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Data Privacy Policy


Privacy of Adults
Here at Veritas Registrars Limited, we have a crystal-clear understanding that trusting us with your information is a huge obligation. Your privacy is of utmost importance to us and that is why we work hard to make sure your information is extremely secure, and we put you in control.

This Privacy Policy is meant to give you a better understanding of the kind of information we collect, our reason(s) for collecting such information, modes of collection, information sharing and the retention period of the information in line with the Nigerian Data Policy Regulation standards. Data we hold or collect comprises of all the details of employees, shareholders, vendors, clients and stockbrokers, directly or indirectly. This includes any online or offline data that makes a person identifiable such as usernames, passwords, phone numbers, nationality, full names, photographs, addresses, date of birth, email, tribe, account number and bank verification number. These data may be received from our website, stockbrokers and other digital online platforms.

Ensuring respect for individual human rights is maintained, we collect, store and handle data with care and transparency with this policy. For the purposes of this Policy, references to “we” and “us” shall refer to Veritas Registrars Limited.

Any individual, set of individuals or body on whose instruction you are providing us with their personal data must sight, read and clearly understand this policy.

In the event you decide to provide us your personal information or the personal information of someone else or a group of people that have authorized you to do so, you acknowledge that we can use it in the ways clearly spelt out in this privacy policy. In the event a need arises that entails certain uses of your personal information outside those originally stated in the policy, we will update our policy and send you notifications.

Due to our everchanging world, several key factors change. These factors include but not limited to technological advancements, new/revised government regulations or a change in data protection laws or privacy generally. Kindly keep yourself up to date by visiting the Veritas Registrars website to view the most recent privacy policy periodically.

Privacy of Children
Veritas Registrars holds in high esteem the privacy of children. On no account do we sell shares directly to children or deliberately collect email addresses, date of birth, names or other personal identifiable information from children under eighteen (18) years of age. In exceptional cases where shares are bought in the name of children or in a situation where it is required to register them as beneficiaries in relations to shares registration, their parents or authorized wards provide us with their information.

Personal Information we collect
The information we collect depends on the service we will be rendering to you. In a situation where you mention other people as beneficiaries, we might ask you to provide the information below in with respect to those people too, if it is relevant to your shares/holdings.

Where Veritas Registrars is a data controller of your personal information, we may collect the following data about you:
 Personal information such as First Name, Last Name, Middle Name, Email address, residential address and mobile number.
 Identification Information such as Date Of Birth, Place of Birth, Tribe, Gender, Nationality, Next of Kin Name, Next of Kin Contact, Passport Photograph, National Identity Number, Bank     Verification Number including other identification number from your passport, driving licence and other valid means of identification you may choose to present.
 Financial information such as bank details.
 Information obtained through our use of cookies. You can find out more about this in our
cookies policy.
 Information regarding your relationship(s), for example your marital status.

How we collect your personal information
We collect information directly from you:
 Via registration forms, Mandate forms, feedback forms and enquiry.
 Via our telephone conversations with you.
 Via our online platforms such as our website.
 Through quotes and application forms.
 Via cookies. You can find out more about this in our cookies policy.
 When you sell or purchase shares.

We also collect your personal information from different sources including:
 Directly from a share holder that has named you as a beneficiary.
 Directly from stockbrokers and stockbroking firms with whom you have registered.
 From social media platforms, in exceptional cases where fraud is suspected or detected.
 Other third parties such as family members, in an event you are unable to provide useful information or incapacitated.

Principles we implement
 We process your personal information in accordance with your rights.
 We make sure the personal information we collect from you is unaltered and updated when necessary.
 Deliberate steps are taken to make sure we maintain the integrity and safety of your personal information.
 Personal information you provide us with is processed fairly, lawfully and in a transparent manner.
 We do not keep your personal information longer than necessary for purposes for which personal information is processed.
 We collect your personal information for a specific purpose and will not be processed in a way that conflicts with the purpose for which Veritas Registrars collected it.
 Veritas Registrars will never sell your personal information and we will not permit the selling of customers data by any person or body who provides any form of service to us.
 We will not transfer your personal information to any relevant body or organization without taking the necessary steps to ensure that your personal information is protected. Such steps may include placing the party we are transferring information to under contractual obligations to protect your personal information to adequate standards.
 We only collect adequate personal relevant information from you. This personal information collected is limited to what is necessary in relation to the purpose for which it is processed.

