Privacy Policy

Introduction

At InvestNaija, we recognise that your privacy is important, and we are dedicated to protecting your data and privacy. Therefore, we treat your data and information (“data”) as private and confidential.

This Privacy policy (“the Policy”) outlines our continuous obligations to you in respect of how we manage your personal information. It also contains the details of personal information collected, the modality of collection, storage and usage of data collected. We believe this will help you make an informed decision about sharing your personal information with us.

InvestNaija strives to maintain the highest standards of decency, fairness and integrity in its operations; we are equally dedicated to protecting the data of our Clients and online visitors (“user/ users”) while using our website and ecommerce platforms (“Site”).

In the light of this, you will be required to read and accept the terms of this Policy prior to accessing our websites, receiving our emails and/or utilising our ecommerce portals.

Personal Information

Personal information are details that identifies an individual such as names, addresses, email addresses, phone numbers and any other unique identifiable information (“Personal Information”).

We limit the collection and use of non-public personal information to the minimum we believe is necessary to deliver superior service to you. Services can include advising you about your investments, maintaining your account with us and other opportunities.

What we Collect

We obtain mostly non-public personal information directly from you or your agents whether in person, by telephone or electronically. This information may include without limitation:

First name, last name and job title;
Contact information including home address, email address, business address, home telephone numbers and business telephone numbers;
Banking information, including your Bank Verification Number (“BVN”);
Occupation;
Non-personal identification information such as browser name, type of computer and technical information about your means of connection to our site, such as the operating system and the internet service providers utilised; and
Other information relevant to customer surveys and/or offers.


Disclosure of Personal Information

We do not disclose any Personal Information about our investors, former investors or stakeholders to anyone, except when we believe it is necessary for fulfillment of our obligations to the investor, stakeholder or under an agreement with the Investor, or with the consent of the investor, or where disclosure is required by law. Except otherwise indicated herein, we will not make any disclosures of non-public personal information to other third parties who may want to sell their products or services to you.

What We do With the Information we Collect

We require this information to understand your needs which will enable us provide you with better products as well as smart service solutions. Other operational reasons:

• Internal record keeping;
• To improve our products and services;
• To improve our service delivery;
• To contact you occasionally for market research purposes;
• To send emails about new investment opportunities, investment valuation statements or other
• information which we believe would be of importance to you; and
• To improve our website through feedback you provide on products and services.


Cookies

We utilise cookies to improve your user experience on our websites. Cookies are messages that web servers pass to your web browser when you visit internet sites and typically contain information about your visit to a specific web page, track website activities, as well as any information you have volunteered, such as name and interests. This is to ensure that you do not have to re-enter this information each time you visit the site.

You can however choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can modify your browser setting to decline cookies if you prefer. However, this may prevent you from taking full advantage of the website.

Links to Other Websites

Our site may contain links to other websites of interest. However, InvestNaija shall NOT be responsible for the protection and privacy of any information which you provide whilst visiting such websites; such websites are not governed by this policy. You should exercise caution and review the privacy statement(s) applicable to those websites.

Security of Personal Information

Your Personal Information is stored in a manner that reasonably protects it from misuse, loss, unauthorised access and/or modification.

When your Personal Information is no longer needed for the purpose for which it was obtained, we will take reasonable steps to destroy or permanently de-identify your Personal Information. However, most of the Personal Information is or will be stored in client files, which will be kept by us for a minimum of seven (7) years.

Access to Personal Information

You may access your Personal Information in order to update and/ or correct the details, subject to certain exceptions. If you wish to access your personal information, please contact us in writing.

To protect your personal identification, we will require some form of identification from you before releasing the requested information.

Maintaining the Quality of Your Information

It is important to us that your Personal Information is updated regularly. We will take reasonable steps to make sure that your Personal Information is accurate, complete and up-to-date. If you find that the information we have is not up to date or is inaccurate, please inform us as soon as practicable so we can update our records to ensure we continue to provide quality services to you.

This policy may change from time to time, to reflect changes in our practices and/or applicable law and regulation.

If you have any queries or seek to withdraw your consent, please contact us at the information below and we shall respond accordingly:

InvestNaija
10, Bankole Oki Road
Ikoyi, Lagos
NIGERIA
Tel: +234 (0) 700 468 3786 2452
Email: info@investnaija.com

Terms of Use (Service)

Welcome to InvestNaija, a personalized financial education, omni-channel, money management solution. This document (the “Terms and Conditions”) provides you with important information about the services provided by InvestNaija with respect to the access and use of investnaija.com, our mobile applications, and our other online services and websites (collectively, the “Platform”). These Terms and Conditions may be varied and supplemented from time to time. We advise that you check this page often, referring to the date of the last modification. If a user objects to any of the changes to the terms of use, the user must cease using the Platform or services immediately. With InvestNaija, you can effortlessly track your personal development, finances, account balances, cash flow, transactions and holdings - from the convenience of your computer, tablet or phone. We look forward to your use of our Platform or services.

For the purpose of these Terms and Conditions, the term “InvestNaija” refers collectively to InvestIN Limited, as well as its respective affiliates, partners, agents, and employees.

Terms of Use Agreement

  1. Description of our Services

Our services (“Services”) include educating clients with varying degrees of financial knowledge and providing them with an omni-channel approach to saving and investing. The Service may include or make available alerts related to your account, symbols, quotes, news stories and other materials or information (collectively, “Content”). Some of the Content is supplied by companies that are not affiliated with InvestNaija (“Information Providers”). Our clients will have access to an extensive portfolio of interest and non-interest savings and investment products from mutual funds to fixed income, equity and alternative investments.

Our portfolio of learning, savings and investment products is designed to facilitate the easy adoption of prudent financial habits necessary for sustainable financial independence. We refer to those who enroll in our Platform as “Clients.”

  1. Agreement and Acceptance of Terms

This terms of use agreement, along with any exhibits, disclosures, addendums or amendments hereto, as the same may be amended or modified from time to time (collectively, this “Agreement”) constitutes an agreement between you and us which sets forth the terms and conditions applicable to your access and use of the Platform and other Services including those provided by our registered professionals. In this Agreement, we refer to those who use our Services collectively as “users.” Some of our Services are provided through the Platform and other Services and through affiliated companies.

