Privacy Policy

Learn more about how we collect, use, and protect your personal data in accordance with the law.

Effective Date: October 2, 2026
Version: 1.1

1. Introduction

Regius Asset Management Limited ("Regius", "we", "us" or "our") respects your privacy and is committed to protecting personal data processed through the App, website and related services.

This Privacy Policy explains what personal data we collect, why we collect it, how we use it, who we share it with, how we protect it and the rights available to you.

This Policy is intended to operate in accordance with the Nigeria Data Protection Act 2023, NDPC GAID 2025 and other applicable data-protection laws and regulations.

The NDPA requires privacy information to be clear, concise, transparent, intelligible and easily accessible.

2. Data Controller

Data Controller: Regius Asset Management Limited

Registered Address: 56, Awolowo Road, Ikoyi, Lagos State

Privacy/DPO Contact: ucheike@regiusassetmanagement.com

Email: privacy@regiusassetmanagement.com

Telephone: 0201-8771787

Data Protection Officer: UCHE IKE

Where Regius qualifies as a data controller of major importance, it should maintain an appropriately designated Data Protection Officer as required under the NDPA.

3. Information We Collect

A. Identity and KYC Data

  • name;
  • date of birth;
  • photograph;
  • BVN;
  • NIN;
  • identification documents;
  • proof of address;
  • nationality/residency information;
  • signature;
  • verification results.

B. Financial Information

  • bank account details;
  • source of funds;
  • source of wealth;
  • investment amount;
  • transaction information;
  • portfolio information;
  • payment information;
  • tax-related information where applicable.

C. Investment Information

  • investment objectives;
  • risk tolerance;
  • investor classification;
  • investment preferences;
  • product interests;
  • investment history;
  • portfolio holdings;
  • transaction history.

D. Biometric/Verification Information

Where applicable, the App may process facial or biometric verification information for identity and fraud-prevention purposes.

Such processing shall be subject to the applicable legal basis and safeguards required by law.

E. Technical Information

We may collect:

  • IP address;
  • device information;
  • operating system;
  • browser information;
  • App version;
  • login information;
  • authentication records;
  • device identifiers;
  • usage information;
  • security logs;
  • crash and diagnostic information.

The App's security design includes monitoring login attempts, access patterns and system usage.

4. Why We Process Personal Data

We process personal data for purposes including:

  • opening and maintaining your investment account;
  • conducting KYC and identity verification;
  • complying with AML/CFT/CPF obligations;
  • screening against applicable sanctions and watchlists;
  • assessing investment suitability;
  • processing investment transactions;
  • processing payments and withdrawals;
  • managing your portfolio;
  • issuing statements and certificates;
  • providing customer support;
  • detecting fraud;
  • protecting the App;
  • maintaining audit trails;
  • meeting regulatory obligations;
  • responding to lawful requests from regulators and authorities;
  • conducting research and analytics;
  • improving our services;
  • sending service communications; and
  • sending marketing communications where legally permitted and appropriately consented to.

The App is specifically designed to support AML/transaction monitoring, compliance approvals, audit trails and regulatory reporting.

5. Lawful Bases

Depending on the purpose, processing may rely on:

  • performance of a contract;
  • steps taken at your request before entering into a contract;
  • compliance with a legal obligation;
  • legitimate interests, where permitted;
  • consent;
  • protection of vital interests;
  • public-interest grounds; or
  • other lawful bases recognised by applicable law.

The NDPA expressly recognises consent, contract, legal obligation, vital interests, public interest and legitimate interests as lawful bases, subject to the statutory conditions.

6. Consent

Where consent is required, it shall be:

  • specific;
  • informed;
  • freely given;
  • affirmative;
  • recorded; and
  • capable of being withdrawn.

Silence or inactivity shall not constitute consent, and pre-ticked consent mechanisms should not be used where affirmative consent is required.

Withdrawal of consent will not affect processing lawfully conducted before withdrawal.

7. Regulatory and AML Processing

You acknowledge that certain processing cannot be withdrawn where Regius is required by law or regulation to retain or process the information.

