You have complete control over your personal information. In general, you can visit our web site without providing us with any personal information. But, there are instances where we must have your personal information in order for us to grant you access to our protected and secured sites. This information may include registration data (your name, address, email address, phone number, title, etc.), information request data and response data (“User Information”). When you receive a confirmation email from us, or when you receive any newsletter email from our newsletter campaign list server, you will be given instructions on how to remove yourself from the newsletter list(s) whenever you want. Our automated system will then take care of everything for you, removing your email address (unsubscribing you) from any newsletter campaign list accordingly. If you wish us to remove all of your personal information from our database, please write to us at our address below. We may ask for identification from you before we delete any data. We may also for the purpose of order management, be unable to delete any purchase history of orders made by you from our website, as such data is held with our Merchant Account and Payment Gateway partners, and we need to retain certain information to be able to audit our order records etc.

We intend to use such information for the purposes of supporting you and if applicable, by designing website content that is suitable to your needs, and which alerts you to new product and service offerings as they become available. This User Information may be retained by Ficoven Investments Limited to verify compliance with the agreement between Ficoven Investments Limited and you, to keep track of the domains from which people visit us, to create a user profile to better serve you, or to simply contact you either electronically or otherwise. If you decide that we should not use your personal User Information to contact you, please let us know, and we will not use that information for such purposes. We do not intentionally collect User Information from juveniles (under 16 years of age), and where this is brought to our attention, we will ordinarily delete it. However, we appreciate that a young person between 16 and 18 years of age, may hold a bank account and debit card, which they may use with full authority on our website to make a purchase for one of our products/services. In such circumstances, we will collect User Information as the young person is a customer. We also do not collect personally identifiable information (PII) that relates to individual health, financial, sexual orientation, race or religious matters etc.

Ficoven Investments Limited does not sell, trade or transfer User Information to third parties. We do not store credit card details nor do we share customer details with any third parties. However, we may share User Information with our business partners for marketing, advertising or product/service offering purposes. For example, we provide User Information to our service providers for direct emailing of our newsletters, online surveys or notifications on Ficoven Investments Limited offerings, to our viewers. We also disclose User Information if: we have your consent; we need to share it in order to provide you with the products and/or services you requested; we respond to a court order, or you violate our Terms of Use. We may also use your User Information for the purpose of conducting credit reference checks, either consumer or business. Ficoven Investments limited is licensed by Nigeria Communications Commission and adheres to the RTS Regulation 2011.

The Nigerian Communications Commission RTS Regulation 2011: The Nigerian Communications Commission is charged with oversight functions on the telecommunications industry. In line with this duty, it issued the Registration of Telephone Subscribers Regulation (RTS Regulation) in 2011.

The Regulation is about the protection of the data collected, collated, retained, and managed by telecommunication companies operating in Nigeria and independent registration agents in view of their obligations to collate and retain data of subscribers under the Regulation.

For the purpose above, section 11 of the RTS Regulation 2011, titled “Data Protection”, states as follows:

“(1) in furtherance of the rights guaranteed by virtue of section 37 of the Constitution of the Federal Republic of Nigeria 1999 and subject to any reasonable guidelines, terms and conditions that may from time to time be issued by either the Commission or License, any Subscriber whose Personal Information is stored in the Central Database, shall be entitled to view the said information and to request updates and amendments thereto[5].

(2) The Subscriber information contained in the Central Database shall be held on a strictly confidential basis and no persons or entities shall be allowed access to any Subscriber information in the Central Database, except as provided in paragraph 1 above and in paragraph 5 of section 10 of these regulations or by any Act of the National Assembly[6]. Licensees, Independent Registration Agents, and Subscriber Registration Solution Providers shall not under any circumstance, retain, deal in or make copies of any Subscriber Information or store in whatever form any copies of the Subscriber Information for any purpose other than as stipulated in these Regulations or an Act of the National Assembly.

Further, section 11(4) of the Regulation states that licensees shall utilize personal information in accordance with the Regulations solely for their operations and in accordance with the provisions of Part V of the General Consumer Code Practice for Telecommunications Services and any other instruments of the Commission or any Act of the National Assembly issued from time to time to regulate the specific purposes for which the Personal Information may be used[7]. Section 11(7) then provides a blanket rule that the subscribers’ information shall not be transferred outside the Federal Republic of Nigeria, unlike the requirement under the NITDA Guidelines.

The General Consumer Code Practice for Telecommunications Services referred to above in the RTS Regulation 2011 also set out certain data protection mechanism for consumers of telecommunication services in Nigeria.

