, Victoria Island, Lagos (hereinafter referred to as "Company", "We", "Us" or "Our", which expression shall include its affiliates, subsidiaries, successors and assigns), owns and operates the website www.eanvest.com and/or the mobile application "Eanvest" (collectively referred to as the "Platform"). "You" and "Your" shall mean anyone who visits, accesses, or uses the Platform or obtains Services (defined below) from Us through the Platform. We are committed to protecting Your privacy and the information You share with Us while using and operating the Platform. We value the trust You place in Us and thus We maintain the highest security standards for securing the transactions and Your information.
We may also allow Our group companies, affiliates and subsidiary companies to use Our Platform to offer their products and services to You, under applicable terms and conditions as may be specified on Our Platform from time to time.
This privacy policy ("Privacy Policy") specifies the manner in which personal data and other information are collected, received, stored, processed, disclosed, transferred, dealt with or otherwise handled by the Company. This Privacy Policy does not apply to all information that You provide to, or that is collected by, any third party (excluding the group companies, affiliates and subsidiary companies) through the Platform, and any Third-Party Sites that You access or use in connection with the services offered on the Platform.
Please read the Privacy Policy carefully prior to using or registering on the Platform or accessing/availing the services made available on the Platform ("Services").
By accessing the Platform and/or using the Services, You accept and agree to be bound by the terms and conditions of this Privacy Policy. This Privacy Policy is incorporated into and shall be subject to the Terms and Conditions of the Platform ("Terms"). The Privacy Policy shall be read harmoniously and in conjunction with the Terms.
This Privacy Policy (i) is an electronic record under Nigerian law, read with rules and regulations made thereunder, and is generated by a computer system; and (ii) will not require any physical, electronic, or digital signature.
In case of any non-compliance with the Privacy Policy by You or any of Your representatives, We shall have the right to terminate Your access to the Services or any part thereof or Your usage rights to the Platform immediately, or remove non-compliant information, or both, as the case may be.
1. Collection of Information
We may collect Personal Information, Transaction Information and Non-Personal Information (defined below) from You when You register or set up an account with Us on the Platform or when You avail the Services. You can browse certain sections of the Platform without being a registered member; however, to avail certain Services on the Platform You are required to register with Us.
This Privacy Policy applies to the following information:
Information You provide Us: You may provide certain information to Us voluntarily while registering on Our Platform or for using Our Services. Such information includes any identification/correspondence details, including Your mobile number, email address, password, date of birth, gender, biometric information, Bank Verification Number (BVN), National Identification Number (NIN), signature, marital status, facial recognition data, nominee details, residential/current address, any national identifiers such as identity card / passport details / Voter ID / driving licence, and/or education details. We may also ask You to provide certain additional information about You or any person acting on Your behalf on a case-by-case basis (collectively "Personal Information"). We may collect your image (upload, storage, and use) information on our platform for app functionality, and You hereby give Your consent for the same. We may also collect information from your images and camera liveness when you use our customer support to upload evidence such as statements and cheques, and in connection with regulatory KYC purposes. When you visit any of our offices, our CCTV cameras may also process your images. Further, You hereby acknowledge and agree that Our affiliates or group or subsidiary companies registered with financial services regulators may retrieve from Your records available with third parties, including from Know Your Customer (KYC) checks, such as name, KYC details, KYC status, mother's maiden name, occupation, address details and related documents. We may also collect Your risk and preference data, which may include Your responses to Naomi's risk questionnaire, Your investment objectives, time horizon, and stated risk tolerance, and Your communication preferences.
Transactional Information: We may also ask You for certain financial information, including Your billing address, bank account details, income, expenses, source of wealth declarations, and/or credit history, including transaction history, balances, and/or other payment-related details or other payment method data, and debit instructions or other standing instructions to process payments for the Services, and information about external assets you choose to register, including real estate, vehicles, and other physical assets. Further, if You choose to invest through the Platform, We will also collect information about Your transactions, including transaction status/ID and details, and Your investing patterns and behaviour (collectively "Transaction Information").