How we use your personal information
At Veritas Registrars, we need to have a cogent reason on legal grounds for collecting and using your personal information, under data protection laws. Stated below are the fundamental reasons why we process your personal information and scenarios where it becomes necessary for us to do so:
 Where we must set you up as a shareholder, assigning a unique account number to you, specifying the quantity of shares you bought, the number of units and beneficiaries you have mentioned in your registration form.
 When its time to pay dividends, it is extremely necessary for us to access your personal information as to avoid mistakes in making payments.
 Where we have a legal or regulatory obligation to use such personal information, for example, when our regulators such as the National Information Technology Development Agency (NITDA) wants us to maintain certain records of any dealings with you.
 In order to comply with local and foreign laws, regulations, judgment or court orders, agreement between any member of Veritas Registrars and any regulator or enforcement agency, reporting requirements under financial transactions legislation and demands or requests of authority, regulatory, exchange body or enforcement agencies such as the Nigeria Financial Intelligent Unit (NFIU) and the Economic and Financial Crime Commission (EFCC).
 Where we need to use your personal information to establish, exercise or defend our legal rights.
 In cases where you make complaints, we will need to use your personal information to communicate with you.
 Where you have given us consent to use your personal information.
 Where we have legitimate business need to use your personal information such as maintaining our records, developing and improving pour services, ensuring that such business need does not interfere with your rights, freedom and does not cause harm to you in any way.

With Who we share your personal information
Here at Veritas registrars we do not share any of your personal information order than for the purposes described in this Privacy Policy. We might share your personal information with relevant offices within Veritas Registrars and other third parties outside Veritas Registrars.
Disclosures within Veritas Registrars
In order to Provide our services, your personal information might be shared with relevant offices within Veritas Registrars. Your personal information might be shared for our general business administration, efficiency and accuracy purposes or for the prevention and detection of fraud.
Disclosure to third parties
Your personal information is also disclosed to third parties listed below for purposes described in this Privacy Policy. This might include:
 Where you have named an alternative contact (such as a relative) or a beneficiary to speak with us on your behalf. Once you have communicated to us who your alternative contact will be, this person by virtue of your authorization is now allowed to discuss all aspects of your agreement with us and make changes on your behalf.
 Your Guardians (acting on your behalf where you are incapacitated or unable to come in person), relatives or other people and firms associated with you such as your stockbroker and representatives of stockbroking firms you registered with and have authorized to act on your behalf.
 Central Securities Clearing System (CSCS)
 Fraud detection agencies and other third parties who maintain fraud detection registers.
 The police and other third parties or law enforcement agencies where reasonably necessary for the prevention or detection of crime.
 Our third-party service providers such as auditors and lawyers.
We may also disclose your personal information to other third parties where:
 We believe that such disclosure is necessary in order to assist in the prevention or detection od any criminal action (including fraud) or is otherwise in the overriding public interest; or
 Exemptions under the data protection legislation allow us to do so.
 We are required or permitted to do so by law or by regulatory bodies such as where there is a court order, statutory obligation or Financial Conduct Authority.
How Long we keep your Personal Information For
At Veritas Registrars, we keep your personal information for as reasonably necessary to fulfil the relevant purposes set out in this Privacy Policy and in the order to comply with our legal and regulatory obligations. The duration we keep your personal information for is dependent on the purpose for which we collected the information in the first instance. In other cases, we do so in compliance with applicable laws and in a bid to establish, exercise or defend our legal rights.

Your Rights
You are at liberty to ask us to do various things with your personal information. For instance, you can request for a copy of your personal information, ask us to make modifications, change the way your personal information is used, or even delete your record. In such an instance, we will either do as you have asked or kindly explain why we cannot; usually because of a regulatory or legal issue.
You have the following rights in relation to our use of your personal information:
The right to transferability:
You have the right to ask us to transfer any personal information you have provided us with to another third party of your choice under certain circumstances.
Rights to limitation of data processing:
You are at liberty to ask us to stop using your personal information under certain circumstances, for example when you think that the personal information we currently hold about you may be inaccurate or where you think we no longer need to process your personal information.
Right to withdraw consent:
For certain uses of your personal information we will ask for your consent. In the event this happens, you have the right to withdraw your consent to further use your personal information. Please note in some cases we may not be able to process payments of your dividends if you withdraw your consent.
Right to access your personal information: You are entitled to a copy of the personal information we hold about you and certain details of how we use it. An electronic copy of your personal information will usually be provided for you, unless otherwise requested. In cases you want it to be couriered to you, we might charge you a reasonable fee to cover the cost.
Right to Deletion
You have the right to ask us to delete your personal information under certain circumstances. For example, where the personal information we collected is no longer necessary for the original purpose or the event you withdraw your consent. However, this will need to be balanced against other factors; for example, according to the type of personal information we hold about you and why we have collected it. There may be some legal and regulatory obligations which means we cannot comply with your request.
Our Contact Information
If you would like any more information about the way we use your information, or if you wish to exercise the rights listed above, please contact us using the details below:
The Data Protection Officer Veritas Registrars Limited Plot 89A, Ajose-Adeogun Street, Victoria Island, Lagos, Nigeria. Customer Care Lines: +234 1 2784167, +234 1 2784168 General Enquires: 234-2-2708930-4 Email: dataprivacy@veritasregistrars.com

You have the right to complain to the Information Regulator if you think that your information has been misused.
Contact details:
National Information Technology Development Agency
Tel: +234929220263, +2348168401851, +2347052420189
Website: www.nitda.gov.ng
Plot 89A, Ajose-Adeogun Street, Victoria Island Extension, Lagos