Your use of our Platform or Services is subject to our Privacy Policy, which explains how we gather, use, disclose and manage your personal information. Terms used but not defined in this Agreement have the meanings provided to them in our Privacy Policy.

By accessing or using the Platform or any Service, you understand and agree to be bound by the terms and conditions of this Agreement as well as the Privacy Policy linked here, and the Copyright and Intellectual Property Policy linked here, all of which may be amended from time to time in the future. If you do not agree to this Agreement, then you may not use the Platform or Services. You also agree that:

  1.  You are able to enter into legally binding contracts, and you agree that this Agreement legally binds you in the same manner that a signed, written, paper contract does. You may not use the Platform or Services in any manner or attempt to access the Platform or any Service if you are not willing to be bound and abide by this Agreement.
  2.  We are not responsible for the financial or other products and services or for the accuracy of the data obtained from third party sites that are displayed or reported through our platform or any of our services. While the Platform and Services provided by InvestNaija may provide significant assistance in helping you manage your finances, you should consult with a professional financial advisor before making investment decisions or deciding on significant changes to your personal financial strategy.
  3.  We reserve the right to change or modify this Agreement or our Privacy Policy, or modify or discontinue any portion of the Services or features and functionality provided through the Platform, from time to time. If we decide to change this Agreement or our Privacy Policy, we will post such changes on the Platform or on our website, and such changes will be effective at such time. We reserve the right to modify or discontinue your access to the Platform or portion thereof, or any Service, without prior notice or reason to you. You agree that we shall not be liable to you or any third party for any modification of the Platform, the Services, this Agreement, or your access to the Platform or Services.
  4.  The Platform and Services are intended to be accessed and used only by individuals that have reached the legal age of majority in the jurisdiction where they are located, which may be 18 years or older, depending on the jurisdiction. You may not use or access this Platform or any Service unless you have reached the legal age of majority in the jurisdiction where you are located.
  5.  The Platform is only intended for use by persons located in Nigeria. InvestNaija makes no representation that the Platform is appropriate or available for use outside Nigeria. Similarly, InvestNaija makes no representations that accessing the Platform from locations outside Nigeria is legal or permissible under local law.
  6.  You agree that you will comply with all applicable laws, including, without limitation, privacy laws, intellectual property laws, anti-spam laws, export control laws, tax laws, and regulatory requirements.
  7. Platform and Services - Risk Warning

By using the Services, you understand and acknowledge that the investment results you could obtain from investment information and financial insights provided by InvestNaija cannot be guaranteed. All investments entail a risk of loss and you may lose some or all of your money. You also understand that all investments are subject to various market, currency, economic, political, business and other risks. Investments can be very volatile and can result in a loss of principal. Investments risks include currency fluctuation, political and economic instability and differences in financial reporting. Investments in smaller companies may involve greater risks than investments in larger, more mature companies. The value of debt securities frequently is reduced (sometimes dramatically) by increases in interest rates. While the financial insights we provide may assist in helping you manage your finances, you should consult with a professional investment advisor before making investment decisions or deciding on significant changes to your personal financial strategy.

  1. Acting as Your Authorized Agent

By accessing and using the Platform and/or Services, you expressly authorize and direct InvestNaija, on your behalf, to electronically retrieve your account information maintained by third-party financial institutions with which you have a legally binding customer relationship (“Account Information”). Subject to our privacy procedures as described in the Privacy Policy, InvestNaija may work with one or more third-party financial service technology providers to access and retrieve your Account Information.

FOR PURPOSES OF THIS AGREEMENT AND SOLELY TO OBTAIN AND PROVIDE THE ACCOUNT INFORMATION TO YOU AS PART OF THE SERVICES, YOU GRANT INVESTNAIJA A LIMITED POWER OF ATTORNEY, AND APPOINT INVESTNAIJA AS YOUR ATTORNEY-IN-FACT AND AGENT, WITH FULL POWER OF SUBSTITUTION AND RE-SUBSTITUTION, FOR YOU AND IN YOUR NAME, PLACE AND STEAD, IN ANY AND ALL CAPACITIES, TO ACCESS THIRD PARTY SITES, SERVERS OR DOCUMENTS, RETRIEVE INFORMATION AND USE YOUR INFORMATION WITH THE FULL POWER AND AUTHORITY TO DO AND PERFORM EACH AND EVERY ACT AND THING REQUISITE AND NECESSARY TO BE DONE IN CONNECTION WITH SUCH ACTIVITIES, AS FULLY TO ALL INTENTS AND PURPOSES AS YOU COULD DO IN PERSON.

YOU ACKNOWLEDGE AND AGREE THAT WHEN INVESTNAIJA IS ACCESSING AND RETRIEVING ACCOUNT INFORMATION FROM THIRD PARTY SITES, INVESTNAIJA IS ACTING AS YOUR AGENT, AND NOT AS THE AGENT OF OR ON BEHALF OF ANY THIRD PARTY. YOU AGREE THAT THIRD-PARTY ACCOUNT PROVIDERS SHALL BE ENTITLED TO RELY ON THE FOREGOING AUTHORIZATION, AGENCY AND POWER OF ATTORNEY GRANTED BY YOU.

  1. Your Registration Information

In order to use our Site/ Platform or any of the Services, you will first need to create an InvestNaija user account (“Account”) through the Site/ App. To establish an Account you must provide Personal Information (as defined in our Privacy Policy) that is collected on the secure enrollment page. See the Privacy Policy for further information.

  1. Your Electronic Disclosure Consent

By providing your email to enroll for use of our Services and/or Platform, you consent to receive all notices and information regarding our Services and other offerings electronically. Electronic communications may be posted on our Platform and/or delivered to your registered e-mail address. All communications in electronic format will be considered to be in “writing,” and to have been received no later than five (5) business days after posting or dissemination, whether or not you have received or retrieved the communication. Your consent to receive communications electronically is valid until you end your relationship with InvestNaija. It is your responsibility to provide us with true, accurate and complete e-mail addresses, contact and other information related to this disclosure and to maintain and update promptly any changes in this information. You may print a copy of any electronic communications and retain it for your records. We reserve the right to terminate or change the terms and conditions on which we provide electronic communications and will provide you notice thereof in accordance with applicable law.

