1.0 Introduction

UCML Capital Limited (hereafter referred to as “UCML” “we” “our” “us), is a foremost investment and advisory firm committed to meeting the diverse and changing needs of our clients by providing a full array of innovative, customized financial solutions that create long lasting value for our investors, the companies in which we invest and society at large. Our services include Investment banking, Private Equities, Securities, Asset Management, Real Estate, and Research. UCML collects information that you provide to us or as described in this Policy. We are committed to protect any personal information (“Personal Information” as defined in section 3.0 below) that you provide when you are using any of our services. We want our services to be safe and secure for our Users. Uniform practices for collecting, using, disclosing, storing, retaining, disposing, accessing, transferring, or otherwise processing such information assists UCML to process Personal Information fairly and appropriately, disclosing it, using it and/or transferring it only under appropriate circumstances. This Policy relates to our use of any Personal Information we collect from you for providing information related to our services. This Policy tells you how we use your Personal Information collected through the Site. Kindly read this Policy to be adequately informed. This Policy will be updated upon any changes in information collection, activities performed or applicable regulations. You are encouraged to review the Policy whenever you visit the Site to make sure that you understand how any Personal Information you provide will be used.

2.0 WHAT PERSONAL DATA WE COLLECT

Our company collects the following Personal Data:

  • Personal Identifiable information (Name, phone number, email, address)
  • Bank details
  • And other relevant personal information that may be required during KYC update

3.0 HOW WE COLLECT AND USE YOUR INFORMATION

You directly provide us with most of the data we collect. We collect and process data when you:

  • Send your CV during our hiring process.
  • Use or view our website.
  • Engage us for our services.

Personal Information (PI): It is the information that relates to an identified or identifiable person such as name, an identification number, location data etc. Thus, Personal Information (PI) only includes information relating to natural persons who:

  • can be identified or who are identifiable, directly from the information.
  • who can be indirectly identified from that information in combination with other information.

Sensitive Personal Information (SPI): Is defined as Personal Information revealing racial, ethnic origin, political opinions, genetic data, biometric data etc. of an individual.


We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.


We use personal information collected via our Sites for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests ("Business Purposes") to enter or perform a contract with you ("Contractual"), with your consent ("Consent"), and/or for compliance with our legal obligations ("Legal Reasons"). We indicate the specific processing grounds we rely on next to each purpose listed below.


We use the information we collect or receive:

  • To send you marketing and promotional communications [for Business Purposes and/or with your Consent]. We and/or our third-party marketing partners may use the personal information you send to us for our marketing purposes if this is in accordance with your marketing preferences. You can opt-out of our marketing emails at any time (see the "Your Privacy Rights" below).
  • To send administrative information to you [for Business Purposes, Legal Reasons and/or possibly Contractual]. We may use your personal information to send you product, service, and new feature information and/or information about changes to our terms, conditions, and policies.
  • and manage your orders [for Contractual reasons]. We may use your information to fulfill and manage your orders, payments, returns, and exchanges made through the Sites.
  • Request Feedback [for our Business Purposes and/or with your Consent]. We may use your information to request feedback and to contact you about your use of our Sites.
  • protect our Sites [for Business Purposes and/or Legal Reasons]. We may use your information as part of our efforts to keep our Sites safe and secure (for example, for fraud monitoring and prevention).
  • To enforce our terms, conditions, and policies [for Business Purposes, Legal Reasons and/or possibly Contractual].
  • To respond to legal requests and prevent harm [for Legal Reasons]. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
  • For other Business Purposes. We may use your information for other Business Purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Sites, products, services, marketing, and your experience.

3.1 WHO WE SHARE YOUR PERSONAL INFORMATION WITH

We only share your information either with your consent, to comply with laws, to protect your rights, or to fulfill business obligations. We only share and disclose your information in the following situations:

  • Compliance with Laws: We may disclose your information where we are legally required to do so to comply with applicable laws, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
  • Vendors, Consultants and Other Third-Party Service Providers: We may share your data with third party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts.
  • Business Transfers: We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
  • Affiliates: We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy policy. Affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.
  • Business Partners: We may share your information with our business partners to offer you certain products, services, or promotions.
  • your Consent: We may disclose your personal information for any other purpose with your consent.

3.2 PERSONAL INFORMATION OF CHILDREN

We do not knowingly solicit data from or market to children under 18 years of age. By using the Sites, you represent that you are at least 18 years or that you are the parent or guardian of such child and consent to such child dependent’s use of the Site. If you become aware of any personal information, we have collected from children under age 18, please contact us at enquiries@unioncapitalmarkets.com.


4.0 INTERNATIONAL TRANSFER OF PERSONAL INFORMATION

We may transfer, store, and process your information in countries other than Nigeria. Our website domain is hosted outside Nigeria. If you are accessing our Sites from outside Nigeria, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information.


5.0 WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?

We are not responsible for the safety of any information that you share with third-party providers who advertise, but are not affiliated with, our websites. The Sites may contain advertisements from third parties that are not affiliated with us, and which may link to other websites, online services, or mobile applications. We cannot guarantee the safety and privacy of data you provide to any third parties. Any data collected by third parties is not covered by this privacy policy. We are not responsible for the content or privacy and security practices and policies of any third parties, including other websites, services or applications that may be linked to or from the Sites. You should review the policies of such third parties and contact them directly to respond to your questions.


6.0 HOW LONG WE KEEP YOUR INFORMATION

We keep your information for as long as necessary to fulfill the purposes outlined in this privacy policy unless otherwise required by law. We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this policy will require us keeping your personal information for longer than is necessary or as required by the regulators.


When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.


7.0 HOW WE KEEP YOUR INFORMATION SAFE

We aim to protect your personal information through a system of organizational and technical security measures. We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although, UCML will ensure that personal information of Data Subjects under its care is adequately protected.


8.0 DATA SUBJECTS RIGHTS

As contained in the Nigeria Data Protection Regulation (NDPR), Data subjects have certain rights. These may include the right:

  • To request access and obtain a copy of your personal information.
  • To request rectification or erasure.
  • To restrict the processing of your personal information.
  • if applicable, to data portability.
  • In certain circumstances, you may also have the right to object to the processing of your personal information.

To make such a request, please contact reach out to us via enquiries@unioncapitalmarkets.com .We will consider and act upon any request in accordance with applicable data protection laws. If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal.


9.0 UPDATES ON THIS POLICY

We will update this policy as necessary to stay compliant with the Regulation. We may update this privacy policy from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information.


10. HOW YOU CAN CONTACT US

If you have questions or comments about this policy, email us at wasiu.amusa@unioncapitalmarkets.com or enquiries@unioncapitalmarkets.com

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7,Fatai Durosinmi Etti Crescent, Off Ligali Ayorinde Street, Victoria Island ,Lagos.

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