Privacy Policy

1. Preamble

Bottom line up front: GETEQUITY LIMITED respects your privacy and is committed to protecting your data.

2. Introduction

This Data Privacy and Protection Policy (the “Privacy Policy”) describes your privacy rights regarding GETEQUITY LIMITED’s (“we”, “us” or “our”) collection, use, storage, sharing and protection of your use personal data and other types of information we collect from you (“Personal Information”) when you participate in our digital asset offering, (meaning the issue of tokens representing underlying securities/shares/stocks or any other type of financial or non-financial assets) or visit and/or use services (“Services”). A digital assets offering is also referred further referred to in this Policy as an offering.

This Policy does not apply to the practices of companies not owned or controlled by us or to people who we do not employ or manage.This Privacy Policy is provided to help you understand what information we collect from you, how the information collected is used, how we protect it, and your rights to it, amongst others.

This Privacy Policy is strictly restricted to only our Services and therefore does not apply to services that are not owned or controlled by us, including third-party websites. We are committed to handling all personal data provided to us in compliance with both applicable and model data privacy and protection laws.

3. Consent

To use our Services in any manner, you indicate to us that you have read and accept this Privacy Policy and consent to the data practices described in this Privacy Policy. If you do not accept this Privacy Policy and do not meet or comply with the provisions set forth herein, then you may not use our Services

4. The Information We Collect

  • 1. Personal Information

    As part of our operations, we collect and processes certain types of information (such as name, telephone numbers, address etc.) of individuals that makes them easily identifiable. These individuals include current, past and prospective employees, merchants, suppliers/vendors, customers of merchants, registered users (“Users”) and other individuals whom we communicate or deals with, jointly and/or severally (“Data Subject(s)”).

    To use our Services, you will voluntarily provide us with certain Personal Information. Personal Information refers to information relating to an identified person or information that can be used to identify you, (e.g. email address, bank details, name, telephone number). It may also include anonymous information that may be linked to you specifically, (e.g. IP address).

    We specifically disclose your data to the offering organizers and their agents who use our portal in order for you to have the opportunity to participate in the offerings or for administering the corresponding digital asset or token after its initial issuance. In addition, unless specifically described below, consent may be obtained in any legally sufficient method.

    We use your Personal Information to:

    • a. provide you with the required Services
    • b. respond to your questions or requests
    • c. improve features, website content and analyse data to develop products and services
    • d. address inappropriate use of our Services
    • e. prevent, detect and manage risk against fraud and illegal activities using internal and third party screening tools
    • f. send you marketing content, newsletters and service updates curated by us, however, we will provide you with an option to unsubscribe if you do not want to hear from us
    • g. verify your identity and the information you provide in line with our statutory obligations using internal and third party tools
    • h. maintain up-to-date records
    • i. resolve disputes that may arise, including investigations by law enforcement or regulatory bodies
    • j. any other purpose that we disclose to you in the course of providing our Services to you
  • 2. Financial Data

    When you subscribe to purchase tokens from an offering that uses our platform, you will be asked to provide financial data and information to verify your status and successfully make financial transactions. Depending on how you wish to purchase tokens you may be required to provide financial data, such as your bank routing number and bank account number, to enable the offering company to utilize your bank account to originate funds transfers and make subsequent investment transfers to you if necessary.

  • 3. Information that we collect from website visitors

    We do not collect your Personal Information when you visit the website. However, so we can monitor and improve our website and Services we may collect nonpersonally-identifiable information. We will not share or disclose this information with third parties except as a necessary part of providing our Services. We may, where applicable, use the information to target advertisements to you.

  • 4. Purpose Limitation

    We collect Personal Information only for identified purposes and for which consent has been obtained. Such Personal Information cannot be reused for another purpose that is incompatible with the original purpose, except consent is obtained for such purpose

  • 5. Data Minimization

    We limit Personal Information collection and usage to data that is relevant, adequate, and absolutely necessary for carrying out the purpose for which the data is processed. We will evaluate whether and to what extent the processing of Personal Information is necessary and where the purpose allows, anonymized data will be used.

  • 6. Cookies

    We use cookies to identify you as a User and make your user experience easier, customise our Services, content and advertising and where applicable help you ensure that your account security is not compromised. We also use cookies to mitigate risk and prevent fraud and promote trust and safety on our website. Cookies allow our servers to remember IP addresses, date and time of visits, monitor web traffic and prevent fraudulent activities.