SMS/Text Messaging Service

You may receive SMS/text messages from InvestNaija about account-related news and alerts and/or promotional offers for InvestNaija products and services. By enrolling in InvestNaija’s services, you agree to receive text messages from InvestNaija to your mobile phone number provided. You certify that your mobile number provided is correct and that you are authorized to enroll the designated mobile number to receive such text messages. You acknowledge and agree that the text messages may be sent using an automatic telephone dialing system and that standard message and data rates may apply. Consent to receive text messages for promotional purposes is not required as a condition of purchase or use of the Services. The text messaging may not be compatible with all mobile phone models. InvestNaija is not responsible for any delays upon sending or receiving text messages.

To unsubscribe from text messages at any time reply STOP, END or QUIT to any text message you receive from InvestNaija. You consent that following such a request to unsubscribe, you may receive additional messages from InvestNaija confirming your request. Note that unsubscribing from promotional and/or account-related texts will not prevent InvestNaija from sending you text messages for security and authentication purposes.

  1. Cost of Service

Your use of the Site/ App and related Services are offered free of charge. We may offer you additional services, which you may elect to participate in or not, for a fee. InvestNaija reserves the right, in its sole discretion, to amend or change it pricing policy for its current Services or any additional services that we may offer.

  1. Data and Data Integrity

The overall integrity and quality of the data presented by InvestNaija to you is an important element in providing you with a high quality and have accurate picture of your account. InvestNaija, however, is not responsible for and cannot guarantee the accuracy of data we provide.

InvestNaija may not be able to foresee or anticipate technical or other difficulties which may result in failure to obtain data, personalization settings or other service interruptions. InvestNaija assumes no responsibility for the timeliness, accuracy, deletion, non-delivery or failure to store any user data, loss of user data, communications or personalization settings. InvestNaija encourages you to periodically confirm the valuation or execution price of particular investments through independent sources, such as an investment adviser, broker-dealer or other financial institution.

  1. External Links

The Platform links to certain content created by third parties that are not affiliated with InvestNaija. InvestNaija is not responsible for such content and does not endorse or approve it. Such content may contain terms and conditions, privacy provisions, confidentiality provisions, or other provisions that differ from the terms and conditions applicable to the Platform. InvestNaija assumes no responsibility or liability whatsoever for the accuracy, reliability, or opinions contained in such content. If you decide to access such content, you do so at your own risk.

  1. Other Obligations While You Use the Services

Confidentiality: You agree and understand that you are responsible for maintaining the confidentiality of your Account’s login information and password. You should also maintain appropriate anti-virus and anti-malware software on your computer, so that your Account login information is not compromised through your own negligence. If you receive evidence that someone has committed fraud by accessing your Account you must contact us immediately at info@investnaija.com.

Accurate and Up-to-Date Information: Our Services depend on your providing us with complete, accurate and up-to-date information, both now and in the future about yourself and your accounts. In turn, we will provide you with online security as described in our Privacy Policy. Those assurances are conditioned upon your provision of correct contact and account information to us, and never misrepresenting to us your identity or account registration information (e.g., for the use of your third-party websites and accounts).

You agree that you will NOT do any of the following: (i) engage in behavior that will put your personal information at unnecessary risk, such as unsecured transmitting, or publishing your Login or passwords; (ii) use our Platform, Services or any of your accounts for illegal purposes, (iii) use our Platform or Services to transmit anything that is unlawful, libelous, intended to harass or violate the rights of another; (iv) resell or make any commercial use of the Platform or Services, as they are intended solely for your use as an end user; (v) reverse engineer or decompile any technology associated with the Platform or Services, including but not limited to any software applications, Java applets or plug-ins associated with the Services; (vi) use any robot, spider, webcrawler, scraper, deep link or similar automated extraction or data gathering mechanism, program or tool to access, copy or monitor our Platform or Services or any portion thereof without our prior written consent; (vii) post or transmit any file or email which contains viruses, worms, Trojan horses or any other damaging or destructive elements; or (viii) create/register accounts or aggregate financial institutions with the Service through unauthorized means, including but not limited to, by using an automated device, script, bot, spider, crawler or scraper.

Consent to Recording: You consent to the recording of any electronic or written correspondence and any or all telephone conversations between you, us and any of our affiliates in connection with this Agreement or the Services and agree and understand that recordings may be submitted in evidence in any legal proceeding relating to this Agreement. For compliance and regulatory purposes, we reserve the right to keep an audit trail of all financial insights or investment advice that we provided to you.

  1. Confidentiality and Feedback

We always welcome your correspondence, feedback, comments, complaints and suggestions (collectively, “Feedback”) as this will help us improve our Services. You agree that all Feedback becomes our confidential information (“Confidential Information”). In addition, any of our trade secrets, computer software, product specifications as well as any non-public technical, financial or business information that we share with you is also our Confidential Information. You agree not to disclose or share any of our Confidential Information with any third party, including, without limitation, any members of the press or colleagues. Feedback may be submitted to riskmanagement@investnaija.com.

  1. Third Party Software and Service Providers

To facilitate our provision of the Platform and Services, we license software, tools and services from third-party providers. From time to time, we may revise this Agreement as requested by our third-party providers and require that you agree to additional pass-through terms with respect to such third-party providers. In the event that any use of the services of such third-party providers results in you leaving our Platform and entering the site of a third-party provider, then you will be subject to the terms of service or use and the privacy policy of such third-party provider, so please review such terms carefully. Also, when you use or access the sites of your financial services providers, you will be subject to their terms of use/service and online policies, and your use of their services constitutes your agreement to their online terms and policies. InvestNaija may provide experiences on social media platforms such as Facebook®, Instagram®, Twitter® and LinkedIn® that enable online sharing and collaboration among users who have registered to use them. Any content you post, such as pictures, information, opinions, or any personal information that you make available to other participants on these social platforms, is subject to the terms of use and privacy policies of those platforms. Please refer to those social media platforms to better understand your rights and obligations with regard to such content.

