Privacy Policy

1.0 Your Privacy Rights

1. Introduction/Scope

This document is prepared in accordance with the provisions of the Nigeria Data Protection Act 2023 (NDPA). It sets out how Gbowy Capital and Investment Services Limited applies and complies with the data privacy principles in processing the personal data of customers, staff, vendors, visitors, and even third parties that interact with us. For personal data of individuals, this document also highlights their rights and covers the data subject(s) whose personal data is collected and processed, in compliance with the NDPA. This privacy policy describes why and how we collect and use personal information about our customers, clients, vendors, and visitors (data subjects). It also highlights with whom we might share Personal Information and how long we keep such information. It also makes data subjects aware of their rights under the Nigeria Data Protection Act 2023.

2. Roles/Responsibilities

Gbowy Capital and Investment Services Limited Data Protection Officer (DPO) is responsible for ensuring that this document is correct and up-to-date. The DPO also ensures that data subjects are duly notified prior to the collection and processing of their personal data, including data collected via the Gbowy Capital and Investment Services Limited’s website. All Gbowy Capital and Investment Services Limited employees/staff who interact with personal data must also ensure to follow the provisions in this policy document.

3. Policy Statement

Gbowy Capital and Investment Services Limited is committed to protecting the privacy and security of data subjects’ personal data. We are responsible for determining how we hold and use personal information about our data subjects. According to the Nigeria Data Protection Act (NDPA), Gbowy Capital and Investment Services Limited is required to notify data subjects of the information contained in this document.

3.1 About Gbowy Capital and Investment Services Limited

Gbowy Capital and Investment Services Limited is incorporated under the laws of the Federal Republic of Nigeria, with our registered office at Plot 35b, Wealth Estate, Sabon Lugbe East Extension, Layout, Abuja, Fct. We provide adapted retail financial services to individuals and salary earners in Nigeria. Gbowy Capital and Investment Services Limited is a reputable technology-driven financial institution that is recognized for innovation, superior performance, and creation of premium value for all stakeholders. With branches and business offices scattered across prime commercial centres in Nigeria, Gbowy Capital and Investment Services Limited is considered a leader in the deployment of various channels of banking technology, driven by a culture of excellence and strict adherence to national and global best practices, combining vision, skilful banking expertise, and cutting-edge technology to create products and services that anticipate and meet customers’ expectations while enabling businesses to thrive and grow wealth for customers.

3.2 What Personal Data Do We Need?

The personal data we would collect and process, depending on the particular processing requirement, are under the following categories:

Data Type	Description of Data
Identity Data	Full Name, maiden name, marital status, title, NIN, date of birth, gender, address and employment history, and citizenship.
Contact Data	Address, Email Address and Telephone Numbers
Financial Data	Bank account information and bank statements, Bank verification Number (BVN), your income and outgoings, your financial position, status, and credit history, debit or credit card information and account number.
Transaction Data	Information regarding the products and services you may have benefited from by using Gbowy Capital and Investment Services Limited and any of its subsidiaries, transactional information including in respect of products which you purchase. Location data of transactions where you may use your debit card.
Technical Data	Internet protocol (IP) address, your login data, details of your browser and operating system, time zone setting and location, browser plug-in types and versions, platforms and other technology on the devices you use to access this website.
Profile Data	Includes your username and password.
Job Application Data	Data submitted throughout the recruitment process eg: name, email address. Any personal information you provide to Gbowy Capital and Investment Services Limited as part of the recruitment process.
Usage Data	Includes information about how you use our website, products and services.
Marketing and Communications Data	Information about your communications with us. Your preferences in receiving marketing e-mails from us and consents you have given us.

Where the personal data we need to collect may fall under a special category of sensitive personal data, the lawful basis of processing will be the explicit consent of the individual, or where applicable, compliance with a legal obligation, or for legal proceedings/advice.

