Privacy Policy
Hilltrust Global Investment Ltd (HGIL) is a Non-bank Microfinance Institution with a distinct vision to penetrate and provide alternative financial services to the underserved teeming Nigerian populace using our unique lending model. At HGIL, we continue to set the pace in the alternative and structured finance space in Nigeria and our products and services are broadly classified thus; SME Finance, Consumer Finance and Funds Management. HGIL is committed to ensuring that the privacy and personal information of its clients, employees, vendors and other beneficiaries are protected at all times. This Privacy Policy is designed to help you understand what information we gather about you, what we use that information for and with whom we share the information. In addition, it also sets out your rights in relation to your information and who you may contact for more information or inquiries. Carefully read the following to understand our processed and practices as regards your personal data and information and how we will manage them.
To Whom This Privacy Policy applies and what it covers.
This Privacy Policy applies to Hilltrust Global Investment Ltd. We respect the privacy of our customers, visitors to our website, business partners and associates who may choose to provide us with their personal and financial information and we are committed to respecting their privacy. This Policy categorically sets out how we collect, handle, store and protect these information when; We provide products and service to you You visit or use our website and/or Perform any other activities that form part of our business Please note that other websites that may be linked to this website/App are not governed by this Privacy Policy. We encourage visitors to review their Privacy Policy on each of these other websites before disclosing any of their personal and financial information.
Consent
You agree with the contents of this Privacy Policy when you give consent upon access to our website, digital and non-digital platforms or use our services, contents, features and functions offered on our website. Note that that you can withdraw your consent at any time. However, such withdrawal will not alter the lawfulness of already processed information based on consent given before its withdrawal.
The Information We Collect
In the course of providing services offerings to you and performing due diligence checks in connection with our services (or discussing the possible services we might offer), we generally collect personal and financial information about you. We typically collect or obtain your personal and financial information because you either give it to us (by visiting our website) or because other people give that information to us (through third party service providers that we use to help operate our website. We may also collect or obtain your personal information from you by inferring those information about you from the way you interact with us. In order to improve your experience when you use this website and to ensure that it functions effectively, we (or our service providers) also use cookies and web beacons which may collect personal information. The personal and financial information that we may collect depends on the specific services and activities we offer and you may find desirable to access. These personal information typically includes but not limited to your;.
- Name
- Date of Birth
- Age
- Gender
- Marital Status
- Home Address
- Office Address
- Email Address
- Bank Verification Number
- Other Contact Details
- Country of residence
- Valid Identity Number
- Employment Details and
Financial information that we may collect includes;
- Income
- Bank Account Details
- Bank Statement
Other information outside Personal and Financial information that we may collect from you includes;
- IP Address
- Browser and Device type
- Username that is used by you for our service offerings
- Access times and Location
- Websites you visited before and after visiting our website
- Details of how you would like to interact with us and other similar information as may be necessary.
- Your employer
- Third party providers of ‘Know your client’ and anti-money laundering service providers which we use to help us meet our legal and regulatory requirements
- Background check providers which we sometimes use to verify your identity
- Third party service providers that help us operate our websites
- Your banks and financial institutions.
Use of Personal Information to Provide Products and Services
We use your information for legitimate business purposes only. We will use your personal and financial information to provide you with products and services as you may request. As part of this, we may use the information in the course of correspondence relating to those products and services. Such correspondences may be with you, our customers, our service providers or public and judicial authorities with the necessary authorization. In many cases, we also use your information to conduct due diligence checks in advance of providing products and services to you and to process an application from you. If you are referred to us by intermediary or similar third party, we also typically use your personal information to access whether to accept or reject your referral to Hilltrust Global Investment by that intermediary or similar third party.
What we do with the information we gather
We generally use information collected through this website;
- To enhance internal record keeping
- To manage and improve services provided via our website
- To tailor content of our website to provide you with a more specialized experience and draw your attention to information about products and services that may be of interest to you.
- To manage and respond to any requests that you submit through our website
- To correspond with you in relation to services you use on our website or information you provide via our website. This correspondence is usually with you, our third party service providers and judicial/public authorities with the necessary authorization.
- To enhance prudent operational management including credit and risk management, audit, training and similar administrative purposes
- To enhance arrangements we have with intermediaries, brokers and other individuals and entities that partner with us.
The Legal Grounds we rely on for processing Personal Information
- All personal information which we collect and process are justified by lawful processing on the basis that;
- You have given consent to the processing
- Processing is necessary for the performance of a contract to which you are a party or have taken steps to enter into
- Processing is necessary for compliance with legal and regulatory obligations to which we are subject
- Processing is necessary in order to protect your vital interests or another natural person
- Processing is necessary for the performance of a task carried out in the public interest
How we collect personal information
We collect information about you and any other party whose details you provide to us when you;
- Complete online forms
- Take part in surveys
- Interact with us through our social media platforms
- Download information such as publications or participate in any other interactive areas as it appears on our website or portal
- Contact us offline via telephone call, sms, email, post or any oter means of communication
- Third party data collection source
- Credit reference agencies
To whom we disclose your information
We generally disclose details about you to professional advisors and third parties that provide services to us such as our;
- IT system providers
- Platform providers
- Financial advisors
- Consultants including Lawyers and Accountants
- Competent Authorities including any national and/or international regulatory or enforcement body
- Law court or other form of tribunal where we are required to do so by applicable law or regulation at their request
- Potential buyer, merger partner and their advisers
- Credit reference agencies and other organizations that help us detect criminal activity and incidence of fraud
- Any Federal, State or Local government department
- Other statutory or public bodies
How long we keep your personal information
We will hold your personal information on our system for as long as it is required to take decision on the service offering for which you have made the information available to us. This information will be held to ease processing of subsequent requests by you and as well save you stress and time.
