1. Introduction

Howdy! We created this privacy policy to explain how we collect, use, disclose and protect your information; including any nonpublic personal information.

This policy applies to information we collect when you use our website ("Services") or otherwise interact with us as described below. We may change this privacy policy from time to time. If we make changes, we will notify you by revising the date at the top of this policy, and in some cases, we may provide you with additional notice (such as by adding a statement to the homepages of our website or by sending you an email notification).

We encourage you to review the privacy policy whenever you interact with us to stay informed about our information practices and the ways you can help protect your privacy. This privacy policy applies to the Services provided by IWD (“we” or “us”).

2. Collection of Information

2.1 Categories of Non-public Personal Information

We collect nonpublic personal information you provide to us when you apply for a IWD account or when you communicate with us about your IWD account. The types of information we may collect include your name, address, phone number, email address, date of birth, bank account information, BVN, username, password, and next of kin details.

2.2 Information About Your Investments With Us

As you perform investment activity on IWD, some plans will require you to provide your nonpublic personal information in connection with each investment, including investment time, Naira amount and bank details. You will also provide photos, government recognized idenity and other information that you attach to your investment.

2.3 Other Information we collect

We may collect information you provide to us, such as your name, email address and any other information you choose to provide such as and not limited to age, gender, ethnic. For example, we may collect such information if you join our refferal program and looking to invite people to join IWD or if you enter into any contest or promotion.

2.5 Information We Collect Automatically from our Services

When you access or use our Services, we automatically collect information about you as follows:

  1. Log Information: We log information about your use of our Services, including the type of browser you use, access times, pages viewed, your IP address and the page you visited before navigating to our Services.
  2. Device Information: We collect information about the computer or mobile device you use to access our Services, including the hardware model, operating system and version, unique device identifiers and mobile network information.

2.6 Information We Do-Not-Collect using our Services

When you access or use our Services, we do not collect the below data manually or automatically:

  1. Cookies: We do not collect nor access your cookies. Cookies are your logs of your activities performed on a certain device and browser stored on your device memory.
  2. Exact Location: We do not collect your exact location or track your exact location using existing technologies. The only location data we have is the one provided by IP address.

3. Use of Information

We may use your information, including non-public personal information as follows:

IWD is based in Nigeria and the information we collect is governed by the Nigerian law. By accessing or using the Services or otherwise providing information to us, you consent to the processing and transfer of information in and to Nigeria and other countries.

4. Disclosure of Information

We may disclose any information we collect about current and former investors, including nonpublic personal information, to affiliates and non-affiliated third parties as follows:

  1. With financial service providers, including the financial institutions identified in your cardholder bank agreement that provide banking services in connection with your IWD account.
  2. With another user, when you sign up for IWD's services via a referral link. The user that referred you may receive information indicating that you have enrolled with IWD. You may avoid this sharing by not using a referral link to enroll.
  3. With non-financial companies, such as email service providers that perform marketing services on our behalf, and fraud prevention service providers that use the information to provide services to IWD and other companies.
  4. With a non-affiliated third-party to access and transmit your personal and financial information from a relevant financial institution. You grant the third-party the right, power, and authority to access and transmit this information. according to terms of their privacy policy.

With other non-affiliated companies for our everyday business purposes, such as to process transactions, maintain accounts, respond to court orders and legal investigations or report to credit bureaus. For example, in connection with our everyday business purposes, we may share information about you as follows:

  1. In response to a request for information, if we are required by, or we believe disclosure is in accordance with, any applicable law, regulation or legal process.
  2. With relevant law enforcement officials or other third parties, such as investigators or auditors, if we believe it is appropriate to investigate fraud.
  3. If we believe your actions are inconsistent with the spirit or language of our user agreements or policies, or to protect the rights, property and safety of IWD or others.
  4. In connection with, or during negotiations of, any merger, sale of IWD's assets, financing or acquisition of all or a portion of our business to another company; and
  5. With your consent or at your direction, including if we notify you that the information you provide will be shared in a particular manner and you provide such information.