  1. Financial Services and Third-Party Offers

Investment advice provided by InvestNaija, or any of its related companies refers to any recommendations, suggestions, analysis, or opinions given to you through a personal advisor concerning buying, selling, holding, evaluating or analyzing any security or related type of investment. Investment advice provided by InvestNaija or any of its related companies also refers to any recommendations, suggestions, analysis, or opinions given to InvestNaija’ s users through the services concerning buying, selling, holding, evaluating or analyzing any security or related type of investment.

InvestNaija can provide more extensive advisory services, such as discretionary money management, under a separate advisory agreement with you.

InvestNaija and Third-Party Offers: Some parts of the Services may, either today or in the future, be supported by advertising or marketing partnership relationships. We will always disclose when a particular InvestNaija third-party offer is sponsored or when a third party compensates InvestNaija in connection with the sponsored offer.

  1. Ownership, Copyright, and Trademark

The technology and content used to offer, or provided in connection with, the Services, including but not limited to our Platform, browser software plug-in, smart phone software and tablet software, are either owned by us or licensed by us from third-party licensors. Such content includes the look and feel of our Platform, all our promotional materials, and in general include all text, graphics, photographs, illustrations, images, videos, tutorials, notices, software and other content, which is protected by the trademark, patent and intellectual property laws of the Federal Republic of Nigeria.

