Privacy Policy

This Privacy notice describes our policies and procedures on the collection, use and disclosure of your information. It also tells you about privacy rights. By ‘your information’, we mean any information provided to us by you or a third party.

Definitions:

This privacy notice (the “Privacy Notice” or “this notice”) relates to all personal information-processing activities carried out by Fidelity Pension Managers. Fidelity Pension Managers is a data controller of personal information collected and processed for our business (including the services that we provide). In this notice, references to: You means the individual or business customer or partner (which includes suppliers or other organisations we do business with. Company (either “the Company”, “We”, “Us” or “Our” in this Agreement) refers to Fidelity Pension Managers Personal Information is any information that relates to an identified or identifiable individual.

Consent:

We will provide you with our privacy policy whenever we are collecting your personal information irrespective of the medium used. For the electronic medium, your consent obtained by asking you to click on a button to show acknowledgement of the policy. On the other hand, for your personal information collected via a paper document, we will require you to sign off on the document showing your understanding of our privacy policy.

Information Collected:

While using Our Service, We may ask you to provide us with certain personally identifiable information that can be used to contact or identify you which may include: your name, gender, residential address, telephone number, e-mail address, bank verification number (BVN), etc . Personally identifiable information may include, but is not limited to the following:

• Information you give to us through our various touchpoints (i.e. website, proposal and claim forms, mobile app, emails, telephone calls etc.).
• Information that we gather from publicly available sources, such as the press, company registers and online search engines.
• Information that we receive from third parties – third parties who provide services to you or us, government agencies, and other.
• Information that we learn about you when you use our services.
• Information that we gather from the technology which you use to access our services (for example location data from your mobile phone, or an IP address or telephone number) and how you use it (for example pattern recognition).

Information Usage:

When you provide your information to us, we may use the information we collect in the following ways:

• To manage our relationship with you or your business.
• To provide and maintain our Service, including monitoring the usage of our Service.
• To manage your Account: to manage your registration as a user of the Service. The Personal data you provide can give you access to different functionalities of the Service that are available to you as a registered user.
• For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services you have purchased or of any other contract with us through the Service.
• To contact you: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to our service and/or products, such as sending you information when you sign up or change tariffs, service announcements and administrative messages.
• To provide you with news, special offers and general information about other services and events that we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information.
• To manage your requests and complaints: To attend and manage your requests and complaints to us.

Information sharing:

When you provide your information to us, we will share your information based on the following requirements:

Business Transactions:

If Fidelity Pension Managers is involved in a merger, acquisition or asset sale, Your Personal data may be transferred. We will provide notice before Your Personal data is transferred and becomes subject to a different Privacy Policy.

Law enforcement:

Under certain circumstances, the company may be required to disclose your personal data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other requirements:

The Company may disclose Your Personal data in the good faith belief that such action is necessary to the following:

• Comply with a legal obligation
• Protect and defend the rights or property of the Company
• Prevent or investigate possible wrongdoing in connection with the Service
• Protect against legal liability
• Consent is provided
• Required by court orders or legal process
• Violation of any part of our Privacy Notice
• Third parties conducting business on our behalf. These parties process such information for specific and limited purposes, in compliance with the privacy notice and any other appropriate confidentiality and security measures

Sensitive personal data (also known as special categories of personal data) make up information we collect from you. In particular, we may process, biometric data, for services that require it. We process such sensitive personal data when you have provided your consent or otherwise required by applicable law and these information will be collected and processed only for the particular purposes and activities for which the information is provided.

Transfer of Your Personal data:

Your information, including Personal data, is processed at the company’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of your state. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer. Fidelity Pension Managers will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

Information Retention:

Fidelity Pension Managers will retain your Personal data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your personal data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies. We will retain and use Your personal data to the extent necessary to comply with our contractual obligations with You and once our contract with you has come to an end (e.g. following retirement or closure of your account), we will only3 retain your personal data for a period that is, depending on the type of personal data, and the purposes for which we hold that information. The Company will also retain usage data for internal analysis purposes. Usage data is generally retained for a shorter period, except when this data is used to strengthen the security or to improve the functionality of our service, or we are legally obligated to retain this data for longer time periods.

