Privacy Policy

1.    Introduction    2

2.    Collection of Personal Data    4

3.    Use of Personal Data   

4.    Disclosure of Personal Data   

5.    Data Security   

6.    Data Retention    

7.    Data Subject Rights   

8.    Contact Information    

9.    Changes to the Data Privacy Statement    

1. • Introduction

    

    

   1. Ndovu Wealth Limited (“Ndovu”) is the owner and operator of Ndovu, a registered trademark and roboadvisory platform. 

   2. As a Fund Manager, Ndovu is licensed by the Capital Markets Authority (Kenya) and is also regulated by the Institute of Certified Investment and Financial Analyst (ICIFA), the Communications Authority, and the Nairobi Securities Exchange (NSE).

   3. At Ndovu Wealth Limited, we place a strong emphasis on safeguarding the privacy and confidentiality of the data collected from our fund management activities. As a leading fund manager company, we recognize the critical importance of respecting the privacy and rights of the individuals whose data we collect. We are committed to adhering to all applicable data protection laws and regulations, including the Data Protection Act 2019 and any other relevant regulations, to ensure that the personal data we collect is processed in a lawful, fair, and transparent manner.

   4. We understand that the privacy and security of personal data are fundamental rights, and we take robust measures to protect the confidentiality, integrity, and availability of the data we collect. We have implemented stringent technical and organizational measures to safeguard against unauthorized access, disclosure, alteration, or destruction of personal data. Our security measures include encryption, firewalls, access controls, and regular system updates, among others, to ensure the highest level of data protection.

   5. Additionally, we ensure that the personal data collected from our fund management activities is used solely for the purpose of managing funds and providing related services. We use the data to analyze and make informed investment decisions, monitor portfolio performance, and fulfill regulatory requirements. The data may also be used for statistical analysis and data aggregation, but always in an anonymized and aggregated form to protect the identity and privacy of the individuals.

   6. We are committed to transparency and provide clear and comprehensive information to our clients and investors about our data collection, use, and disclosure practices. We obtain explicit consent from individuals before collecting their personal data, and we provide them with the option to withdraw their consent at any time. We also ensure that the data collected is relevant, accurate, and necessary for the fund management purpose, and we retain the data only for as long as required to fulfill the fund management objectives or as mandated by applicable laws and regulations.

   7. In the event of any data breaches or incidents, we have established robust incident response and data breach notification procedures to promptly detect, mitigate, and address any security breaches or incidents to minimize any potential harm to the affected individuals.

   8. We are committed to upholding the rights of our clients and investors. Individuals have the right to access, correct, update, and delete their personal data held by us, and they can exercise these rights by contacting us. We also respond to any inquiries or concerns related to data privacy in a timely and appropriate manner.

   9. We regularly review and update our data privacy practices to ensure compliance with evolving laws, regulations, and industry best practices. Any changes to our data privacy practices will be communicated through updates to this Data Privacy Policy or through other appropriate channels.

2. • Collection of Personal Data

    

    

   1. At Ndovu Wealth Limited, we take the collection of personal data from our clients and investors with the utmost care and responsibility. We collect a variety of personal data, which may include but is not limited to, names, contact information (such as email address and phone number), financial information, and other relevant information that is necessary for fund management and related services.

   2. The data is collected through various channels, including online forms, account applications, and direct communication, and is obtained only with the explicit consent of the individuals.

   3. When collecting personal data, we ensure that the data collected is relevant, accurate, and necessary for the fund management and service provision purposes, and we collect only the minimum amount of personal data required to fulfill these objectives.

   4. We are transparent in our data collection practices and provide clear information to our clients and investors about the purpose of data collection, the types of data being collected, and how the data will be used. We obtain explicit consent from individuals before collecting their personal data, and we provide them with the option to withdraw their consent at any time.

3. • Use of Personal Data

    

    

   1. At Ndovu Wealth Limited, the personal data collected from our clients and investors is used exclusively for fund management and related purposes. We value the privacy and confidentiality of the data entrusted to us and are committed to using it responsibly and ethically.

   2. The data collected is used to analyze and make informed investment decisions, monitor portfolio performance, and fulfill regulatory requirements. This enables us to provide optimal fund management services to our clients and stakeholders, helping them achieve their financial goals.

   3. Additionally, the data collected is used to improve our own products, services, and business operations, allowing us to continuously enhance the quality and effectiveness of our fund management offerings.

   4. In addition to fund management purposes, the data may also be used for market research, statistical analysis, and data aggregation. However, rest assured that any such use will always be done in compliance with applicable data protection laws and regulations, and with the utmost care to protect the identity and privacy of the individuals.

   5. The data will be anonymized and aggregated in a way that prevents the identification of individuals, ensuring that their personal information remains confidential and secure.