    Our cookies never store personal or sensitive information. They simply hold a unique random reference to you so that once you visit our website, we can recognize who you are and provide certain content to you. If your browser or browser add-on permits, you have the choice to disable cookies on our website, however this may impact your experience using our website.

5. How We Protect Your Information

We shall establish adequate controls in order to protect the integrity and confidentiality of your Personal Information, both in digital and physical format and to prevent your Personal Information from being accidentally or deliberately compromised.

We are committed to managing your Personal Information in line with global industry best practices. We protect your Personal Information using physical, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure and alteration, we also use industry recommended security protocols to safeguard your Personal Information. Other security safeguards include but are not limited to data encryption, firewalls, and physical access controls to our building and files and only granting access to your Personal Information to only employees who require it to fulfil their job responsibilities. No Personal Information processing will be undertaken by an employee who has not been authorized to carry such out as part of their legitimate duties.

Employees may have access to your Personal Information only as is appropriate for the type and scope of the task in question and are forbidden to use your Personal Information for their own private or commercial purposes or to disclose them to unauthorized persons, or to make them available in any other way.

6. How We Share the Personal Information You Provide

In order to participate in an offering, you will have to provide Personal Information to pass Know Your Customer (KYC) and Anti-Money Laundering (AML) verifications as required by law. We provide this data to third-party companies designated by the digital asset issuer as their agent(s) to verify all KYC/AML information and/or more broadly to administer the digital asset during its existence. When you participate in a company’s offering your Personal Information including personal data is shared with the offering company or its designated agent. Be aware that when you participate in an offering, the offering company may use a different KYC/AML service than the we use. We may also provide your anonymized data to the company analytics solutions in order to do analytics to better operate our company for our users.

We do not sell, trade or rent personal information to anyone. However, to enable us render our Services to you on our website, we may share your information with trusted third parties, such third parties include financial institutions, payment processors verification services, sanctions screening and identity verification services as well as any third parties that you have directly authorized to receive your Personal Information. Your Personal Information may be stored in locations outside our direct control, for instance, on servers or databases co-located with hosting providers.

We may disclose your Personal Information in compliance with applicable law or a legal obligation to which we are bound. Please note that third-party sites you engage with through our Services will have their privacy policies, and we are therefore not responsible for their actions, including their information protection practices. The use of your information by such third party will be subject to their applicable privacy policy, which you should carefully review.

7. Transfer of Personal Information

  • 1. Third Party Processor within Nigeria

    We may engage the services of third parties in order to process the Personal Information of Data Subjects we collect. The processing by such third parties shall be governed by a written contract with us to ensure adequate protection and security measures are put in place by the third party for the protection of Personal Information in accordance with the terms of this Privacy Policy.

  • 2. Transfer of Personal Information to Foreign Country

    Where Personal Information is to be transferred to a country outside Nigeria, we shall put adequate measures in place to ensure the security of such Personal Information. In particular, we shall, among other things, confirm whether the country is on the National Information Technology Development Agency (“NITDA”) White List of Countries with adequate data protection laws.

    Transfer of Personal Information out of Nigeria would be in accordance with the provisions of the Nigeria Data Protection Regulation ("NDPR”). We will therefore only transfer Personal Information out of Nigeria on one of the following conditions:

    • a. the consent of the Data Subject has been obtained;
    • b. the transfer is necessary for the performance of a contract between us and the Data Subject or implementation of pre-contractual measures taken at the Data Subject’s request;
    • c. the transfer is necessary to conclude a contract between us and a third party in the interest of the Data Subject;
    • d. the transfer is necessary for reason of public interest;
    • e. the transfer is for the establishment, exercise or defense of legal claims;
    • f. the transfer is necessary in order to protect the vital interests of the Data Subjects or other persons, wwhere the Data Subject is physically or legally incapable of giving consent

    We will take all necessary steps to ensure that your Personal Information is transmitted in a safe and secure manner. Details of the protection given when your Personal Information is transferred outside Nigeria shall be provided to you upon request.