Your Rights:

Subject to applicable laws, Nigeria data protection regulations, you have the following rights:

• To request a copy of the personal data processed in relation to you
• To request that we correct your personal data
• To request us to delete your personal data, for example if we no longer have a valid reason to process it
• To object to how we process your personal data
• To restrict how your personal data is processed in certain cases, such as when the accuracy of your Personal data is contested
• To request a copy of the personal data you have given to us in a machine readable format

Cookies Policy:

Cookies are small text files containing information that your computer or mobile device downloads when you visit a website, return to websites – or visit websites that use the same cookies – they recognize these cookies and therefore your browsing device. We do not store confidential or sensitive personal information in cookies. To find out more about how we use cookies and what benefits they bring, please take a few moments to read this Cookie Policy. Usage Data collected when using the Service may include information such as Your Device’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

Why and How We Use Cookies on Our Website:

We use cookies to improve your online activity session by making navigation easier and providing important security features. When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data. We may also collect information that your browser sends whenever you visit our Service or when you access the Service by or through a mobile device. We use Cookies to track the activity on Our Service and store certain information We use Google Analytics to collect the following types of information from users who have JavaScript enabled on their browser:

• Web browser used – software manufacturer, and version number
• Operating system
• Screen colours
• JavaScript support
• Flash version
• Screen resolution
• Network location and IP address
• Geographic data
• Hostname
• Connection bandwidth
• Time of visit
• Pages visited and dwell time on these pages
• Referring site
• The referring website URL
• Search engine query used

Cookie Category :

Some cookies are required to make our website work, but we need your consent to use others. The cookie categories are:

Category	Description
Strictly Necessary	These cookies are required to run our website, to keep it secure, and to obey regulations that apply to us. These cookies are essential even if customer declines to the collection of cookies.
Functional	These cookies remember your region or country, language, accessibility options and your settings.
Performance	These cookies tell us how customers use our website. We study and profile this data to help us improve our products and performance.
Marketing	These cookies help us decide which products, services and offers may be relevant for you. We may use this data to tailor the ads you see on our own and other websites and apps.

We do not use third party cookies on our website.

What are your choices regarding cookies?:

You can choose to have your computer warn you each time a cookie is collected, or you can choose to turn off all cookies. Since browsers differ, we recommend that you access the Help Menu to learn the correct way to modify your cookies. If you turn your cookies off, some of the features that make your site, experience more efficient may not function properly.

Where you can find more information about cookies:

You can learn more about cookies at https://www.allaboutcookies.org/

Security:

We will always hold your information securely. To prevent unauthorized access to your information, we have implemented strong controls and security safeguards at the technical and operational levels. This site uses Secure Sockets Layer/Transport Layer Security (SSL/TLS) to ensure secure transmission of your personal data. You should see the padlock symbol in your URL address bar once successfully logged into the platform. The URL address will also start with https:// depicting a secure webpage. SSL applies encryption between two points such as your PC and the connecting server. To ensure that data is unreadable during transmission, encrypted data transmits during a session and decrypted at the receiving end Your information is confidential to any third party except under legal and/or regulatory conditions. You have the right to request sight of, and copies of all information we keep on you, if such requests made comply with the Freedom of Information Act and other relevant enactments. While Fidelity Pension Managers is responsible for safeguarding the information entrusted to us, your role in fulfilling confidentiality duties includes, but is not limited to, adopting and enforcing appropriate security measures such as non-sharing of passwords and other platform login details, adherence with physical security protocols on our premises, dealing with only authorized officers of the Agency.

Children’s Privacy:

Our Service does not address children. We do not knowingly collect personally identifiable information from a minor. If you are a parent or guardian and you are aware that your child has provided us with Personal data, please contact us. If we become aware that we have collected Personal data from anyone that is a child without verification of parental consent, we take steps to remove that information from our servers.

Changes to This Privacy Notice:

Based on the changing nature of privacy laws, user needs and our business, this privacy notice is subject to changes from time to time. Communications on changes made to the privacy policy will be on our website and this will be effective as soon as published. Accordingly, we encourage periodic reviews of this Privacy Notice for awareness of any changes that may have occurred.

Governing Law:

This Privacy Policy is made pursuant to the Nigeria Data Protection Regulation (2019) or any other relevant Nigerian laws, regulations or international conventions applicable to Nigeria. