Privacy Policy

This notice explains how we collect, use, share, store and protect the personal data of our clients, prospective clients, counterparties, website visitors, and other individuals whose personal data we process in connection with our brokerage, investment banking, advisory, and related financial services. It applies whether you interact with us in person, by phone, in writing, or through our digital platforms.

This notice does not apply to data processed by any third party that may be linked with Kedari. Please review the policies of those third parties separately.

We collect personal data directly from you, through automated interactions on our digital platforms, and via authorized third parties.

KYC & Account Opening

Full name, date of birth, residential address, utility bills, BVN, NIN, passport photograph, nationality, occupation, political exposure (PEP) status.

For Corporate accounts: Company name, RC No., identification of directors and beneficial owners.

Stockbroking Operations

CSCS account number, Clearing House Number (CHN), bank account details, investment profile, trading history, and portfolio records, next of kin and beneficiary details.

Issuing House Engagements

Financial records, tax identification numbers (TIN), employment details, accredited investor status, signature specimens, and corporate ownership structure (for institutional clients).

Digital & Platform Usage

IP address, device identifier, log-in credentials, geolocation data, and browsing behavior on our portal/trading app.

Biometric & Technical Data

Facial recognition or fingerprint data for app authentication or identity verification (processed under explicit statutory safeguards).

We process your personal data in accordance with Section 25, NDPA 2023 under the following lawful basis:

• Legal and Regulatory Obligation: Processing necessary to comply with the Investments and Securities Act (ISA), Money Laundering (Prevention and Prohibition) Act, SEC Rules, and Central Bank of Nigeria (CBN)/NFIU directives.
• Contractual Necessity: Processing required to fulfill our brokerage, portfolio management, or issuing house advisory agreements with you.
• Legitimate Interests: Processing required to conduct our business, prevent fraud, ensure network security, and manage risk, provided these interests do not override your fundamental rights.
• Consent: Where you have explicitly granted clear, informed permission for specific processing activities (e.g., direct marketing or non-essential cookies).

We collect and process your personal data for the following specific purposes:

• Securities Trading: Executing buy/sell mandates on the NGX/NASD and settlement via the CSCS.
• Capital Raising & Advisory: Managing public offers, rights issues, private placements, and corporate restructuring mandates.
• Regulatory Compliance: Fulfilling anti-money laundering (AML), counter-terrorism financing (CFT), and counter-proliferation financing (CPF) screening.
• Communication & Reporting: Transmitting contract notes, account statements, portfolio valuations, and regulatory disclosures.
• Risk Management & Security: Preventing fraud, authenticating platform access, and conducting audit trails.

We do not sell your personal data. We may share your data with third parties solely for legitimate operational and legal purposes, including:

1. 1Regulatory and Statutory Authorities: SEC, NGX, NASD OTC Exchange, CSCS, Nigerian Financial Intelligence Unit (NFIU), Central Bank of Nigeria (CBN), and Federal Capital Territory/State Inland Revenue Services.
2. 2Professional Advisors & Counterparties: Registrars, receiving banks, trustees, auditors, legal counsel, and rating agencies involved in capital market transactions.
3. 3Third-Party Service Providers: Cloud storage providers, IT infrastructure vendors, KYC verification partners, and automated trading platform developers operating under strict non-disclosure and data processing agreements.

Where it is necessary to transfer your personal data outside Nigeria (e.g., cloud storage servers or international brokerage partners), we ensure compliance with Section 43 of the NDPA 2023. Transfers are only conducted to jurisdictions with adequate data protection laws or where standard contractual clauses and binding rules approved by the NDPC are enforced.

• Security: We employ robust technical and organizational security controls, including end-to-end encryption, multi-factor authentication (MFA), role-based access control, and routine vulnerability testing, to prevent unauthorized access or disclosure.
• Retention Period: Under SEC and AML/CFT regulations, transactional, trading, and KYC records are typically retained for a minimum of six (6) to ten (10) years post-account closure or transaction completion. Thus, we retain your personal data for as long as your account remains active or as required by law.

In accordance with Part VI of the NDPA 2023, you hold the following rights regarding your personal data:

• Right to be Informed: To know how your data is collected and processed.
• Right of Access: To request copies of your personal data held by us.
• Right to Rectification: To request immediate correction of inaccurate or incomplete data.
• Right to Erasure (“Right to be Forgotten”): To request deletion of your data where no overriding legal obligation requires its retention.
• Right to Restrict or Object to Processing: To object to direct marketing or processing based on legitimate interest.
• Right to Data Portability: To request transfer of your structured data to another entity.
• Right to Withdraw Consent: To revoke consent at any time without affecting prior lawful processing.

This notice may be updated from time to time to reflect our operational changes, legal obligations, or regulatory changes. By continuing to use our services, you acknowledge that you have read and understand this notice.

If you have questions, wish to exercise your rights, or wish to file a privacy concern, contact our DPO via compliance@kedaricapital.com.

If you believe your privacy rights have been infringed and we fail to address your concern within 30 days, you have the right to lodge a formal complaint with the Nigeria Data Protection Commission (NDPC) via info@ndpc.gov.ng.