8. Ground for Processing of Personal Information

Our processing of Personal Information shall be lawful if at least one of the following applies:

  • a. the Data Subject has given consent to the processing of his/her Personal Information for one or more specific purposes;
  • b. the processing is necessary for the performance of a contract to which the Data Subject is party or in order to take steps at the request of the Data Subject prior to entering into a contract;
  • c. processing is necessary for compliance with a legal obligation to which we are a subject;
  • d. processing is necessary in order to protect the vital interests of the Data Subject or of another natural person; and
  • e. processing is necessary for the performance of a task carried out in the public interest or in exercise of official public mandate vested in us.

For the purpose of this Privacy Policy, consent means any freely given, specific, informed and unambiguous indication of the Data Subject's wishes by which they, through a statement or a clear affirmative action, signify their agreement to the processing of Personal Information relating to them.

9. The Data that We Retain

We will retain your Personal Information for as long as is needed to provide our Services to you, comply with our legal and statutory obligations or verify your information with the required verification authorities.

We are statutorily obligated to retain the Personal Information and data you provide us with in order to process transactions, ensure settlements, make refunds, identify fraud, holistically carry out our Services and in compliance with laws and regulatory guidelines applicable to us and our service partners.Therefore, even after discontinuance of our Services, we will retain certain Personal Information and transaction data to comply with these obligations. All Personal Information shall be destroyed by us where possible. For all Personal Information and records obtained, used and stored by us, we shall perform periodical reviews of the data retained to confirm the accuracy, purpose, validity and requirement to retain

The length of storage of your Personal Informaiton shall, amongst other things, be determined by:

  • a. the contract terms agreed between us and the Data Subject or as long as it is needed for the purpose for which it was obtained; or
  • b. whether the transaction or relationship has statutory implication or a required retention period; or
  • c. whether there is an express request for deletion of the Personal Information by the Data Subject, provided that such request will only be treated where the Data Subject is not under any investigation which may require us to retain such Personal Information or there is no subsisting contractual arrangement with the Data Subject that would require the processing of the Personal Information; or
  • d. whether we have another lawful basis for retaining that information beyond the period for which it is necessary to serve the original purpose

10. Choices and Rights

Once your Personal Information is held by us, you are entitled to reach out to us to exercise the following rights:

  • right to request for and access your Personal Information collected and stored. Where data is held electronically in a structured form, such as in a Database, as the Data Subject, you have a right to receive that data in a common electronic format;
  • b. right to information on your Personal Information collected and stored;
  • c. right to objection or request for restriction;
  • d. right to object to automated decision making;
  • e. right to request rectification and modification of your Personal Information which we keep;
  • f. right to request for the deletion of your data;
  • g. right to request the movement of your data from us to a third party; this is the right to the portability of data; and
  • h. right to object to, and to request that we restrict the processing of your Personal Information

Your request will be reviewed by us and carried out except as restricted by law or our statutory obligations. You may decline to provide your Personal Information when it is requested by us, however, certain Services or all the Services may be unavailable to you. You may review and update your Personal Information directly or by contacting us.

11. Age Restriction

Our Services are not directed to children under 18. We do not knowingly collect information from children under 18. If as a parent or guardian, you become aware that your child or ward child has provided us with any information without your consent, please contact us through the details provided in this Privacy Policy

12. Compliance with Local and International Regulatory Best Practices

We confirm that we comply with the NDPR on data collection, transmission, usage and protection. We also, for best practices, adopt pertinent best practices per the General Data Protection Regulation (2016/679) (GDPR) to the extent that they do not conflict with Nigerian data protection regulations and laws.

13. Updates, Modifications and Amendments

We reserve the right to update, modify, change or revise this Privacy Policy from time to time. The changes will not be retroactive, and the most current version of this Privacy Policy which will always be on this page and will continue to govern our relationship with you. We advise that you check this page often, referring to the date of the last modification on the page. We will also try to notify you of any material changes which could be done via email associated with your account or service notification. By continuing to use our Services after the changes become effective, you agree to be bound by the revised Privacy Policy.

14. Contact Us

You may contact us upon becoming aware of any breach of Personal Information or if your access to our Services have been compromised, to enable us to take the necessary 8 steps towards ensuring the security of your Personal Information. You may also contact us if you have any questions relating to this Privacy Policy or would like to find out more about exercising your data protection rights. All questions and inquiries may be sent to [email protected] .