  1. Disclaimer of Representation and Warranty; Disclaimer of Liability
  2. INVESTNAIJA, ITS LICENSORS, REPRESENTATIVES AND AGENTS DO NOT REPRESENT OR IMPLY ANY PERFORMANCE LEVEL, RESULTS OR GUARANTEES IN RELATION TO THE OPERATION OF THE SERVICE AND INVESTNAIJA DOES NOT MAKE ANY CLAIM THAT THE USE OF THE SERVICE WILL RESULT IN A PARTICULAR PROFIT OR PREVENT ANY LOSS FOR A USER.
  3. NOTWITHSTANDING ANYTHING STATED IN THIS AGREEMENT TO THE CONTRARY, INVESTNAIIJA, LICENSORS AND AGENTS REPRESENT THAT THE SERVICES AND THE PLATFORM ARE PROVIDED “AS IS” AND “AS AVAILABLE” WITHOUT WARRANTY OF ANY KIND. INVESTNAIJA, ITS LICENSORS AND AGENTS ASSUME NO RESPONSIBILITY FOR ERRORS OR OMISSIONS MADE BY YOU, OR ERRORS OR OMISSIONS IN THE CONTENT, INFORMATION OR OTHER DATA AND DOCUMENTS, WHICH ARE REFERENCED BY, LINKED TO OR PROVIDED BY OR THROUGH THE SERVICES AND/OR THE WEBSITE. INVESTNAIJA, ITS LICENSORS AND AGENTS EXPRESSLY DISCLAIM ALL WARRANTIES OF ANY KIND REGARDING THE SERVICES AND ALL INFORMATION, PRODUCTS AND OTHER CONTENT INCLUDED IN OR ACCESSIBLE FROM THE SERVICES, WHETHER EXPRESS OR IMPLIED. WITHOUT LIMITATION, INVESTNAIJA DISCLAIMS THE IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, AND NON-INFRINGEMENT. YOUR USE OF THE SERVICES AND ALL INFORMATION, PRODUCTS AND OTHER CONTENT (INCLUDING THAT OF THIRD PARTIES) INCLUDED IN OR ACCESSIBLE FROM OUR SITE IS AT YOUR SOLE RISK.
  4. INVESTNAIJA, ITS LICENSORS AND AGENTS DO NOT GUARANTEE THE ACCURACY OR COMPLETENESS OF ANY INFORMATION OR ANALYSIS ON THIS SERVICE. ACCORDINGLY, INVESTNAIJA WILL NOT BE LIABLE FOR THE ACCURACY OR RELIABILITY OF ANY DATA, INFORMATION OR CONTENT, FOR ANY SERVICES INTERRUPTIONS, OR FOR ANY FAILURE OR DELAY RESULTING FROM ANY ACTS OF FORCE MAJEURE OR ACTS THAT ARE OTHERWISE OUTSIDE OF INVESTNAIJA’S OR ITS LICENSORS’ OR AGENTS’ REASONABLE CONTROL, OR ANY INTERNET OR TELECOMMUNICATIONS FAILURE OR YOUR INABILITY TO ACCESS THE SERVICES OR THE WEBSITE. NOR CAN INVESTNAIJA OR ITS AFFILIATES, LICENSORS OR AGENTS GUARANTEE THE COMPLETE SECURITY OF THE SERVICES OR THE WEBSITE, THAT THE QUALITY OF ANY PRODUCTS, SERVICES, INFORMATION, OR OTHER MATERIAL PURCHASED OR OBTAINED BY YOU THROUGH THE SERVICES WILL MEET YOUR EXPECTATIONS OR THAT ANY ERRORS IN THE TECHNOLOGY WILL BE CORRECTED.
  5. YOU AGREE THAT ANY DOWNLOADS OF CONTENT OR MATERIALS RELATED TO THE SERVICES OR THE PLATFORM IS DONE AT YOUR OWN RISK AND YOU ARE SOLELY RESPONSIBLE FOR ANY DAMAGE TO YOUR COMPUTER/SYSTEM OR LOSS OF DATA THAT RESULTS FROM THE DOWNLOAD OF OR ACCESS TO ANY SUCH MATERIALS. IN ADDITION, WE CANNOT ALWAYS ANTICIPATE TECHNICAL OR OTHER DIFFICULTIES WITH THE SERVICES, EITHER PRESENTLY OR AS THEY EVOLVE; THE SERVICES MAY CONTAIN BUGS, ERRORS OR OTHER PROBLEMS, WHICH MAY RESULT IN LOSS OF DATA OR SETTINGS. IT IS THE SOLE RESPONSIBILITY OF THE USER TO ISOLATE SOFTWARE AND INFORMATION, EXECUTE ANTI-CONTAMINATION SOFTWARE, AND OTHERWISE TAKE STEPS SO THAT SOFTWARE OR INFORMATION, IF CONTAMINATED OR INFECTED, WILL NOT DAMAGE USER'S INFORMATION OR SYSTEM.
  6. SOME JURISDICTIONS DO NOT ALLOW THE EXCLUSION OF CERTAIN WARRANTIES; ACCORDINGLY, SOME OF THE ABOVE LIMITATIONS MAY NOT APPLY TO YOU. NEITHER INVESTNAIJA NOR ITS CONTENT PROVIDERS SHALL BE RESPONSIBLE FOR INVESTMENT AND OTHER FINANCIAL DECISIONS, DAMAGES, OR OTHER LOSSES RESULTING FROM USE OF THIS PLATFORM/WEBSITE.
  7. Limitation of Liability
  8. INVESTNAIJA, ITS LICENSORS AND AGENTS SHALL NOT IN ANY EVENT BE LIABLE FOR ANY SPECIAL, INCIDENTAL, INDIRECT OR CONSEQUENTIAL DAMAGES OF ANY KIND, OR FOR DAMAGES MEASURED BY LOST PROFITS, OR FOR DAMAGES FOR LOST OPPORTUNITY, LOSS OF GOODWILL, LOSS OF USE, LOSS OF DATA OR OTHER INTANGIBLE OR SPECULATIVE LOSSES, EVEN IF INVESTNAIJA HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES, ARISING, IN ANY WAY, OUT OF THE AVAILABILITY, USE, RELIANCE ON, OR INABILITY TO UTILIZE THIS SERVICE OR THE PLATFORM; THE COST OF SUBSTITUTE GOODS OR SERVICES; ANY PRODUCTS, DATA, INFORMATION OR SERVICES PURCHASED OR OBTAINED OR MESSAGES RECEIVED OR TRANSACTIONS ENTERED INTO, THROUGH OR FROM THE SERVICES; UNAUTHORIZED ACCESS TO OR ALTERATION OF YOUR TRANSMISSIONS OR DATA, STATEMENTS OR CONDUCT OF ANYONE RELATED TO THE SERVICES; THE PERFORMANCE OR NON-PERFORMANCE OF ANY THIRD PARTY ACCOUNT PROVIDER SITE, EVEN IF THE PROVIDER HAS BEEN PREVIOUSLY ADVISED OF THE POSSIBILITY OF SUCH DAMAGES; OR ANY PROVIDER OR THIRD PARTY WEBSITE, OR ANY OTHER MATTER RELATING TO THE SERVICES OR THE PLATFORM. BECAUSE SOME JURISDICTIONS DO NOT ALLOW THE EXCLUSION OR LIMITATION OF INCIDENTAL OR CONSEQUENTIAL DAMAGES, THE ABOVE EXCLUSIONS OF INCIDENTAL AND CONSEQUENTIAL DAMAGES MAY NOT APPLY TO YOU, BUT SHALL APPLY, IN ANY EVENT, TO THE MAXIMUM EXTENT POSSIBLE.
  9. THE SERVICES MAY BE AVAILABLE THROUGH A COMPATIBLE MOBILE DEVICE, INTERNET AND/OR NETWORK ACCESS AND MAY REQUIRE SOFTWARE. YOU AGREE THAT YOU ARE SOLELY RESPONSIBLE FOR THESE REQUIREMENTS, INCLUDING ANY APPLICABLE CHANGES, UPDATES AND FEES AS WELL AS THE TERMS OF YOUR AGREEMENT WITH YOUR MOBILE DEVICE AND TELECOMMUNICATIONS PROVIDER. INVESTNAIJA MAKES NO WARRANTIES OR REPRESENTATIONS OF ANY KIND, EXPRESS, STATUTORY OR IMPLIED AS TO: (i) THE AVAILABILITY OF TELECOMMUNICATION SERVICES FROM YOUR PROVIDER AND ACCESS TO THE SERVICES AT ANY TIME OR FROM ANY LOCATION; (ii) ANY LOSS, DAMAGE, OR OTHER SECURITY INTRUSION OF THE TELECOMMUNICATION SERVICES; AND (iii) ANY DISCLOSURE OF INFORMATION TO THIRD PARTIES OR FAILURE TO TRANSMIT ANY DATA, COMMUNICATIONS OR SETTINGS CONNECTED WITH THE SERVICES.
  10. Allocation of Risk

In addition to the limitations on liability contained elsewhere in these Terms and Conditions, you will not hold InvestNaija, its Affiliates, their respective partners, officers, employees, agents, licensors, distributors, and suppliers and/or Information Providers liable in any way for (a) any inaccuracy of, error or delay in, or omission of the Content, or (b) any loss or damage arising from or occasioned by i) any error or delay in the transmission of such Content, ii) interruption in any such Content due either to any negligent act or omission by any party to any “force majeure” (e.g., flood, extraordinary weather conditions, earthquake or other act of God, fire, war, insurrection, riot, labor dispute, accident, action of government, communications or power failure, equipment or software malfunction), or iii) to any other cause beyond the reasonable control of the Company, its Affiliates, their respective partners, officers, employees agents, licensors, distributors, and suppliers and/or Service and Information Provider, or iv) non-performance.

  1. Indemnification

You agree to indemnify, defend and hold us and any of our affiliates, licensors and agents, and all of their officers, directors, employees, agents, Information Providers and licensors harmless from and against any and all third-party claims, damages, liability and costs (including attorneys’ fees and costs) incurred by any of these parties that arise out of or are caused by: (i) your use of our Services and/or our Platform, (ii) your violation of this Agreement, (iii) your infringement of any intellectual property rights, (iv) access and/or use of, or interaction with the Service and/or Content (including, without limitation, the forums); or (v) any act, error, or omission of your use of an account or any user of your account. In the event that there are third party claims against you for which you properly seek damages from us under this Agreement, or we are subject to any claim for which we have the right to be indemnified by you, we reserve the right at our expense in the case of claims by third parties against you, and at your expense in the case of claims for which we have the right to be indemnified by you, to assume the exclusive defense and control of any such claim, and you agree that in any event no such claim can be settled without our written consent.

