Privacy Policy

Data Protection Privacy Policies

At United Capital, we treat your privacy with the highest importance. Our Data Protection Privacy Policy details the measures we take to preserving and safely guarding your privacy when you visit our website or communicate with our personnel. This policy has been approved and provided by our legal advisors.

These policies include:

A. Privacy Policy

Data Collection

We may collect, use, store, and transfer different categories of Personal Data about you, grouped as follows:

Identity Data – first name, last name, username or similar identifier, title, date of birth, and gender.
Contact Data – residential address, email address, and telephone numbers.
Human Resource Data – information relating to your employment history, professional qualifications, and educational background, particularly where you apply for employment with us.
Technical Data – IP address, domain name, login data, browser type and version, time zone setting and location, browser plug-ins, operating system, and device information.
Profile Data – username and password, preferences, interests, feedback, survey responses, and transaction or interaction history.
Usage Data – information on how you use our website and services.
Marketing and Communications Data – your preferences for receiving marketing communications from us and any affiliated entities, as well as your communication preferences.

We collect this information when you interact with us directly, including when you visit our website, subscribe to newsletters, request information, complete forms, participate in surveys, provide feedback, submit your details via business cards or visitor registers, apply for employment, or contact us through any other communication channel.

As you use our website, we may automatically collect Technical Data about your device, browsing actions, and usage patterns through cookies and similar technologies. For more information, please refer to our Cookies Policy.

We do not intentionally collect Sensitive Personal Data. We kindly request that you do not submit such information to us except same is specifically required for a defined purpose

Your Personal Data and how it is Used

Primarily, we collect, process and store your Personal Data to help us better connect with you. The following are the purposes for which we collect your Personal Data:

To monitor, review, evaluate and improve your experience when you visit our website
To analyse the traffic on our website, including determining the number of visitors to the website and analyse how they navigate the website.
To invite you to complete a survey or provide feedback to us on specific matters.
At any time, you request information from us via a form or other electronic transmission we may use your Personal Data to fulfil that request and keep a record of such request and how it was handled, for quality assurance and service improvement purposes.
To keep you updated on our activities, programmes and events where your explicit consent has been given.
To notify you of changes to our websites or relevant processes.
We may also use your information or allow Affiliated Third Parties such as our affiliate companies or partners use of this Personal Data, to offer you information about unrelated products or services you may be interested in. We or such Affiliated Third Parties can only communicate with you if you have expressly consented to such communication and data use.
We may share your personal data with Affiliated Third Parties such as service providers who we have engaged to assist with providing certain services on our behalf, for which they require your personal data.
Where we have any contracts with you which create a commitment, we may require contact or use of your information to perform the contract.
To process or manage your appointments with any of our staff.
To fulfil legal/ regulatory obligations or to report any criminal or unethical activity.
To store either on our central computer system or a third-party Computer’s central computer system for archiving and back up purposes.

Be aware that we do not reveal identifiable information about you to our advertisers, though we may at times share statistical visitor information with our advertisers.

Change of Purpose

We collect, process, and store your Personal Data to help us deliver better financial services to you.

Purposes for Processing Your Personal Data

We use your Personal Data for the following purposes:

To monitor, review, evaluate, and improve your experience on our website.
To analyse website traffic, including visitor numbers and usage patterns.
To invite you to participate in surveys or provide feedback on our products and services.
To respond to your enquiries and keep records for quality assurance and service improvement.
To send updates on our activities, programmes, and events where you have given consent.
To notify you of changes to our website or relevant processes.
To provide information about our or affiliates’ products or services, where you have consented to receive such communications.
To share data with our trusted service providers who support the delivery of our services.
To perform our contractual obligations with you where applicable.
To manage your appointments and interactions with our staff.
To comply with legal and regulatory obligations, including reporting unlawful or unethical activity where required.
To securely store data for archiving, backup, and business continuity purposes.

We may also share aggregated, non-identifiable statistical information with advertisers; however, we will not disclose personally identifiable information for advertising purposes without your consent.

Your Personal Data Rights

Data protection laws provide you with certain rights in relation to your Personal Data. These rights include:

Withdrawing consent to us or our Affiliated Third Parties. In order to make use of your personal data, we would have obtained your consent. For consent to be valid, it must be given voluntarily. In line with regulatory requirements, consent cannot be implied, and we ensure that you have the opportunity to read our data protection privacy policy before you provide your consent. Consent in respect of Sensitive Personal Data must be explicit and will be given by you in writing to us. The consent of minors (under the age of 18) will always be protected and obtained from the minor’s representatives in accordance with applicable regulatory requirements.
Opting out of marketing communications at any time either by clicking the unsubscribe option in the marketing messages or by updating your preferences.
Requesting for access to or deletion of your Personal Data in our possession subject to retention policies required for legal purposes and the time required technically to delete such information.
Requesting for correction or update of inaccurate or incomplete Personal Data.
Objecting to the processing of your Personal Data where applicable.
Requesting transfer of your Personal Data to another organisation where technically feasible.
Lodging a complaint with the relevant data protection authority (ies).

