DATA PRIVACY POLICY
- About this Policy
- This policy explains when and why we collect personal information about our shareholders, clients, investors and staff, how we use it and how we keep it secure and their rights in relation to it.
- We may collect, use and store your personal data, as described in this Data Privacy Policy and as described in the process of data collection.
- We reserve the right to amend this Data Privacy Policy from time to time without prior notice. We may be required to amend this Data Privacy Policy due to regulations. For any significant changes you will be notified but you are advised to check our website for the latest Privacy Policy.
- We will always comply with the Nigeria Data Protection Regulation (NDPR) when dealing with your personal data. For the purposes of the NDPR, we will be the “controller” of all personal data we hold about you.
- Who are we?
Sterling Asset Management & Trustees Limited is a leading asset management, and investment banking firm focused on providing financial advisory, capital raising and investment management services for private individuals, institutions, governments and government agencies.
We can be contacted at
7, Alfred Rewane Road, Ikoyi, Lagos.
Tel: 070012372685, 01-4537353
- What information we collect and why.
| Which information | What we do | Why we do it | Retention time How long do we keep your information |
| Name: Surname First Name Middle Name | Complete a task Provide a service | To comply with legal and regulatory obligations and requirements | For as long as it is necessary to comply with Sterling Asset Management & Trustees Limited obligations and statutory functions |
| Date of birth / age related information | Complete a task Provide a service | To comply with legal and regulatory obligations and requirements | For as long as it is necessary to comply with Sterling Asset Management & Trustees Limited obligations and statutory functions |
| Gender | Complete a task Provide a service | To comply with legal and regulatory obligations and requirements | For as long as it is necessary to comply with Sterling Asset Management & Trustees Limited obligations and statutory functions |
| Photo(s) and video(s) | Complete a task Provide a service | To comply with legal and regulatory obligations and requirements | For as long as it is necessary to comply with Sterling Asset Management & Trustees Limited obligations and statutory functions |
| Bank account detail(s) | Complete a task Provide a service | To comply with legal and regulatory obligations and requirements | For as long as it is necessary to comply with Sterling Asset Management & Trustees Limited obligations and statutory functions |
| Phone number(s) | Complete a task Provide a service | To comply with legal and regulatory obligations and requirements | For as long as it is necessary to comply with Sterling Asset Management & Trustees Limited obligations and statutory functions |
| Email address | Complete a task Provide a service | To comply with legal and regulatory obligations and requirements | For as long as it is necessary to comply with Sterling Asset Management & Trustees Limited obligations and statutory functions |
| National Health Insurance (NHIS) details | Complete a task Provide a service | To comply with legal and regulatory obligations and requirements | For as long as it is necessary to comply with Sterling Asset Management & Trustees Limited obligations and statutory functions |
| Academic qualification(s) details | Complete a task Provide a service | To comply with legal and regulatory obligations and requirements | For as long as it is necessary to comply with Sterling Asset Management & Trustees Limited obligations and statutory functions |
| Contractors and Service Providers details | Complete a task Provide a service | To comply with legal and regulatory obligations and requirements | For as long as it is necessary to comply with Sterling Asset Management & Trustees Limited obligations and statutory functions |
| Bank verification number (BVN) | Complete a task Provide a service | To comply with legal and regulatory obligations and requirements | For as long as it is necessary to comply with Sterling Asset Management & Trustees Limited obligations and statutory functions |
| Pension fund administrator (PFA) details | Complete a task Provide a service | To comply with legal and regulatory obligations and requirements | For as long as it is necessary to comply with Sterling Asset Management & Trustees Limited obligations and statutory functions |
| Employment details | Complete a task Provide a service | To comply with legal and regulatory obligations and requirements | For as long as it is necessary to comply with Sterling Asset Management & Trustees Limited obligations and statutory functions |
- How we
protect your personal data
- We will not transfer your personal data outside Nigeria without your consent.
- We have implemented generally accepted standards of technology and operational security in order to protect personal data from loss, misuse, or unauthorised alteration or destruction.
- Please note however that where you are transmitting information to us over the internet this can never be guaranteed to be 100% secure.
- For any payments which we take from you online we will use a recognised online secure payment system.
- We will notify you promptly in the event of any breach of your personal data which might expose you to serious risk.
- Who else has
access to the information you provide us?
- We will never sell your personal data. We will not share your personal data with any third parties without your prior consent (which you are free to withhold) except where required to do so by law.
- We may pass your personal data to third parties who are Service Providers, Agents and Subcontractors to us for the purposes of completing tasks and providing services to you on our behalf (e.g. to print newsletters and send you mailings). However, we disclose only the personal data that is necessary for the third party to deliver the service(s) and we have a contract in place that requires them to keep your information secure and not to use it for their own purposes.
- How long do we keep your information?
- We will hold your personal data on our Database Management System for as long as you are our client, service provider, corps member and staff for as long as is necessary to comply with our legal obligations. We will review your personal data yearly to establish whether we are still entitled to process it. If we decide that we are not entitled to do so, we will stop processing your personal data except that we will retain your personal data in an archived form in order to be able to comply with future legal obligations e.g. compliance with tax requirements and exemptions, and the establishment exercise or defense of legal claims.
- We securely destroy all financial information once we have used it and no longer need it.
- Your rights
- You have rights under the NDPR:
- to access your personal data
- to be provided with information about how your personal data is processed
- to have your personal data corrected
- to have your personal data erased in certain circumstances
- to object to or restrict how your personal data is processed
- to have your personal data transferred to yourself or to another
business in certain circumstances.
- You have the right to take any complaints about how we process your personal data to the National Information Technology Development Agency (NITDA):
- You have rights under the NDPR:
dpo@nitda.gov.ng
For more details, please address any questions, comments and requests regarding our data processing practices to our Data Protection Officer via dpo@samtlng.com