  1. Consent

By accepting this terms of use agreement, you consent to receiving relevant marketing information from InvestNaija, its related companies and selected partners and participating in market research about our products and services. We may contact you via various means including email, phone (e.g. SMS and MMS) and via data based messaging services. We may sometimes use other means such as websites, mobile apps, post or automated calls.

We may share your data with companies in our group, and selected partners with whom we work closely, so that they can send you relevant offers which might interest you. This could include partners in financial services, telecommunications, Information technology or other related sectors.

We may analyse your personal preferences, interests or behaviour so that we can send you customised communication that we think you might like.

  1. Ending Your Relationship with InvestNaija

This Agreement will continue to apply until terminated by either you or us as set out below. If you want to terminate your legal agreement with us, you may do so by closing your Account.

Please use the directions below to close your Account:

Email info@investnaija.com from the email address associated with your Account, indicating “REQUEST TO CLOSE ACCOUNT” in the subject line of the message. After confirming you are the Account owner we will proceed to close the account. We will however continue to retain such information as we are required by law to retain.

We reserve the right to terminate our Agreement with you (by providing an email notice of such termination): (i) if you have breached any provision of this Agreement (or have acted in a manner which clearly shows that you do not intend to, or are unable to comply with the provisions of this Agreement); (ii) if we believe we are required to do so by law (for example, where the provision of the Services to you is, or becomes, unlawful); (iii) if we no longer offer any of the Services you utilize; (iv) if you no longer agree to the terms and conditions of this Agreement; or (v) for any other reason or no reason, in our sole and absolute discretion. The termination of this Agreement will not affect any of our rights or your obligations arising under this Agreement prior to termination.

  1. Governing Laws

This Agreement, and any Services provided hereunder, will be governed exclusively by the laws of the Federal Republic of Nigeria.

  1. Arbitration

We shall make an effort to settle all disputes amicably. Any dispute arising out of this terms and conditions, which cannot be settled, by mutual agreement/negotiation within 1 (one) month shall be settled by the Arbitration and Conciliation Act, Cap A10, Laws of the Federal Republic of Nigeria. The arbitration shall be conducted by a single arbitrator jointly appointed by both of us (we and you), where both of us are unable to agree on the choice of an arbitrator, the arbitrator shall be appointed by the Chairman (for the time being) of the Chartered Institute of Arbitrators UK (Nigeria Branch). The findings of the arbitrator and subsequent award shall be binding on both of us. Each of us shall bear our respective costs in connection with the Arbitration. Venue for the arbitration shall be Lagos, Nigeria.

  1. Claims of Copyright and Trademark Infringement

If you believe that your intellectual property is being used on the website or the Platform in a way that constitutes copyright infringement, please provide us with the following information:

  • Identification of the copyrighted work claimed to have been infringed, or, if multiple copyrighted works at a single online site are covered by a single notification, a representative list of such works at that site;
  • Identification of the material that is claimed to be infringing or to be the subject of infringing activity and that is to be removed or access to which is to be disabled, and information reasonably sufficient to permit InvestNaija to locate the material on our website or the Platform;
  • Information reasonably sufficient to permit us to contact you, such as an address, telephone number, and, if available, an electronic mail address, if different from your registered profile with InvestNaija;
  • A statement that you have a good faith belief that use of the material in the manner complained of is not authorized by you, your agent, or the law; and
  • A statement that the information in the notification is accurate, and under penalty of perjury, that you are authorized to act on behalf of the owner of an exclusive right that is allegedly infringed.

The information specified above must be sent to the contact information as follows:

Attention: The Managing Director
InvestIN Limited
10, Bankole Oki Road
Ikoyi
Lagos
Email us at info@investnaija.com

  1. Change of Terms

We may revise this Agreement at any time, and therefore we suggest that you check this Agreement from time to time. We may notify you of any changes at the e-mail address associated with your Account and you agree to accept email communications, links to and/or our posting of any revised Agreement on our Platform, and you agree that any of these means of our communicating a change in the Agreement constitutes adequate notice to you. Your continued access or use of the Site/ App or any of the Services indicates your agreement to be bound by any such revisions.

  1. Not a Legal or Tax Advisor

We make managing your personal finances convenient and as streamlined as possible. However, neither we nor our Services give, offer or render tax or legal advice. Before making financial or investment decisions, we recommend that you contact an investment advisor, or tax or legal professional. InvestNaija, and its related companies, separately offer and provide investment advice.

  1. Waiver and Severability

We do not waive our rights by delaying or failing to exercise them at anytime. If any provision of this Agreement shall be determined to be invalid or unenforceable under any rule, law, or regulation of any governmental agency, local, state, or federal, the validity or enforceability of any other provision of this Agreement shall not be affected.

  1. Section Headings

Section headings in this Agreement are for convenience of reference only, and shall not govern the interpretation of any provision of this Agreement.

  1. English Language Controls

Any translation of this Agreement is provided for your convenience. The meanings of terms, conditions and representations herein are subject to definitions and interpretations in the English language. Any translation provided may not accurately represent the information in the original English.

  1. Entire Agreement

The Agreement, including the separate Privacy Policy and any other documents referred to herein, represents the entire understanding between both you and us regarding the Services (as defined herein) and the subject matter hereof and supersedes any prior statements or representations. In the event of a conflict between the terms of this Agreement and the terms of an exhibit, amendment, schedule, addendum or disclosure, the terms of the exhibit, amendment, schedule, addendum or disclosure shall prevail but, solely as to the subject matter herein.

Risk Disclosure

InvestNaija – Investment Notice

All Clients (existing and prospective) are advised to thoroughly read the investment risk warnings and disclosures contained in this document.

