Respecting your privacy rights is important to us. Please read below to understand the purposes for which we process your personal data and who it may be shared with:
Privacy Statement for all parties to a Ndovu account
This Privacy Statement relates to the collection, use and disclosure of personal data, including special or sensitive personal data, by Waanzilishi Capital Limited, its affiliates, website and Android & iOS applications (“Ndovu”, “we” or “our”). Personal Data is information relating to an individual (“you” or “your”).
Personal data comprises all the details Ndovu holds or collects about you, directly or indirectly, your transactions, transactions you effect, financial information, interactions and dealings with Ndovu, including information received from third parties, the public domain, collected through use of our website, cookies, and our digital advisory services.
If you do not provide us with the personal data that we need to meet our legal and regulatory obligations or to enter into an agreement with you, we may not be able to provide you with the services you have requested.
Purposes for which we may process your Personal Data
To enable us to fulfil the contract between us for the services you have requested, we need to process your personal data for purposes including the following:
- processing applications for services, effecting payments, transactions and completing instructions or requests;
- providing services (including digital advisory);
- assessing suitability for products and services;
- operational purposes;
- statistical purposes;
- establishment, continuation and management of advisory relationships and investment accounts;
For some purposes in connection with the service you have requested, we have a legal or regulatory obligation to process your Personal Data. These purposes include:
- the prevention, detection, investigation and prosecution of crime in any jurisdiction (including, without limitation, money laundering, terrorism, fraud and other financial crime);
- identity verification, government sanctions screening and due diligence checks;
- to comply with local or foreign law, regulations, directives, judgments or court orders, government sanctions or embargoes, reporting requirements under financial transactions legislation, and demands of any authority, regulator, tribunal, enforcement agency, or exchange body.
We may also process your Personal Data in line with any voluntary codes; to effect agreements between Waanzilishi Capital and any authority, regulator, or enforcement agency; to comply with policies and good practice standards where it is in our legitimate interest to do so.
We may also process your Personal Data where it is in our legitimate interests to seek professional advice, including, in connection with any legal proceedings (including any prospective legal proceedings), for obtaining legal advice or for establishing, exercising or defending legal rights.
To whom we may disclose Personal Data
Any member of Waanzilishi Capital and its affiliates, including our officers, employees, agents and advisers, may disclose your Personal Data to any of the following parties for any of the purposes specified above:
- any member of Waanzilishi Capital and its affiliates anywhere in the world, including any officer, employee, agent or director;
- professional advisers (including auditors), third party service providers, agents or independent contractors providing services to support our business;
- our business alliance partners who may provide their product or service to you;
- upon your death or mental incapacity, your legal representative and their legal advisers, and a member of your immediate family for the purpose of allowing him/her to access your investment account;
- any person to whom disclosure is allowed or required by local or foreign law, regulation or any other applicable instrument;
- any court, tribunal, regulator, enforcement agency, exchange body, tax authority, or any other authority (including any authority investigating an offence) or their agents;
- any fraud prevention agency;
- any financial institution to conduct credit checks, anti-money laundering related checks, for fraud prevention and detection of crime purposes;
Personal Data may be transferred to, or stored at, a location outside of your country of residence, which may not have data protection law. The security of your personal data is important to us. We have technical and organisational security measures in place to safeguard your personal data. When using external service providers, we require that they adhere to our mandated security standards. We may do this through contractual provisions, including any required by a privacy regulator, and oversight of the service provider. Regardless of where personal data is transferred, we take all steps reasonably necessary to ensure that personal data is kept securely.
You should be aware that the Internet is not a secure form of communication and sending us any personal data over the Internet carries with it risks including the risk of access and interference by unauthorised third parties. Information passing over the Internet may be transmitted internationally (even when sender and recipient are located in the same country) via countries with weaker privacy and data protection laws than in your country of residence.
Other Terms and Conditions
There may be specific terms and conditions in our service agreements that govern the collection, use and disclosure of your personal data. Such other terms and conditions must be read in conjunction with this Privacy Statement.
We retain your personal data in line with our legal and regulatory obligations and for business and operational purposes. In the majority of cases this will be for seven years from the end of your relationship with us.
Automated decisions and profiling
We may use profiling, including behavioural analysis, to assist us to provide you with better services, to make decisions and to prevent money laundering, terrorism, fraud and other financial crime, for example using profiling may help us to try and detect whether use of your credit card may be fraudulent. If any profiling will result in an automated decision relating to you, we will let you know and you will have the right to discuss the decision with us.
We may use your Personal Data:
i. to conduct market research and surveys with the aim of improving our services;
ii. for marketing purposes, promotional events, competitions and lucky draws.
We process your Personal Data for these purposes because it is in the interest of our business to do so with the intention of improving our products and services and generating business. We will not send you marketing material if you have specifically asked us not to do so. You have the right to opt out of receiving marketing material at any time. To do so please contact our support team.
If you change your mind and ask us not to send you marketing material or other promotional or research material you have subscribed to receive, we may need to retain a record that you have asked us not to do so to ensure that you do not receive anything further.
To the extent permitted by law, we may record and monitor your electronic communications with us to ensure compliance with our legal and regulatory obligations and internal policies for the purposes outlined above.
Subject to applicable law, regulations and/or capital market guidelines, you may have the following rights:
To request a copy of the personal data processed in relation to you. We may be allowed by law to charge a fee for this.
To request that we correct your personal data. You can do this via our support team.
To ask us to delete your personal data, for example if we no longer have a valid reason to process it.
To object to how we process your personal data. This does not mean you can decide or choose how we process your personal data other than in relation to marketing. If you have any concerns about how we process your personal data, please discuss this with our support team. We may not be able to offer you services if you do not want us to process the personal data that we consider necessary in order to provide the services.
To restrict how your personal data is processed in certain cases, such as when the accuracy of your Personal Data is contested. If you have any concerns about how we process your Personal Data, please discuss this with our support team.
If you have a complaint in relation to the processing of your Personal Data and you are not happy with the way we deal with it, please contact the Chief Risk and Compliance Officer.