Specifically, section 35 of the General Consumer Code Practice for Telecommunications Services provides that a licensee may collect and maintain information on individual consumers reasonably required for its business purposes.

But such collection and maintenance of information on individual consumers shall be-

Fairly and lawfully collected and processed;

Processed for limited and identified purposes;

Relevant and not excessive;

Accurate;

Not kept longer than necessary;

Processed in accordance with the Consumer’s other rights;

Protected against improper or accidental disclosure; and

Not transferred to any party except as permitted by any terms and conditions agreed with the Consumer, as permitted by any permission or approval of the Commission, or as otherwise permitted or required by other applicable laws or regulations.

A licensee is required under section 35(2) of the Code to meet generally accepted fair information principles including:

Providing notice as to that individual consumer information they collect and its use or disclosure;

The choices consumers have with regard to the collection, use and, disclosure of that information;

The access consumers have to that information, including to ensure its accuracy; and

The security measures taken to protect the information and the enforcement and redress mechanisms that are in place to remedy any failure to observe these measures.

You may separately agree to provide your personal information to third parties that provide content for Ficoven Investments Limited offerings, in order to access and/or use their products and/or services. If you agree to provide such information to these third parties, then your personal information will be subject to their privacy policies.

The accuracy and security of User Information is important to Ficoven Investments Limited . Currently, you may review and request updates to your User Information retained by contacting Ficoven Investments Limited , either via the website where you can update your personal information by login, or by writing to us. If you contact us to correct your User Information, we will attempt to correct such inaccuracies in a timely manner. We reserve the right to request identification from you when you request a change in the personal data we may hold about you; we do this to protect your privacy and identity. Ficoven Investments Limited is concerned with the security of your User Information and is committed to taking more than reasonable steps to protect it from unauthorised access and use of that personal information. To that end, we put in place the appropriate physical, electronic and managerial policies and procedures to secure your personal User Information and these include but are not limited to, firewalls, intrusion monitoring and passwords to protect electronic information. Multiple physical security systems are in use at our commercial premises and include Access Control Systems, Intruder Detection Systems, CCTV Video Systems, Fire Detection Systems and high security perimeter fencing – all of which is monitored. Furthermore, access to personally identifiable information is limited to a small number of vetted personnel and on a need-to-know basis. We also continue to implement procedures to maintain accurate, complete and current User Information.

Access to certain content on our web site may be allowed under a written agreement between you and Ficoven Investments Limited and will require a username and/or password. In some cases, failure to provide personal information may prevent you from accessing certain Ficoven Investments Limited web site(s) containing certain confidential information, products, services, or promotional offers (“Ficoven Investments Limited Offerings”). By accessing and using our protected and secured web site(s), you agree to maintain the confidentiality of the username and password you selected to access such site(s) and consent to our Terms of Use.

Ficoven Investments Limited uses “cookies” and you can view our Cookie Policy for more information. A cookie is a small data file that a web site can transfer to a visitor’s hard drive to keep records of the visits to such web site(s). A cookie contains information such as your username and password that helps us recognise the pages you have visited and improve future visits, but the only personal information a cookie can contain is the information that you provide yourself. A cookie cannot read data off of your hard drive or read cookie files created by other sites. Information stored in cookies may be encrypted, however, we do not store your credit card number in cookies. If you prefer not to accept a cookie, you can set your web browser (Microsoft Internet Explorer, Apple Safari, Mozilla Firefox) to warn you before accepting cookies or you can refuse all cookies by turning them off in your web browser. However, access to some of our website pages are secure (shopping payment form etc) and will require the use of cookies, which you must enable, to ensure that our system cookies that get sent back to the originating server, will work correctly. However, you can still access most of the features on our website without accepting a cookie.

Ficoven Investments Limited  web site may provide links to other third party web sites. Even if the third party is affiliated with Ficoven Investments Limited through a business partnership or otherwise, Ficoven Investments Limited is not responsible for the privacy policies or practices or the content of such external links. These links are provided to you for convenience purposes only and you access them at your own risk.

Please also see our Terms of Use, which describes the restrictions, disclaimers, indemnification and limitation of liability governing the use of the entire Ficoven Investments Limited.

Based on the information a user has provided, Ficoven Investments Limited may send email correspondence to the user. Each correspondence will contain an easy means to opt out of further correspondence.

If you have questions regarding our Privacy Statement, please contact Ficoven Investments Limited via our Contact Page or if you prefer you can write to us at the following address: Ficoven Investments Limited, 1 Nwadiolu Street Aboru. Ipaja Lagos State, Nigeria.

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