For example, requests to delete KYC, transaction or regulatory records may be refused where retention is necessary for statutory, regulatory, audit, legal or AML purposes.

8. Automated Decision-Making and Profiling

The App may use automated processes to:

  • verify identity;
  • detect fraud;
  • assess risk;
  • identify unusual activity;
  • determine product eligibility; or
  • support suitability processes.

Where a decision is based solely on automated processing and produces legally significant or similarly significant effects, Regius shall provide appropriate safeguards required by law, including applicable rights to human intervention, expression of views and challenge.

9. Sharing Personal Data

Personal data may be disclosed to:

  • regulators;
  • government authorities;
  • courts and law-enforcement agencies where legally required;
  • custodians;
  • banks;
  • payment processors;
  • identity-verification providers;
  • KYC/AML service providers;
  • technology providers;
  • cloud-service providers;
  • professional advisers;
  • auditors;
  • insurers;
  • service providers; and
  • other persons where disclosure is lawful and necessary.

Where a third party processes data on behalf of Regius, appropriate contractual and technical safeguards shall be implemented.

The NDPA requires controllers engaging processors to ensure appropriate compliance and security measures, including written arrangements.

10. International Data Transfers

Where personal data is transferred outside Nigeria, Regius shall comply with applicable requirements concerning international transfers.

Depending on the circumstances, transfers may rely on an adequacy decision, an approved cross-border transfer instrument, or another lawful basis permitted by the NDPA/GAID.

The NDPC's current GAID framework expressly addresses adequacy decisions, approved cross-border transfer instruments and specified legal bases for international transfers.

11. Data Security

Regius shall implement appropriate technical and organisational measures designed to protect personal data against:

  • unauthorised access;
  • unlawful processing;
  • accidental loss;
  • destruction;
  • alteration;
  • disclosure;
  • misuse; and
  • other security threats.

Measures may include encryption, access controls, authentication, monitoring, pseudonymisation/de-identification and security testing.

12. Data Breaches

Where a personal-data breach occurs, Regius shall assess the nature and risk of the breach and take appropriate containment, remediation and notification measures.

Where required by law, the NDPA requires notification to the NDPC within 72 hours of becoming aware of a qualifying breach, and high-risk breaches must be communicated to affected data subjects in accordance with the Act.

13. Data Retention

We retain personal data only for as long as reasonably necessary for the purposes for which it was collected or as required by:

  • applicable law;
  • SEC requirements;
  • AML/CFT/CPF obligations;
  • tax requirements;
  • accounting requirements;
  • contractual obligations;
  • dispute resolution;
  • audit requirements; or
  • legitimate legal/business requirements.

The NDPA requires storage limitation and retention for no longer than necessary for the applicable lawful purpose.

14. Your Data-Protection Rights

Subject to applicable legal limitations, you may have rights to:

  • access your personal data;
  • obtain information about its processing;
  • request correction;
  • request deletion;
  • request restriction;
  • object to processing;
  • withdraw consent;
  • request data portability where applicable;
  • challenge certain automated decisions; and
  • lodge a complaint with the NDPC.

These rights are expressly recognised under the NDPA.

15. Direct Marketing

Regius may send investment education, product announcements, newsletters and promotional communications where legally permitted.

Where consent is required, marketing consent shall be obtained separately from acceptance of the Terms.

You may opt out of marketing communications at any time.

The NDPA expressly gives data subjects the right to object to processing for direct marketing, including related profiling.

16. Complaints

Privacy complaints may be submitted to:

Data Protection Officer
Regius Asset Management Limited
Email: privacy@regiusassetmanagement.com
Address: 56, Awolowo Road, Ikoyi, Lagos State

You may also lodge a complaint with the Nigeria Data Protection Commission where applicable.

17. Changes to this Privacy Policy

We may update this Privacy Policy to reflect changes in:

  • legislation;
  • regulation;
  • technology;
  • services;
  • processing activities; or
  • our privacy practices.

Material changes shall be communicated through appropriate channels.