The following is a summary of the factors that can affect the value of your investments over time. Investing involves risk of loss that investors should be prepared to bear. The future value of your investments can increase or decrease, which means you may get less than your initial investment or more, according to the prevailing investment risk factors. Please note that past performance is not an indication of future performance. Please note that this is not an exhaustive list of the risks of investing.

This notice does not disclose, discuss, or explain all the risks involved in investing. Therefore, the Client undertakes and warrants to consult with own financial, legal and tax advisers prior to entering into any investment transaction.

Market Risk

Market risk is the risk of loss due to an adverse change in the market value of financial instruments. It is also known as undiversifiable risk because it affects all asset classes and is unpredictable. An investor can only mitigate this type of risk by hedging a portfolio. The key market parameters impacting the price of financial instruments are interest rates, in addition to equity, commodity and foreign exchange prices.

Interest Rate Risk

Fluctuation of interest rates is one of the biggest risk factors affecting fixed income securities. Generally, if interest rates fall, the value of the bond increases as the bond price rises, as the interest rate on the existing bond will be higher than the interest rate on newer bonds. On the other hand, when general interest rates rise the price of existing bonds is expected to fall.

Equity Risk

Equity securities include common stocks, preferred stocks, convertible securities and mutual funds that invest in these securities. Investors in equity securities may be exposed to a high level of risk because the prices of equity securities may fluctuate significantly in a short period of time. This may arise as a result of risk factors associated with the financial and operational performance of the issuing companies and/or with general stock market conditions and/or with domestic and international political and economic developments, amongst others.

Foreign Exchange Risk

Investing in securities that are priced in foreign currencies involves foreign currency or exchange rate risk. Securities that are priced in foreign currencies can lose or gain value depending on the positive or negative exchange rate fluctuations between the local currency and the foreign currency. Furthermore, foreign governments may impose currency exchange restrictions, which could limit the ability to buy and sell certain foreign investments. This could negatively impact the value of the foreign securities that are held by investors.

Fixed Income Risk

Fixed income securities include corporate bonds, municipal bonds, other debt instruments and mutual funds that invest in these securities. They are essentially a promise to pay regular or fixed interest and repay the principal at maturity of the investment. Fixed income investment risk differs by investment type and an associated range of risks such as interest rate risk, credit risk, inflation risk, foreign currency risk, etc.

Commodity Risk

Commodity risk is the risk that a business's financial performance or position will be adversely affected by fluctuations in the prices of commodities like Maize, Sorghum, Millet, Melon etc. Commodity Risk is the possibility that commodity price changes will cause financial losses for either commodity buyers or producers. Buyers face the risk that commodity prices will be higher than expected. Commodity risk is the threat of price fluctuations of a raw material. For commodity producers, a decrease in raw material prices is going to hurt, because they’re going to receive less money for the raw material that they’re providing. For commodity buyers—that is, the companies who rely on raw materials to produce their products—an increase in raw material prices is going to hurt, because they’re going to pay more than they had expected to pay.

Exchange Traded Fund Risk

Exchange Traded Funds (ETFs) are investment funds, traded like shares, which hold investment assets such as Shares, Commodities or Bonds. ETFs normally closely track the performance of a financial index, and as such their value can fluctuate based on market dictates. This means the investor may get back less than the initial value invested. Some ETFs rely on complex investment strategies, or hold riskier underlying assets to achieve investment objectives. The following are risks specifically associated with these types of investments:

  • The ETF may fail to accurately track the market segment or index that underlies its investment objectives;
  • The ETF may not be “actively” managed. As a result, the performance of an ETF may be lower than the performance of an actively managed fund;
  • Some ETFs employ leverage, which can magnify the risk of the underlying market segment or index;
  • The market price of ETF units may trade at a discount to its net asset value;
  • An active trading market for an ETF’s units may not develop or be maintained; and
  • There is no assurance that the requirements of the exchange necessary to maintain the listing of an ETF will continue to be met or remain unchanged.

Credit Risk

The probability that the issuer of the fixed income security will fail to honor its contractual payment obligations either by default or insolvency is called credit risk. Credit rating agencies give investors an idea of how much of a credit risk an issuer represents. If a company or government has a high credit rating, the credit risk tends to be low as there is a strong probability that the loan will be repaid. A lower rating however implies the opposite and therefore portends higher credit risk.

Inflation Risk

Inflation is the decline in the purchasing power of your money due to a general rise in prices. Inflation risk is the probability that the rate of return on your investment will be lower than the rate of inflation.

Foreign Investment Risk

Investments in foreign securities involve certain risks that differ from the risks of investing in domestic securities, some examples of which are:

  • Investments in foreign securities are subject to currency fluctuations
  • Foreign governments may impose investment restrictions
  • Adverse political, economic, social or other conditions in a foreign country may impact the saleability of the foreign securities
  • It is more difficult to obtain reliable information about some foreign securities; and
  • The costs of investing in some foreign markets may be higher than investing in domestic markets.

Liquidity Risk

Liquidity refers to the speed and ease with which an asset can be sold and converted into cash. Most securities can be sold easily and at a fair price if there is sufficient supply and demand. This means the security is liquid. In highly volatile markets, certain securities may become less liquid, which means they cannot be sold as quickly or easily. Some securities may be illiquid, which means that there is either limited or no supply and/or demand. Illiquidity may be because of legal or regulatory restrictions, the nature of the investment, or certain other features such as guarantees or a lack of buyers interested in the particular security or market. Difficulty in selling securities may result in a loss or reduced return for a Client.

Counterparty Risk

Counterparty risk is the likelihood or probability that one of those involved in a transaction might default on its contractual obligation. Counterparty risk can exist in credit, investment, and trading transactions. To mitigate against counterparty risk in trading transactions, all stock/share transactions in InvestIn shall be in the depository of Central Securities Clearing System Plc as stipulated by SEC

Political Risk

The government policies and political condition can greatly affect the price movements of financial markets. International relations, trade barriers, taxation policies, legislation, and administrative restrictions play an important role in guiding the price movements of financial markets. Any policies or decisions made by the government goes against or in favour of the concerned financial market then, the market would react the policies or decision which could affect the price movements of the financial instruments across multiple sectors in that market. It is advisable for the investors to watch out for the impact of government policies on the chosen instrument to mitigate political risk.