You may exercise these rights by following our Data Subject Access Request procedure.

Persons Who Have Access to Your Personal Data

In addition to our authorised staff who require access for business purposes, your Personal Data may be shared with other third parties:

Customer relationship management and email communication service providers used to manage our database and communications.
Affiliated third parties who support the purposes described in this Policy, under strict contractual data protection obligations.
Professional service providers such as IT support providers and website hosting services.
Regulatory authorities

Except regulatory authorities, these third parties are contractually required to protect your Personal Data in accordance with applicable data protection laws. They are only permitted to process your Personal Data for specified purposes and in line with our instructions.

Security & Confidentiality

We store your information on secure, encrypted servers, and access is restricted to authorised personnel only. Appropriate physical, technical, and administrative safeguards have been deployed to protect your Personal Data from unauthorised access, alteration, disclosure, or loss.

While we take reasonable steps to secure your information, no method of electronic transmission or storage is completely secure, and we cannot guarantee absolute security. In the event of a Personal Data breach, we shall manage and report such breach in line with the Nigerian Data Protection Act (NDPA), 2023 and other applicable regulations.

Where required, we shall notify the Nigeria Data Protection Commission (NDPC) within 72 hours of becoming aware of the breach and may also notify affected individuals where the breach poses a significant risk to their rights.

Our employees and authorised third parties are contractually bound to maintain the confidentiality of all Personal Data processed by us.

Transfer of Personal Data outside Nigeria

Where necessary and for the purposes outlined in this policy, your personal data may be transferred and processed abroad. The data protection laws in other countries may be different from, and less stringent than the Nigerian laws. By accepting this Policy or by providing your Personal Data to us, you expressly consent to such transfer and processing.

We will however take all reasonable steps to ensure that your data is treated securely, and transfer of your Personal Data is handled in accordance with the requirements of applicable laws.

We will only transfer your Personal Data to trusted third parties that are contractually required to implement appropriate security measures to protect your information.

Retention of Personal Data

We retain your Personal Data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable legal, regulatory, tax, accounting, or reporting obligations.

We may retain Personal Data for a longer period where there is an ongoing complaint, dispute, or where we reasonably believe there is a likelihood of litigation.
Retention periods are determined based on the nature, sensitivity, and purpose of the Personal Data, as well as legal and regulatory requirements.

Where Personal Data forms part of business records or documents, it will be retained in line with our internal records and retention policies.

Third Party Links

This website or our email communication may include links to third party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

Legal Basis for Processing

We process your Personal Data on the following legal bases:

Consent – where you have given permission (e.g., marketing communications).
Contractual necessity – where processing is required to deliver services or fulfill obligations.
Legal obligation – where processing is required to comply with applicable laws and regulations.

B. Cookie Policy

Our advertisers and organisation may have the occasion to collect information in regard to your computer for our services. The information is gained in a statistical manner for our use or advertisers on our site.
Data gathered will not identify you personally. It is strictly aggregate statistical data about our visitors and how they used our resources on the site. No identifying Personal Data will be shared at any time via cookies.
Close to the above, data gathering can be about general online use through a cookie file. When used, cookies are automatically placed in your hard drive where information transferred to your computer can be found. These cookies are designed to help us correct and improve our site’s services for you.
You may elect to decline all cookies via your computer or set up alerts to prompt you when websites set or access cookies. Every computer has the ability to decline file downloads like cookies. Your browser has an option to enable the declining of cookies. If you do decline cookie downloads you may be limited to certain areas of our site, as there are parts of our site that require cookies.
Any of our advertisers may also have a use for cookies. We are not responsible, nor do we have control of the cookies downloaded from advertisements. They are downloaded only if you click on the advertisement.

You provide this information through direct interaction when you visit our website, sign up to our newsletters or publications, request marketing materials to be sent to you, respond to surveys, complete our feedback or comment form, provide your business card to any of our staff, sign our visitor management form, complete other forms, apply for employment through our careers page, or contact us to request for any information or other correspondence by post, email, our website or otherwise.