We may also share aggregated or de-identified Information, which cannot reasonably be used to identify you.

We will usually not share your personal information with other third parties without your consent. Where we need to transfer your data to another country, we shall ensure that such country to which the data is being transferred shall have adequate data protection law. We will seek your consent where we need to send your data to a country without an adequate data protection law.

5. Your Choices

5.1 Account Information

You may edit your account profile information by logging into your account via our Services. If you wish to delete or deactivate your online account, please contact us, but note that we may retain certain information as required by law or for legitimate business purposes.

5.2 Promotional Communications

You may opt out of receiving promotional emails and text messages from IWD by following the instructions in those messages. Please note that if you opt out, we may still send you transactional or relationship messages, such as those about your account or our ongoing invesment(s) relations.

5.3 Location Information

We do not collect your exact location. We do not use google or any high end to determine or collect details about your location. We only process location decoded from your IP address.

5.4 Social Sharing Features

Our Services include social sharing features for common social networks to let users share content. These features are served from third-party services that may serve their own cookies. The use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the entity that provides the social sharing feature. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of the entities that provide these features.

5.5 Analytics and Advertising Services Provided by Others

We may allow others to provide analytics services on our behalf and to serve advertisements on our behalf across the Internet. These entities may use cookies, web beacons and other technologies to collect information about your use of the Services and other websites, including your IP address, web browser, pages viewed, time spent on pages, links clicked and conversion information. This information may be used by IWD and others, to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising targeted to your interests and better understand your online activity.

6. Your Rights

The law gives you certain rights in respect of the information we hold about you. Below is a highlight of some of those rights. It is not a complete, exhaustive statement of your rights in respect of your personal data:

  1. You have a right to consent to this Privacy Policy and to withdraw your consent at any time.
  2. You have a right to a copy of the personal data we hold about you, as well as the information about what we do with it, who we share it with and how long we hold it for. We may make a reasonable charge for additional copies of that data in the case of unfounded and excessive requests.
  3. You have a right to freely transfer your data received from us to any other person.
  4. You have the right to have the information we hold about you corrected, if it is factually inaccurate. You may contact us for this purpose.
  5. In some circumstances, you have the right to the deletion of the information that we hold about you.
  6. You have a right to lodge a complaint about the handling of your personal information with the National Information Technology Development Agency (NITDA).
  7. You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes.

NITDA’s website has a wealth of useful information in respect of your rights over your personal data.

If you wish to exercise your rights, you may write to us at [email protected]

7. Security

IWD takes reasonable measures to help protect all information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. Additionally, IWD implements policies designed to protect the confidentiality and security of your nonpublic personal information, including a privacy protection policy. IWD limits access to your nonpublic personal information to employees that have a business reason to know such information, and implement security practices and procedures designed to protect the confidentiality and security of such information and prohibit unlawful disclosure of such information in accordance with its policies.

Where you have chosen a password that allows you to access certain parts of the website and mobile application, you are responsible for keeping this password confidential. We advise you not to share your password with anyone. We have also taken measures to comply with provision of security facilities for the protection of your nonpublic personal information through the set up of firewalls, limited access to specified authorized individuals, encryption and continuous capacity building for relevant personnel. We therefore have digital and physical security measures to limit and eliminate possibilities of data privacy breach incidents.

Although we use appropriate security measures once we have received your personal information, the transmission of data over the internet (including by email) is never completely secure. We endeavour to protect personal information, but we cannot guarantee the security of data transmitted to us or by us. We will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Where we store your Data

The data that we collect from you will be transferred to and stored at a destination outside Nigeria. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.All information you provide to us is stored on our secure cloud storage solution.

Your personal information will not be retained for longer than is necessary for the purposes for which it was processed.

9. How long we keep your personal information

We will hold your personal information on IWD’s systems for as long as is necessary to fulfil the purpose for which it was collected or to comply with legal, regulatory or internal policy requirements.

Contact Us

If you have any questions about this Privacy Policy, please contact us at:

IWD Attention: Compliance Officer

IWD

Lagos,

Nigeria

[email protected]