Privacy Policy

INTRODUCTION

FMDQ Privacy Policy (“Privacy Policy”) provides information on the collection, use, sharing and processing of personal information by FMDQ Securities Exchange PLC and its subsidiaries (“FMDQ”, “the Company” or “us”) when you use FMDQ websites, our services, download documents from us, subscribe for newsletters, interact with FMDQ during in-person meetings, at FMDQ sponsored events or events hosted at our premises, and in the context of other marketing and branding activities. This Privacy Policy also explains the choices you have in relation to these processing activities.

This Privacy Policy was last updated on April 15, 2019. However, the Privacy Policy may change over time, for example to comply with legal requirements or to meet changing business needs. The most up-to-date version can be found on this website. In case there is an important change that we want to highlight to you, we will also inform you in another appropriate way (for example via a pop-up notice or statement of changes on our website).

In this Privacy Policy, ‘personal information’ or ‘personal data’ means information that relates to an identified individual or to an identifiable individual. For example, this could include among other things your name, address, email address, business contact details, or information gathered through your interactions with us via our websites or at events. Personal information is also referred to as ‘information about you.’

WHO WE ARE

FMDQ is Nigeria’s foremost debt capital, foreign exchange and derivatives securities exchange located at Exchange Place, 35, Idowu Taylor Street, Victoria Island, Lagos, Nigeria. This website contains links to other sites that are not owned or controlled by FMDQ. FMDQ is not responsible for the privacy practices of non-FMDQ websites linked to the FMDQ site. We encourage you to read the privacy statements of other linked websites when you leave our website. This privacy statement applies only to information collected by this website.

WHO IS RESPONSIBLE FOR YOUR PERSONAL INFORMATION

FMDQ is your data controller and is responsible for processing your personal information described in this Privacy Policy. FMDQ uses the personally identifiable information you provide to communicate with you in response to your enquiries, to provide the services you request, and to manage your account. Any personally identifiable information gathered by FMDQ will be used for these purposes only. We will not disclose or divulge such data outside of FMDQ, other than to third party providers that assist us in providing the services. FMDQ does not share, sell, rent or trade personally identifiable information with third parties for their promotional purposes.

WHAT PERSONAL INFORMATION DO WE COLLECT

The types of personal information that we process will depend on the service you receive from us. FMDQ uses the personally identifiable information you provide to communicate with you in response to your enquiries, to provide the services you request, and to manage your account. The types of personal information which FMDQ may collect and process are:

  • Black Square Name, contact address, email addresses, and telephone numbers
  • Black Square Demographic attributes, when tied to personal information that identifies you
  • Black Square Employer, corporate contact details, job title
  • Black Square Transactional data, including financial details, your photograph
  • Black Square Career history, professional background and other CV related information
  • Black Square National passport, driving license or any other form of proof of identification
  • Black Square Data from surveys and publicly available information, such as social media posts
  • Black Square Unique IDs such as your mobile device identifier or cookie ID on your browser
  • Black Square IP address and information that may be derived from IP address, such as geographic location
  • Black Square Information about a device you use, such as browser, device type, operating system

The Company will only collect information that is necessary for the provision of its service(s) that you have requested.

HOW WE COLLECT PERSONAL INFORMATION

We collect information about you and any other party whose details you provide to us when you:

  • Black Square Register to use our websites and portals
  • Black Square Complete online forms
  • Black Square Take part in surveys
  • Black Square Interact with us using our social media platforms
  • Black Square Download information such as publications or participate in any other interactive areas that appear on our website or portals
  • Black Square Contact us offline, for example by telephone, SMS, email, post or any other means of communication
  • Black Square Access and use any of our websites or portals from your devices (including mobile devices) and applications
  • Black Square Share information with third parties that are entitled to share that information, but in each case as permitted by applicable laws

WHY AND HOW DO WE USE YOUR PERSONAL INFORMATION

All personal information which we collect, and process is justified by lawful processing on the basis that:

  • Black Square You have given consent to the processing
  • Black Square Processing is necessary for the performance of a contract to which you are a party or take steps to enter into a contract
  • Black Square Processing is necessary for compliance with a legal obligation to which we are subject
  • Black Square Processing is necessary in order to protect your vital interests or another natural person
  • Black Square Processing is necessary for the performance of a task carried out in the public interest

 

We may use personal information for the following purposes:

  • Black Square To communicate and respond to your requests and enquiries about FMDQ – If you get in touch with us (such as by completing the registration form on our website, sending an email or by visiting the social media platforms), we process information about you to communicate with you and to respond to your requests or other enquiries. Based upon the personally identifiable information you provide us, we may send you a welcoming email to verify your username and password. Also, in response to your enquiries, FMDQ may communicate with you by email or telephone

