Custodian Investment Plc (the Group) is an investment company with major subsidiaries, including Custodian and Allied Insurance Limited, Custodian Life Assurance Limited, Custodian Trustees Limited, CrusaderSterling Pensions Limited, Interstate Securities Limited and UPDC Plc, each providing best-in-class services within their respective industries.
This privacy policy outlines how our Company (the Group, its subsidiaries, and associated companies) collects and uses personal data from data subjects.

In this privacy notice, references to:
“Data Subject” means the individual, employees or business customer, Visitors or partner (which includes suppliers or other organizations we do business with Company (either “the Company”, “We”, “Us” or “Our” in this Agreement) refers to Custodian investment Plc and its subsidiaries. Personal Information is any information that relates to an identified or identifiable individual.

For all intents and purposes, this policy applies to the following companies

• Custodian Investment Plc
• Custodian Life Assurance Limited
• Custodian and Allied Insurance Limited
• Custodian Trustees Limited
• CrusaderSterling Pensions Limited
• Interstate Securities Limited
• UPDC Plc

How do we collect your data?

You directly provide Our Company with most of the data we collect. We collect data and process data when you:

• Complete any of our physical or electronic forms in relation to any of our products or services. For example, completing a claims form or purchasing an insurance policy via our digital channels
• Voluntarily complete a customer survey or provide feedback on any of our online contact us forms or via email
• Use or view our website via your browser’s cookies
• Download and use our mobile app
• Use our USSD service
• Use our chatbot (Max)
• Use our interactive voice response (IVR) and/or contact centre service
• Interact with any of our agents and/or brokers

Our Company may also receive your data indirectly from the following sources:

• Nigerian Interbank Settlement Service (NIBSS) Application Programming Interfaces (APIs)
• Nigerian Insurance Industry Database (NIID) Application programming interfaces (APIs)
• Social media sites and apps
• Your email address

Information Collected

While using our Service, we may ask you to provide us with certain Personally Identifiable Information (PII) that can be used to contact or identify you. Personally Identifiable Information may include, but is not limited to, Information you give to us through our various touchpoints listed above.

• Information that we gather from publicly available sources, such as the press, company registers, and online search engines
• Information that we receive from third parties—such as service providers, government agencies, and others who provide services to you or us. Information that we learn about you when you use our services
• Information that we gather from the technology that you use to access our services (for example location data from your mobile phone, or an IP address or telephone number) and how you use it (for example pattern recognition)

Our Company collects your data so that we can:

Business Transactions

• Process your request for any of our products and services, in addition to facilitating a more efficient and more customized relationship with you
• Send you an email or SMS with additional information about our products and services or special offers
• Customize your experience with our mobile app and other digital channels
• To process certain transactions, Our Company will share your data with our partner companies so that you may be offered a product/service bundle or any of their services at competitive prices. These include:
  • Fitness service companies and Gyms
  • Travel agencies in relation to travel service bundles
  • Car tracking service companies
  • Digital lifestyle service companies

Law Enforcement

Under certain circumstances, the company may be required to disclose your personal data if required by law or in response to valid requests by public authorities (e.g., a court or a government agency).

Other requirements

The Company may disclose your Personal data in the good faith belief that such action is necessary to:

• Comply with a legal obligation
• Protect and defend the rights or property of the Company
• Prevent or investigate possible wrongdoing in connection with the Service
• Protect the personal safety of Users of the Service or the public
• Protect against legal liability
• Consent is provided
• Required by court orders or legal process
• Violation of any part of our Privacy Notice
• Third parties conduct business on our behalf. These parties process such information for specific and limited purposes, in compliance with the privacy notice and any other appropriate confidentiality and security measures

In addition, for certain transactions or processes, we may send your data to and also use the resulting information from reference agencies to detect or prevent fraudulent transactions.

How do we store your data?

Our Company securely stores your data in very secure databases in our data center (on-premises and cloud) protected by perimeter firewalls and intrusion detection devices. We will continue to enhance the security of your data by upgrading our security infrastructure to safeguard against new threats as they emerge.

Our Company will keep your personal data for inactive accounts (insurance policies, etc.) for a period of 15 years. Once this period has elapsed, we will delete your data by purging the records from our active database.