4. Why We Need the Data

Gbowy Capital and Investment Services Limited ensures that the personal data collected and processed is necessary for the purpose of collection, and shall not collect or process more data than is reasonably required for a particular processing activity.

5. Legal Grounds for Processing

Gbowy Capital and Investment Services Limited identifies, establishes, defines, and documents the specific purpose of processing and the legal basis for processing personal data (including any special categories of personal data processed) before any processing operation takes place under:

• Consent obtained from the data subject;
• Performance of a contract where the data subject is a party;
• Legal obligation that we are required to meet;
• Protect the vital interests of the data subject, including the protection of rights and freedom of the Data Subject;
• Official authority to carry out the processing that is in the public interest;
• National law such as biometric data.

In addition, every processing purpose has at least one lawful basis for processing to safeguard the rights of the data subjects, as listed below:

Purpose of Processing	Lawful Basis of Processing
Account creation, identity verification and maintenance of records	Contract
Vendor validation/information processing	Contract
Employment	Contract

6. Processing of Personal Data Based on Consent

Where applicable, Gbowy Capital and Investment Services Limited will require the explicit consent of customers, visitors, and other relevant stakeholders to process collected personal data.

Website visitors are expected to read and understand the website privacy notice, and then agreeing to the website’s terms of use. And by consenting to the privacy policy, data subjects are giving Gbowy Capital and Investment Services Limited the permission to use/process their personal data specifically for the purpose identified before collection.

On this ground, if any data subject (customer, client, visitor, vendor, staff, or third party) does not agree to Gbowy Capital and Investment Services Limited collecting and processing their personal data, such individual is not allowed to enjoy service(s) where applicable.

If, for any reason, we are requesting sensitive personal data from its stakeholders (external and internal), the individuals will be rightly notified why and how the information will be used.

Where processing relates to a child under 18 years old, as in the case of NDPA Gbowy Capital and Investment Services Limited shall demonstrate that consent has been provided by the person who holds parental responsibility over the child. Gbowy Capital and Investment Services Limited shall demonstrate that reasonable efforts have been made to verify the age of the child and establish the authenticity of the parental responsibility taking into consideration available technology.

6.1 Withdrawal of Consent

Irrespective of initial consent given, an individual can withdraw their consent at any time by making a withdrawal of consent request.

Gbowy Capital and Investment Services Limited demonstrates the data subject (customer, client, visitor, vendor, staff, or third-party) has withdrawn consent to the processing of his or her personal data with a written instruction from the data subject.

For child consent, Gbowy Capital and Investment Services Limited shall demonstrate that the holder of parental responsibility over the specified child has withdrawn consent via a written instruction from the parent. We will also demonstrate that reasonable efforts have been made to establish the authenticity of the parental responsibility, when withdrawing consent for the specified child, considering available technology.

Where applicable, the Data Protection Officer will inform the relevant process owner of this change, and the processing activities that relied upon the consent is stopped immediately, in accordance with the relevant process.

7. Use of Cookies

The website uses cookies provided by trusted third parties, such as Google Analytics, to help us understand and improve users experience on the website.

Gbowy Capital and Investment Services Limited may use the information we obtain from your use of our cookies to:

• Recognize your computer when you visit our website,
• Track you as you navigate our website,
• Improve the website’s usability (including our Live Chat application to answer questions you have in real time),
• Analyze the use of our website - such as how many people visit us each day, and
• Manage the website.

Users can disable cookies and prevent the setting of cookies by adjusting the settings on their browser. However, this is not recommended, as disabling cookies may also disable certain functionality and features of the site.

8. Disclosure to Third-Parties

Asides situations where we may be required to disclose personal data of individuals in accordance to a legal obligation in response to requests by government authorities or law courts on matters involving national security or law enforcement requirements, Gbowy Capital and Investment Services Limited will not pass on its data subjects’ personal data to third parties without first obtaining consent.