Anti-money Laundering Policy

INVESTNAIJA ANTI-MONEY LAUNDERING, COMBATING THE FINANCING OF TERRORISM AND COMBATING PROLIFERATION FINANCING (“AML/CFT/CPF”) POLICY STATEMENTS

InvestNaija is committed to compliance with AML/CFT/CPF Laws and Regulations for the protection of the interests of our collective stakeholders, that is, our Board, Senior Management, Employees, Clients, Partners, Vendors and Other Third parties. This commitment is shown through the formulation of the AML/CFT/CPF Policy which aligns with existing AML/CFT/CPF regulations. This Policy statement provides adequate guidance to assist all stakeholders against AML/CFT/CPF risk.

Objectives of the Policy Statements

The objectives of AML/CFT/CPF Policy Statements are as follows:

  1. To ensure that InvestNaija operations complies with AML/CFT/CPF laws and regulations (both local and international).
  2. To ensure that InvestNaija and its stakeholders are not victims of Money Laundering, Terrorism Financing and Proliferation Financing; and
  3. To clarify the preventive measures put in place by InvestNaija in fighting and campaigning against Money Laundering, Terrorism Financing and Proliferation Financing.

Regulatory Framework

The InvestNaija AML/CFT/CPF Policy Statements are formulated in compliance with the regulations outlined below:

  1. CBN AML/CFT/CPF Regulations 2022
  2. SEC AML/CFT/CPF Regulations 2022
  3. Money Laundering (Prohibition) Act 2022
  4. Terrorism (Prevention and Prohibition) Act 2022
  5. Banks and Other Financial Institutions Act 2022
  6. CBN Anti-Money Laundering and Combating the Financing of Terrorism (administrative sanctions) regulations, 2018
  7. Cybercrimes (Prohibition, Prevention, etc.
  8. ) Act, 2015.
  9. Special Control Unit against Money Laundering AML/CFT/CPF Regulations for Designated Non-Financial Businesses and Professions in Nigeria, 2013.
  10. Advance Fee Fraud and other Fraud Related Offences Act, 2006.
  11. Bank’s (recovery of Debt) and Financial Malpractices in Banks in Nigeria Act (as amended).
  12. Banks and other Financial Institutions Act, 1991 (as amended 2020).
  13. The Corrupt Practices and Other Related Offences Act, 2000.
  14. Economics and Financial Crimes Commission Act, 2004.
  15. Directive 2005/60/EC of the European Parliament and of the Council.
  16. Office of Foreign Asset Control (OFAC).
  17. USA PATRIOT Act
  18. FATF 40 Recommendations.

Policy Statements

  1. The Board of Directors of InvestNaija has an oversight function on the AML/CFT/CPF policies. The Board would designate the AML/CFT/CPF Chief Compliance Officer at the Management level to implement the AML/CFT/CPF Policy. The Board shall set an appropriate culture of AML/CTF/CPF by establishing a clear policy regarding the management of key AML/CTF/CPF risks.
  2. The Management Team is responsible for communicating and implementing AML/CTFCPF culture established by the Board. The Management Team shall ensure that there is adequate controls in place to mitigate against AML/CTF/CPF risks
  3. All Stakeholders – employees, clients, partners, vendors & third parties, etc. – are to acquaint themselves with the AML/CTF/CPF Policy as it relates to their respective dealings with InvestNaija.
  4. The Know Your Client (KYC) process is well established with the completion of online account opening forms that includes the verification of the Client’s Bank Verification Number at the on-boarding stage. InvestNaija shall conduct Enhanced Due Diligence (EDD) on clients classified as high-risk accounts in line with AML/CTF/CPF Regulations while Ongoing Due Diligence shall be conducted on all clients with the objective of updating information and transaction monitoring.
  5. InvestNaija shall conduct an effective risk assessment for all clients at the onboarding stage and at various stages of the client journey to ensure proper risk profiling.
  6. In InvestNaija, all payments for the investment in or redemption of products shall be through electronic transfer, bank cheque, draft or direct bank deposits by the client. InvestNaija, its employees and Investment Financial Advisors, shall not accept or give cash to any client. It should be noted that where a client (prospective or existing) deposits cash into the bank account of InvestNaija, on several occasions within a short period of time and the transactions appear to be linked, InvestNaija as required by regulation, shall file a suspicious transaction report to the NFIU/CBN/ SEC.
  7. InvestNaija shall comply promptly with all the requests received from the regulatory bodies with matter pertaining to AML/CFT/CPF.
  8. To ensure compliance with AML/CTF/CPF Regulations, InvestNaija shall render all AML AML/CTF/CPF regulatory reports to the regulatory bodies as and when required.

 Prohibited Businesses

InvestNaija shall not conduct business with Blacklisted Countries and Individuals, shell businesses, gambling establishments, casinos, lottery houses, dealers in arms and weapons, offering of services to unknown correspondent banking and high risk countries/individuals, opening of anonymous accounts and other predicated offences as listed in the AML/CFT/CPF Regulations. Our Clients are screened against approved sanction lists (both local and international) at the onboarding and transaction monitoring stages.

Other Controls

InvestNaija has other control measures in place to safeguard all stakeholders from financial crimes, money laundering, terrorism financing and proliferation financing. These include periodic Employees’ Regulatory Compliance Training, Record Keeping and Retention, Data Protection, Designation of Chief Compliance Officer, Board approved policies, and periodic audits / reviews in line with the AML/CFT/CPF Regulations 2022. InvestNaija will continually cooperate with all Regulators and Law Enforcement Agencies to ensure compliance with laws and the financial safety of its stakeholders.

Policy Statements Review

This document may change from time to time, to reflect changes in our practices and/or applicable law and regulation. If you have any queries or require further information or guidance, please contact us via the details below and we shall respond accordingly:

Chief Compliance Officer

InvestIN Limited

10, Bankole Oki Road

Ikoyi, Lagos.

Nigeria

Tel: +234 (0) 700 468 3786 2452

Email: info@investnaija.com