 

  • Black Square To administer subscriptions of periodic newsletters – The Company may use a third party to create and distribute various newsletters via e-mail. The third party will collect your name and e-mail address when you click through to their site and sign up for the newsletter. Please review their privacy policy to determine how your information will be used

 

  • Black Square To deliver technical and functional management on our sites  – When you choose to register with us (such as to make use of our market data), we need to process the personal information provided by you so that we can create and manage a personal account for you. Upon creating your account, we will send you your personal login information. This personal information enables us to administer your account, for example by changing your password for you

 

  • Black Square To market our services or related services, and to tailor our marketing and brand activities to you or your company’s interests – FMDQ may use information about you to notify you (email or telephone) about new products and services, updates and associated campaigns and promotions (including via newsletters)

 

  • Black Square To provide specific services in accordance with an agreement you are entering, or have entered into with usIf you subscribe to our services (for instance, e-Markets subscription) , you provide services to us, our employees, or as a supplier or business partner, we process information about you to engage in, provide such services, and administer the relevant transactions. For instance, if you register as a Member, we will use the information to onboard you as a client and to carry out background and screening checks

 

  • Black Square To analyse, develop, improve and optimise the use, function and performance of our sites and products and servicesWe may process personal information in order to analyse, develop, improve and optimise the use, function and performance of our sites and products, as well as marketing campaigns. In case the sites permit you to participate in interactive discussions, create a profile, post comments, opportunities or other content, or communicate directly with another user or otherwise engage in networking activities, FMDQ may process personal information when moderating these activities

 

  • Black Square To manage the security of our sites, networks and systemsWe may collect site use data for security and operations management to help keep our sites, networks and systems secure, or to investigate and prevent potential fraud, including ad fraud and cyber-attacks and to detect bots

 

  • Black Square To comply with applicable laws and regulations and to operate our business In some cases, we have to process personal information to comply with applicable laws and regulations. For example, to respond to a request from a regulator or to defend a legal claim. We may also process personal information in the performance and operation of our business, such as to conduct internal audits and investigations or for finance and accounting, archiving and insurance purposes

 

  • Black Square To arrange events hosted at our premises whether you are either an organiser or an attendee and to control access to our premises

DATA ANALYTICS

We may use data analytics tools to analyse the information generated and stored during your use of our services to improve our services, provide content tailored to your personal preferences, and to monitor our website’s traffic and usage. The other purposes include:

  • Black Square Develop and provide new and existing functionality and services
  • Black Square Determine your general location to evaluate how our known clients engage with different parts of our website

All these tools may be provided by third-party service providers and may include the collection and tracking of certain data and information regarding the characteristics and activities of visitors to our website. We may disclose data, including personal information, to such third-party services providers in order to obtain such services.

You have the right to object to processing based on our legitimate activities but if you object, this may affect our ability to provide certain services and/or solutions for your benefit.

WHO WE SHARE YOUR PERSONAL DATA WITH

Your personal data may be stored in a database that we, as well as other subsidiaries of FMDQ, can access in order to provide you with our services. We may also share your data with third parties (data controllers) who provide data storage facilities to us. The other categories of third parties, in accordance with this Privacy Policy, we may share your information with are:

  • Black Square Service providers (for example, IT services) or third parties which process information on our behalf (e.g. internet service and platform providers, payment processing providers and those organisations we engage to help us send communications to you) so that they may help us to provide you with the applications, services and information you have requested or which we believe is of interest to you
  • Black Square Analytics and search engine providers that assist us in the improvement and optimisation of our website
  • Black Square Law enforcement or regulatory agencies, or authorised third parties, in response to a verified request relating to a criminal investigation or alleged illegal activity or any other activity that may expose us and/or the user or any third party to legal risks or liability
  • Black Square Third parties where you have a relationship with that third party, and you have consented to us sending information (for example social media sites or other third party application providers)
  • Black Square National Information Technology Development Agency (NITDA) professional advisors and auditors for the purpose of seeking professional advice or to meet our audit responsibilities
  • Black Square Agencies where reporting is mandatory under applicable laws

We may share non-personally identifiable information (e.g. the pages you visit, and which links you click, which ads you see and click on, and the categories of search terms you enter) about the use of our website or portal publicly or with third parties but this will not include information that can be used to identify you.