In situations where the processing of personal data will involve investigation of potential violations of the Terms of Service, fraud prevention/mitigation, security issues management, and the preservation of the rights and freedom of staff, customers, and clients, we shall establish an appropriate legal ground for such data transfers.

Gbowy Capital and Investment Services Limited has put in place, to the best of its ability and in line with standard global practices, physical, technical, and organisational measures (including secure encryption and anonymisation) to ensure the optimum protection of personal data, which also extends to data transferred or shared with third-parties.

8.1 Cross-Border Transfers

Gbowy Capital and Investment Services Limited may also engage third parties abroad (such as banks, contractors, government-authorised agencies, etc.) that will receive personal data for certain purpose(s) as part of the Bank’s processing activities and process them on the Bank’s behalf. Where this is the case, we will enter into a Data Processing Agreement with the third party and also ask for your consent if the purpose of processing was not initially stated on inception and be satisfied that the third party has adequate measures in place to protect the data against accidental or unauthorised access, use, disclosure, loss, or destruction.

In such a case where the disclosure is to third parties outside the jurisdiction of the NDPA, Gbowy Capital and Investment Services Limited will ensure that the third party meets the core global regulatory standards prior to the transfer. This may include transferring the personal data to the third party where we are satisfied that:

• the country of the recipient has adequate data protection controls established by legal or self-regulatory regime. However, in a case not covered by an adequacy decision from the NDPC;
• It has a contract in place that uses existing data protection clauses with approval of NDPC to ensure adequate protection.
• It is making the transfer under approved binding corporate rules.
• Provisions inserted into administrative arrangements between public authorities or bodies authorised by the supervisory authority NDPC.

9. Retention of Records

Gbowy Capital and Investment Services Limited stores a broad spectrum of personal information, which indicates that retention periods differ with the type of data collected and stored. All information Gbowy Capital and Investment Services Limited holds is stored and retained, stored and destroyed in compliance with NDPA’s guideline on the retention of records and personal data.

Gbowy Capital and Investment Services Limited will retain your personal data as long as the information is active on our systems and necessary for service delivery purposes. This retention period is verified and established with special considerations to the following areas:

• Our requirements to onboard customers
• The type of personal data
• The purpose of processing
• Lawful basis for processing
• The categories of data subjects

Details of Personal Data Retention

Details of personal data retention periods for the different categories of personal data is captured in the Records of Processing Activities document (internal document).

This retention period is established to enable the use of personal data for the necessary legitimate purposes identified, in full compliance with the regulatory requirements. When the personal data is no longer needed or beyond the stipulated retention period, Gbowy Capital and Investment Services Limited will delete or destroy it from its systems and records, or take steps to securely archive it while protecting your identity and privacy rights as the case may be.

10. Data Subject Rights

At any point while Gbowy Capital and Investment Services Limited is in possession of or processing personal data, the data subject has the right to:

• Request a copy of the information that we hold about them
• Correct the data that is inaccurate or incomplete
• Ask for their data to be erased from our systems/records
• Restrict processing of their personal data where certain conditions apply
• Have their data transferred to another organisation
• Object to certain types of processing like direct marketing
• Object to automated processing like profiling, as well as the right to be subject to the legal effects of automated processing or profiling
• Complain and pursue judicial review in the event that we refuse their request under rights of access without a clear and justifiable reason as to why

All of the above requests will be forwarded on should there be a third party involved in the processing of your personal data.

11. Complaints

If for any reason a vendor/contractor, customer, or staff wishes to make a complaint about how Gbowy Capital and Investment Services Limited (or any of our third parties) handles or have handled their personal data, or how their complaint has been handled, they have the right to lodge a complaint directly with the supervisory authority and Gbowy Capital and Investment Services Limited Data Protection Officer.

Below are the details for each of these contacts:

Supervisory Authority
Email: dpo@ndpc.gov.ng

Data Protection Officer (DPO)
Email: info@gbowy.net