Non-Personal Information and Cookies: We may also collect certain non-personal information, such as Your internet protocol address, web request, operating system, browser type, URL, internet service provider, aggregate user data, software and hardware attributes, pages You request, and cookie information, which will not identify You specifically ("Non-Personal Information"), while You browse, access or use the Platform. We receive and store Non-Personal Information using data collection devices such as "cookies" on certain pages of the Platform, in order to help analyse Our web-page flow, track user trends, measure promotional effectiveness, and promote trust and safety. We offer certain additional features on the Platform that are only available through the use of a "cookie". We place both permanent and temporary cookies on Your computer's hard drive; most are "session cookies", meaning they are automatically deleted from Your hard drive at the end of a session. You are always free to decline Our cookies if Your browser permits, although in that case You may not be able to use certain features or Services on the Platform, or You may be required to re-enter Your password each time you log in. No Personal Data will be collected via cookies and other tracking technology; however, if You previously provided Personal Data, cookies may be tied to such information. When You download and/or use the Platform through Your mobile device, We may receive information about Your location, Your IP address, and/or Your mobile device, including a unique identifier number for Your device, which We may use to provide You with location-based Services. You can withdraw Your consent at any time by disabling the location-tracking functions on Your mobile, though this may affect Your enjoyment of certain features. You acknowledge and agree that when You browse the Platform without being a registered member, We may still collect and store Your Non-Personal Information.
User Communications: If You choose to post messages on our message boards, chat rooms or other message areas, or leave feedback, or send us correspondence such as emails, letters or calls, or if other users or third parties send us correspondence about Your activities on the Platform ("User Communications"), We will collect and store such information. We retain this information as necessary to resolve disputes, provide customer support, respond to queries, and troubleshoot problems and improve the Services. Any communication, post, comment or correspondence made by You while using the Platform, including any communication with our customer service (including any integrated AI feature or chatbot offered by the Platform), may be collected and retained as per the terms of this Privacy Policy.
All information disclosed by You, including but not limited to Your Personal Information, Non-Personal Information, User Communications and Transaction Information, shall be deemed disclosed willingly and without coercion. No liability pertaining to the authenticity, genuineness or misrepresentation of Your information provided to Us, or with regard to any fraud or negligence, shall lie on the Company, nor will the Company be responsible to verify any information obtained from You. All information collected shall be stored on servers, log files and any other storage system owned by the Company or by third parties. Our primary goal is to provide You a safe, efficient and customised experience on the Platform, and to make Your experience safer and easier.
Wherever possible, We indicate which fields are mandatory and which are optional. You always have the option not to provide Personal Information by choosing not to use a particular Service or feature that requires it.
2. Use of Your Information
We use the Personal Information, Non-Personal Information, Transactional Information and User Communications provided by You for the following: (i) to provide and improve the Services on the Platform that You request; (ii) to resolve disputes and troubleshoot problems; (iii) to help promote a safe service and protect the security and integrity of the Platform, the Services and users; (iv) to collect money from You in relation to the Services; (v) to inform You about online and offline offers, products, services and updates; (vi) to customise Your experience or share marketing material with You; (vii) to detect, prevent and protect Us from errors, fraud and other criminal or prohibited activity on the Platform; (viii) to enforce and inform about our Terms; (ix) to process and fulfil Your requests or respond to Your comments and queries; (x) to contact You; (xi) to allow Our business partners and associates to present customised messages to You; (xii) to communicate important notices or changes in Services, use of the Platform, or the terms/policies governing Our relationship with You and Our affiliates; and (xiii) for any other purpose after obtaining Your consent at the time of collection.
You hereby specifically agree and provide Your consent enabling Us and/or Our group companies, subsidiaries and affiliates to collect, store, transfer, process and share information (including Personal Information) related to You with third parties such as banks, financial institutions, credit information companies, entities registered under applicable law with the Securities and Exchange Commission Nigeria, the Nigerian Exchange, the Central Securities Clearing System, the Central Bank of Nigeria, the Nigerian Financial Intelligence Unit (NFIU), payment gateways and collecting banks, solely for the purpose of reviewing Your profile and processing Your transaction requests for the Services or for other products/services offered by Us or Our group companies, affiliates and subsidiary companies.
We may automatically track certain information about You based on Your behaviour on the Platform, and use it to do internal research on Your demographics, interests and behaviour to better understand, protect and serve You, on an aggregated basis that does not specifically identify You.
We also use Your IP address to help diagnose problems with Our servers, resolve such problems, administer the Platform, and gather broad demographic information.