4. • Disclosure of Personal Data

    

    

   1. At Ndovu Wealth Limited, we hold the privacy and confidentiality of personal data collected from our clients and investors as a top priority. We are committed to ensuring that such data is not disclosed to third parties without explicit consent, unless it is required by law or authorized by the individuals themselves.

   2. In certain cases, we may engage third-party service providers to assist us with data collection, analysis, and reporting as part of our fund management activities. These service providers may include data collection agencies, data analysis firms, or technology partners who help us with data processing and management. In such cases, we may need to share personal data with these service providers to enable them to perform their services on our behalf.

   3. However, rest assured that we have strict confidentiality and data protection requirements in place for our third-party service providers. We carefully select our partners and ensure that they comply with industry best practices and applicable data protection laws and regulations. We also have written agreements in place with these providers to govern the handling of personal data and to ensure that they maintain the confidentiality and security of the data entrusted to them.

   4. Furthermore, we do not sell, rent, or trade personal data collected from our clients and investors to any third parties for marketing or commercial purposes. Our primary purpose for collecting personal data is for fund management and related services. Any sharing of personal data with third-party service providers is solely for the purpose of assisting us in carrying out our fund management activities in a secure and effective manner.

5. • Data Security

    

    

   1. At Ndovu Wealth Limited, we prioritize the security and confidentiality of the personal data collected from our clients and investors. We understand the importance of implementing robust technical and organizational measures to safeguard against unauthorized access, disclosure, alteration, or destruction of personal data.

   2. To ensure the security of personal data, we implement industry-standard security measures, including but not limited to encryption, firewalls, access controls, and regular system updates. These measures are designed to protect the integrity and confidentiality of personal data, and we continuously review and update our security protocols to align with best practices in the industry.

   3. However, it’s important to note that no method of data transmission over the internet or electronic storage is completely foolproof. Despite our best efforts, there is always a risk of unauthorized access or data breaches due to the inherent vulnerabilities of online communication and information systems. Therefore, while we take appropriate measures to protect personal data, we cannot guarantee absolute security against all potential threats.

   4. In addition to technical measures, we also have strict policies and procedures in place to govern access to personal data, limit data access to authorized personnel only, and ensure that personal data is used only for the purposes for which it was collected. Our staff undergoes regular training on data protection and privacy to ensure compliance with our data handling practices and to maintain the confidentiality and security of personal data.

6. • Data Retention

    

    

   1. At Ndovu Wealth Limited, we follow strict data retention policies to ensure that personal data collected from our clients and investors is retained only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable laws and regulations.

   2. The retention period of personal data depends on the nature of the fund management activities and the specific purposes for which the data was collected. We carefully assess the data retention requirements for each client or investor, taking into consideration legal obligations, the purpose of the fund management services, and the consent obtained from the individuals.

   3. Once the data is no longer needed, we take appropriate measures to securely delete or anonymize it to prevent identification. Data deletion is carried out in accordance with industry-standard practices to ensure that the data is permanently and irreversibly removed from our systems.

   4. In cases where anonymization is chosen as the method of data handling, we ensure that the anonymized data is stripped of any personally identifiable information and transformed into a format that cannot be used to identify individuals. Anonymized data may be used for research, analysis, or reporting purposes, but it will not contain any identifiable information.

7. • Data Subject Rights 

    

    

   1. At Ndovu Wealth Limited, we respect the rights of our clients and investors and are committed to ensuring that they have control over their personal data. Clients and investors have the right to access, correct, update, and delete their personal data that we hold, as well as to withdraw their consent for data collection and processing at any time.

   2. We have implemented processes and procedures to facilitate clients and investors in exercising their data protection rights. Upon request, we will provide them with access to their personal data and allow them to review, update, or correct any inaccuracies. If they wish to delete their personal data, we will take appropriate measures to securely delete or anonymize it, in accordance with our data retention policies.

   3. In addition, clients and investors have the right to request information about the data we hold about them, including the purposes for which it is being processed, the categories of recipients to whom it may be disclosed, and the legal basis for processing. We are committed to providing clear and transparent information about our data practices and will respond to such requests in a timely manner.

   4. Furthermore, if clients and investors believe that their data protection rights have been violated, they have the right to lodge a complaint with the relevant data protection authority in their jurisdiction. We take such complaints seriously and will cooperate with the data protection authority in any investigation or resolution process.

8. • Contact Information

    

    

If you have any questions, concerns, or requests regarding our data privacy practices, please contact us at compliance@ndovu.co  

9. • Changes to the Data Privacy Statement

    

    

We reserve the right to update or modify this Data Privacy Statement at any time without prior notice to reflect changes in our data privacy practices or legal requirements. Any updates or modifications will be effective upon posting on our website or notifying participants through other appropriate channels. 

Last updated: [31/5/2023]