Protection of your personal information
We are committed to ensuring that your information is secure. In order to prevent unauthorized access or disclosure, we have put in place reasonable physical, electronic and managerial procedures to safeguard and secure the information we collect online. In particular, we adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of your personal transaction information and data stored on our website. Implementation of regular education and training of relevant staffs to ensure that they are aware of our privacy obligations when handling personal information as well as training around social engineering, phishing and password risks, administrative and technical controls to restrict access to personal information on a ‘need to know’ basis. Sensitive and private data exchange between the website and its users happen over a secured communication channel that is encrypted and protected. Transactions are also handled over a secure payment gateway and additional measures has been designed to protect personal information against accidental or unlawful destruction, accidental loss, alteration, damage, unauthorized disclosure or access as well as other forms of unlawful processing.
Storage of your data
The data we collect from you will be transferred and stored at a destination in Nigeria. By submitting your personal data, you agree to this transfer, storage and processing. We will take all steps reasonably to ensure that your data is treated securely and in accordance with this privacy policy. All information you provide to us is stored on our cloud-based data storage as well as on premises, at an off-site based location and a network accessible storage which includes external drives only for authorized users. We erase/delete personal data in the event of any of the following;
- The personal data is no longer necessary in relation to the purposes for which they were collected or processed
- You withdraw your consent or object to the processing and there is no overriding lawful basis for the processing
- The personal data was unlawfully collected or processed in the first place
- In compliance with NITDA’s or any other directive.
Do we use cookies?
Cookies are a kind of short-term memory for the web. They are stored in your browser and enable a site to remember little bits of information between pages or visits. We use cookies to improve your browsing experience on our website. By browsing on our website, you consent to our use of cookies in accordance with our Privacy Policy.
Sharing your Personal Information
We do not sell, trade or rent the personal information of our data subjects to others outside our firm howsoever without your consent to do so except one of the following circumstances applies; For External Processing We may provide your personal information to our affiliates or other third part agents to process them for us based on our instructions and in compliance with our privacy policy and any other appropriate confidentiality and security measures. For Legal Reasons We may share your personal information with companies, organizations or individuals outside our firm if we have a good faith belief that access, use, preservation or disclosure of the information is reasonably necessary to; Meet any applicable law, regulation, legal process or enforceable governmental request Detect, prevent or otherwise address fraud, security or technical issues Protect against harm to the rights, property or safety of the Firm, our users or the public as required or permitted by law.
Your rights as a data subject
At any point while we are in possession of or processing your personal data, you, the data subject has the following rights;
- Right of Access – You have the right to request a copy of the information that we hold about you
- Right of Rectification- You have right to correct the data that we hold about you that is inaccurate or incomplete
- Right to be Erased/Forgotten – In certain circumstances, you can ask for the data we hold about you to be erased from our records.
- Right to Restriction of Processing – Where certain conditions apply to have a right to restrict the processing
- Right to Portability – You have the right to have the data we hold about you transferred to another organization (To be reused for your personal purposes)
- Right to object to automated processing, including profiling – You have the right to be subject to the legal effects of automated processing or profiling
- Right to Withdraw – You have the right to withdraw your consent at any time.
Dispute Resolution or Filing a Complaint
If you have any complaint regarding our compliance with this Privacy Policy, please contact our data protection officer. We will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information within thirty (30) days in accordance with this Privacy Policy and in accordance with applicable laws and regulations.
Changes to this Privacy Policy
Our privacy policy may change from time to time. We will not reduce your rights under this policy without your explicit consent. We will post any privacy policy changes on this page and if the changes are significant, we will provide more prominent notice either via email notification, pop-up notice or statement of changes on our website You acknowledge that it is your responsibility to review this Policy periodically and become aware of modifications. This Privacy Policy was last updated on July 12, 2020.
Compliance with Regulators
This privacy policy is in line with the provisions of Nigeria Data Protection Regulation, 2019, a regulation which describes how organization (Hilltrust Global Investment Ltd. inclusive) must collect, handle and store personal information and applies regardless of whether the information is stored electronically, on paper or on other materials.
Contacting Us
If you have any questions about this Privacy Policy, the practices of this site or your dealings with the site, please contact us at;
Hilltrust Global Investment Ltd.
242, Muhammadu Buhari Way, Central Business District, Abuja
Tel: +234(0)8135458664
Email: info@hilltrustglobal.com