We may occasionally ask You to complete optional online surveys, which may ask for contact and demographic information, to tailor Your experience and content preferences. We use Your Personal Information to send You promotional emails, but We will provide You the ability to opt out. If You opt out, the Company may still send You non-promotional emails, such as those about the Services and Your account.
Unless and until You explicitly give Your consent, We will not share Your Personal Information with another user of the Platform, and vice versa.
3. Sharing of Information
We may make Your Personal Information, Non-Personal Information, Transaction Information, User Communications and/or other information available to Our affiliates and subsidiary companies to enable providing You Services through the Platform. All information shared with or made available to group companies, affiliates and subsidiary companies will be governed by this Privacy Policy. In order to provide Services to You, Eanvest may also collect Your BVN, NIN, biometrics, facial information, fingerprint details and signature solely for completing account-opening procedures and authenticating Your transactions. Providing Your BVN and/or NIN is voluntary, and the Company will collect, use and store such details in compliance with applicable laws and this Privacy Policy.
We may also disclose Your Personal Information, including transactional information, to third-party vendors, consultants and other service providers who are bound by contractual obligations to keep such information confidential and use it only for the purposes We disclose it to them, and You hereby give Your consent for the same. This may be required, for instance, to provide You access to Services and/or process payments (including validating Your bank accounts), to facilitate Our marketing and advertising activities, to undertake auditing or data analysis, or to prevent, detect, mitigate and investigate fraudulent or illegal activities related to Our Services.
You hereby specifically agree and provide Your consent enabling Us and/or Our associate/affiliate companies to access, store, transfer and process Your SMS data for the purpose of reviewing Your profile or doing internal evaluation and analysis, and to share Your SMS data with third parties such as banks and billers/utility service providers towards the services offered, and You hereby give Your consent for the same. You further understand that Eanvest may access and process Your SMS data for the purpose of streamlining Your usage of the Platform, using relevant encryption methodologies such as hashing, and will use such data only for the limited purposes set out under this Privacy Policy.
The Company may disclose Your information to the extent necessary: (i) to comply with laws and respond to lawful requests and legal process; (ii) to protect the rights and property of the Company, Our users and others, including to enforce the Terms; and (iii) in an emergency, to protect the personal safety and assets of the Company, users, or any person. In such an event, the Company is not obliged to inform You or seek Your approval or consent.
We and Our affiliates and subsidiary companies (to the extent Personal Information is collected by them) may, in compliance with applicable laws, share, transfer or assign all of Your Personal Information and other information with any other business entity in the event of a merger, sale, reorganisation, amalgamation, joint venture, assignment, restructuring of business, or transfer or disposition of all or any portion of Our business.
4. Connecting Your Email Account
You may choose to provide Your explicit consent to connect/integrate Your email account(s) with Your account on the Platform by clicking on the authentication email sent by the Company to Your registered email address.
We encourage You to review the information prior to giving Your consent for integration of Your email address. The Company will not use or transfer any data or information received from this integration to third parties for serving ads, including retargeting, personalised or interest-based advertising. Such data will be used by the Company solely for providing the Services, improving Your experience of the Platform's features, and consolidating Your investment details and history.
5. Links to Other Third-Party Sites and Collection of Information
Our Platform may link You to other third-party platforms ("Third-Party Sites") that may collect Your Personal Information, including Your IP address, browser specification, or operating system. The Company is not responsible for the security of such information or the privacy practices or content of those Third-Party Sites. You may also encounter "cookies" or similar devices on Third-Party Sites; the Company does not control the use of cookies by Third-Party Sites, and their own privacy policies (not this one) govern the information You provide to, or that is collected by, them. We recommend that when You enter a Third-Party Site, You review its privacy policy. We use third-party advertising companies to serve ads when You visit the Platform. These companies may use information (not including Your name, address, email address, or telephone number) about Your visits to the Platform and Third-Party Sites to provide advertisements about goods and services of interest to You. You agree that We are not liable for information published in search results or by any Third-Party Sites.