As you interact with our website, we will automatically collect technical data about your equipment, browsing actions and patterns. We collect this data by using cookies, and other similar technologies. Please see our cookies policy for further details.

We do not intentionally or knowingly collect any Sensitive Personal Data. We ask that you do not send to us nor disclose such Sensitive Personal Data save where required for a specific purpose.

C. Subject Access Request Response Procedure

Where you wish to exercise any of your data privacy rights you shall make a formal request by completing the Subject Access Request Form (SAR Form) and sending the completed form via email to us at privacy@unitedcapitalplcgroup.com.
We shall contact you within 5 working days of the receipt of the SAR Form to confirm receipt of the subject access request and may request additional information to verify and confirm the identity of the individual making the request.
On receiving any request from you, we shall record the request and carry out verification of the identity of the individual making the request using the details provided in the SAR Form and a valid means of identification such as international passport, driver’s license, national identification card or any other acceptable means of identification.
Where the request is from a third party (such as relative or your representative), we will verify their authority to act for you and may contact you to confirm their identity and request your consent to disclose the information.
When your identity is verified, we shall coordinate the gathering of all information collected with respect to you in a concise, transparent, intelligible and easily accessible form, using clear and plain language with a view to responding to the specific request. The information may be provided in writing, or by other means, including, where appropriate, by electronic means or orally provided that your identity is proven by other means. We may also contact you to ask you for further information in relation to your request to speed up our response.
Where the information requested relates directly or indirectly to another person, we will seek the consent of that person before processing the request. However, where disclosure would adversely affect the rights and freedoms of others and we are unable to disclose the information, we will inform you promptly, with reasons for that decision.

Fees and Timeframe

We will respond to your request regarding your personal data within the timeframe required by applicable data protection laws and regulations. Where we are unable to act on your request, we will inform you of the reasons for our decision, subject to any applicable legal or regulatory restrictions. If you are not satisfied with our response or believe that your data protection rights have been infringed, you may lodge a complaint with the Nigeria Data Protection Commission (NDPC), in accordance with the Nigeria Data Protection Act, 2023 and applicable regulations and directives.
Where the request relates to any perceived violation of your rights, we shall take appropriate steps to remedy such violations, once confirmed. Remedies shall include but not limited to the investigation and reporting to appropriate authorities, recovering the personal data, correcting it and/ or enhancing controls around it. You shall be appropriately informed of the remedies employed.
Any information provided to you by us shall be provided free of charge. However, where requests are manifestly unfounded or excessive in particular because of their repetitive or cumbersome nature, we may:
- Charge a reasonable fee taking into account the administrative costs of providing the information or communication, taking the action required or making a decision to refuse to act on the request; or
- Write a letter to you stating the refusal to act on the request and copy the Nigeria Data Protection Commission (NDPC).

Exceptions to Data Subjects Access Rights

To the extent permitted by applicable laws, we may refuse to act on your request, if at least one of the following applies:

in compliance with a legal obligation to which we are subject;
protecting your vital interests or of another natural person; and
for public interest or in exercise of official public mandate vested in us.

Glossary

Affiliated Third Parties includes companies with which we have common ownership or management or other contractual strategic support or partnership relationships with, our advisers, consultants, bankers, vendors or sub-contractors.
Data is information, which is stored electronically, on a computer, or in certain paper-based filing systems.
Data Controller is a person responsible for determining the manner in which Personal Data would be processed.
NDPA means the Nigeria Data Protection Act, 2023.
NDPC means the Nigeria Data Protection Commission.
GAID means the General Application and Implementation Directive, 2025.
Personal Data is the information relating to an identified or identifiable natural person. These include a name, gender, a photo, an email address, bank details, medical information, computer internet protocol address and any other information specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Processing is any activity that involves use of Personal Data. It includes obtaining, recording or holding the data, or carrying out any operation or set of operations on the data including organising, amending, recording, retrieving, using, disclosing, erasing or destroying it. Processing also includes transferring personal data to third parties.
Sensitive Personal Data includes information about a person’s racial origin, political opinions, religious or similar beliefs, trade union membership, physical or mental health or condition or sexual life.

We undertake regular updates to our Data Protection Privacy Policies which we will notify you of on our website and/or by email.

Contact Details of Our Data Protection Officer (DPO)

If you have any questions or concerns about how we collect, use, store, or process your personal data, or if you wish to exercise your rights as a data subject under the Nigeria Data Protection Act (NDPA), you may contact our Data Protection Officer (DPO) via privacy@unitedcapitalplcgroup.com