WHAT ARE YOUR RIGHTS

In accordance with the Regulation, you may have the following rights in respect of your personal information:

  • Black Square Right to access and/or have your information provided to you – You have the right to obtain a copy of your personal information and be told how we use your information
  • Black Square Right to rectify, erase or place restrictions on processing of your information – You have the right to rectify inaccurate personal information (including the right to have incomplete personal information completed), erase your personal information (in limited circumstances, where it is no longer necessary in relation to the purposes for which it was collected or processed), restrict processing of your personal information (e.g. where the processing is based on our legitimate interests)
  • Black Square Right to transfer to information to another organisation – You have the right to have any information you provided to us on an automated basis returned to you in a structured, commonly used and machine-readable format, or sent directly to another organisation, where technically feasible
  • Black Square Opt-out of our use of your personal information – You may withdraw consent you have previously provided for the processing of information about you subject to legal or contractual restrictions
  • Black Square Opt-out of our processing of your personal information – You may have the right to object to any decisions based on the automated processing of your personal data, including profiling
  • Black Square Right to lodge a complaint – You have the right to lodge a complaint with the supervisory authority responsible for data protection matters. In Nigeria, NITDA is the authority responsible for data protection

RETENTION OF YOUR PERSONAL INFORMATION

We maintain personal information not longer than we need to use it in accordance with this Privacy Policy. In some circumstances, we may retain your personal information for longer periods if it is in accordance with regulatory, legal, tax or accounting obligations. The Company has an established retention procedure it applies to records and information collected and stored. In all cases, where your information is no longer required or you request for deletion, we will ensure it is disposed of in a secure manner.

HOW IS YOUR PERSONAL INFORMATION SECURED?

The security of your personal information is important to us. FMDQ therefore takes reasonable precautions to protect your personal information. We generally follow accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure. However, FMDQ has implemented appropriate technical, physical and organisational measures designed to protect personal information against accidental or unlawful destruction, accidental loss, damage, alteration, unauthorised disclosure or access, as well as all other forms of unlawful processing.

WHAT COOKIES AND SIMILAR TECHNOLOGIES DO WE USE ON OUR SITES?

This privacy statement covers the use of cookies on the website and does not cover the use of cookies by advertisers. FMDQ’s third party partners who provide certain features on the website or display advertising based upon your web browsing activity may use flash cookies to collect and store information. In an effort to provide users with the most relevant website content, FMDQ may also use embedded pixel technologies to help track site usage. These technologies are used on selected pages for the purposes of identifying unique user visits as opposed to aggregate hits. The site usage information collected by these technologies is associated with cookies and may provide data about site use by registered users of the website. This information is used to evaluate site content, navigability, and composition, as well as page response rates. Any data linking the information gathered by clear gifs (tiny graphics with a unique identifier, similar in function to cookies) to a user’s personally identifiable information is used for internal tracking purposes only. FMDQ will not disclose or divulge such data linkages outside of FMDQ. When to use cookies, how you can manage your cookies and details about your consent are provided below.

 

WHEN DO WE USE COOKIES AND SIMILAR TECHNOLOGIES?

Cookies are small text files that contain a string of characters and uniquely identify a browser on a device connected to the internet. Any browser visiting our sites will receive cookies from us. We use cookies and other technologies on our sites to ensure the best possible and secure experience on our sites and to provide you with tailored information on products and brands. FMDQ also uses cookies or similar technologies on its sites to collect online information such as your mobile device ID, IP address, and other information about your device, as well as behavioral data of your device usage on our sites (e.g. pages viewed, links clicked, documents downloaded).

 

HOW CAN I MANAGE MY COOKIE PREFERENCES?

By continuing to use our website, you are agreeing that we may place cookies on your computer in order to analyse the way you use our website. If you are a visitor or our sites, you can use our cookie preferences tool to opt out of cookies.

However, if you do not wish to accept cookies in connection with your use of this website, you must stop using our sites or use your browser settings to block the placing of cookies. If you wish to withdraw your consent at any time, you will need to delete your cookies using your internet browser settings. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies as soon as you visit our site. If you do not wish to receive cookies, you can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies.

DISPUTE RESOLUTION OR FILING A COMPLAINT

If you have any complaints regarding our compliance with this Privacy Policy, please contact us first. We will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information within thirty (30) days in accordance with this Privacy Policy and in accordance with applicable law and regulation.

CHANGES IN THIS PRIVACY STATEMENT

If we decide to change our Privacy Policy, we will post those changes to this privacy statement, the homepage, and other places we deem appropriate so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. We reserve the right to modify this privacy statement at any time, so please review it frequently. If we make material changes to this policy, we will notify you here or by means of a notice on our homepage.

COMPLIANCE WITH THE REGULATORS

This Private Policy is in line with the provisions of Nigeria Data Protection Regulation, 2019 (Regulation). This Regulation describes how organisations including FMDQ must collect, handle and store personal information and applies regardless of whether data is stored electronically, on paper or on other materials.

 

CONTACT US

If you have any questions or suggestions regarding our privacy policy, please contact us by email privacypolicy@fmdqgroup.com.