6. Security Precautions and Measures
Our Platform has reasonable security measures and safeguards in place to protect Your privacy and Personal Information from loss, misuse, unauthorised access, disclosure, destruction and alteration, in compliance with applicable laws. Whenever You access Your account or related information, We offer the use of a secure server. We cannot, however, ensure or warrant the security of any information You transmit to the Company, or guarantee that Your information will not be accessed, disclosed, altered or destroyed by a breach of Our security measures. You have the obligation to take adequate physical, managerial and technical safeguards, at Your end, to preserve the integrity and security of Your data, including Your Personal Information.
When Transaction Information is transmitted on or through the Platform, it will be protected by encryption technology. You expressly consent to the sharing of Your information with third-party service providers. We take various steps to protect Your information from misuse, loss, unauthorised access, modification or disclosure, using secure server-layer encryption and access control on our systems. Please do not share Your account's login, password, OTP details or credentials with anybody.
While We observe reasonable security measures, security risks may still arise for reasons outside Our control, such as hacking, virus dissemination, force majeure events or breach of firewall. These measures do not guarantee absolute protection of Your Personal Information. The Company assumes no liability for disclosure of Your information due to errors in transmission, unauthorised third-party access, or other causes beyond its control. You play an important role in keeping Your information secure and shall not share it with anyone. We shall not be liable for unauthorised or unlawful disclosures made by third parties who are not subject to Our control.
You agree to notify Us immediately of any unauthorised or illegal access/use of Your account or any breach of security arising from Your action or inaction. We shall notify You and/or the appropriate authority in case of any breach of security at Our end, in accordance with the timelines prescribed under applicable law.
This Privacy Policy, and the security controls and practices We implement to protect Your Personal Information, reflect the reasonable security practices and procedures required by the laws of the Federal Republic of Nigeria.
You shall not host, display, upload, modify, publish, transmit, store, update or share any information that:
- belongs to another person and to which You do not have any right;
- is obscene, pornographic, invasive of another's privacy (including bodily privacy), insulting or harassing on the basis of gender, racially or ethnically objectionable, relating to or encouraging money laundering or gambling, promotes enmity between groups on grounds of religion or caste with intent to incite violence, or is harmful to a child;
- infringes any patent, trademark, copyright or other proprietary right;
- deceives or misleads about the origin of a message, or knowingly communicates misinformation or information that is false or misleading;
- impersonates another person;
- threatens the unity, integrity, defence, security or sovereignty of Nigeria, or friendly relations with foreign states, or public order, or incites the commission of an offence, or is insulting to another nation;
- contains a software virus or other code, file or program designed to interrupt, destroy or limit the functionality of any computer resource; or
- violates any law for the time being in force.
7. Automated Decision-Making and Profiling
Naomi, our recommendation engine, uses information you provide to generate insights and suggested portfolio allocations. This involves automated processing, but does not constitute solely automated decision-making with legal or similarly significant effects, because all investment decisions and order instructions remain with you. You have the right to request a human review of any output that significantly affects you. For more information, see our Naomi AI Disclaimer.
8. Your Consent and Changes to This Policy
Your Consent: By visiting the Platform or setting up/creating an account for availing the Services, You signify Your acceptance of the provisions of this Privacy Policy.
Account Deletion: You may choose to delete Your account on the Platform (i.e. the website eanvest.com and/or the mobile application, Eanvest) and any associated information, at any time. Such a request must be sent in writing to support@eanvest.com. Once You request deletion, You will no longer be able to access the Platform or use the Services, and We reserve the right not to provide You any further Services. We may delete Your information or de-identify it so that it is anonymous and no longer attributable to You. Notwithstanding this, We may retain some or all of Your information in accordance with Our policies and/or requirements under applicable law.
Changes to This Privacy Policy: We reserve the unconditional right to change, modify, add to, or remove portions of this Privacy Policy at any time, without specifically notifying You. We may, at Our discretion, provide push notifications or other forms of notice to keep You updated. Any changes will be effective immediately. You should review this Privacy Policy regularly; You can determine if changes have been made by checking the "Last Updated" date above. Your continued use of the Platform signifies Your consent to such changes.
9. Grievance
If You have any grievance with respect to the Platform, please reach out to Us at support@eanvest.com.
10. Questions
Please contact us at support@eanvest.com regarding any questions on this Privacy Policy.
11. Governing Law and Jurisdiction
This policy is governed by and construed in accordance with the laws of the Federal Republic of Nigeria.