You have the right at any time to stop Our Company from contacting you for marketing purposes or giving your data to other members of the Our Company Group. If you no longer wish to be contacted for marketing purposes, please click here

What are your data protection rights?

Your Rights

These are summarized rights that you have under data protection law:

• The right to access
• The right to be informed
• The right to rectification
• The right to erasure
• The right to restrict processing
• The right to withdraw consent
• The right to object to processing
• The right to data portability
• The right to complain to a supervisory authority
• The right in relation to automated decision-making and profiling

Our Company would like to ensure you are fully aware of all your data protection rights. Every user is entitled to the following:

• The right to access: Data subjects have the right to request copies of their personal data. We may charge a small fee for this service.
• The right to be informed: Any data controller wanting to use, consult, or process the personal data of a data subject must inform the subject about the processing and its extent timeously.
• The right to rectification: The data subject has the right to request that we correct any of their personal information that they believe is inaccurate. They also have the right to request that we complete any of their personal information that they believe is incomplete.
• The right to erasure: The data subject has the right to request that Our Company erase their personal data, under certain conditions.
• The right to restrict processing: The data subject has the right to request that Our Company restrict the processing of their personal data, under certain conditions.
• The right to withdraw consent: A data subject must be informed, before giving their consent, that they have the right to withdraw it at any time, and the process for withdrawing consent should be straightforward.
• The right to object to processing: The data subject has the right to object to Our Company’s processing of their personal data, under certain conditions.
• The right to data portability: The data subject has the right to request that Our Company transfer their personal data to another organization, or directly to them, under certain conditions.
• The right to complain to a supervisory authority: Data subjects have a right to lodge a complaint to the Nigeria Data Protection Commission when aggrieved with the action of a data controller.
• The right in relation to automated decision-making and profiling: The Act grants data subjects the general right to not be subjected to decisions made solely through the automated processing of personal data.

When you make a request, we will respond within one (1) month. If you would like to exercise any of these rights, please contact us at our email: dataprotection@custodianplc.com.ng or Call us on: Phone: (+234)12774000-9

Cookies

Cookies are text files placed on your computer to collect standard Internet log information and visitor behavior information. When you visit our websites, we may collect information from you automatically through cookies or similar technology.

How do we use cookies?

Our Company uses cookies in a range of ways to improve your experience on our website, including:

• Marketing: Our Company would like to send you information about our products and services which we think you might be interested in, as well as those of our partner companies. You have the option to opt out of all marketing messages.
• Functionality: Our Company uses these cookies to enable us to recognize you on our website and to remember your previously selected preferences. These could include your location and language preference. A mix of first-party and third-party cookies are used.
• Advertising: Our Company uses these cookies to collect information about your visit to our website, the content you viewed, the links you followed, and information about your browser, device, and IP address. Our Company sometimes shares some limited aspects of this data with third parties for advertising purposes. We may also share online data collected through cookies with our advertising partners. This means that when you visit another website, you may be shown advertising based on your browsing patterns on our website.

Furthermore, we can use cookies to achieve the following:

• Keeping your session active
• Understanding how you use our website

Cookies are needed to make our website work, but we need your consent to use them.

How to manage cookies

You can disable cookies on your browser. However, in a few cases, some of our website features may not function as a result.

Privacy policies of other websites

Our Company website may contain links to other websites. Our privacy policy applies only to our website. If you click on a link to another website, you should read their privacy policy.

Changes to our privacy policy

Our Company keeps its privacy policy under regular review and places any updates on this web page.

Governing Law

This Privacy Policy is made pursuant to the Nigeria Data Protection Regulation (2019) or any other relevant Nigerian laws, regulations, or international conventions applicable to Nigeria. Where any provision of this Policy is deemed inconsistent with a law, regulation, or convention, such provision shall be subject to the overriding law, regulation, or convention.

How to contact us

If you have any questions about Our Company’s privacy policy or your data in our possession, or you would like to exercise one of your data protection rights or make a complaint, please do not hesitate to contact us.
Email us at: dataprotection@custodianplc.com.ng
Call us: (+234)12774000-9
Head Office: 16A, Commercial Avenue, Sabo, Yaba, Lagos
Website: www.custodianplc.com.ng

Nigeria Data Protection Commission
No. 12 Clement Isong Street,
Asokoro,
Abuja,
Nigeria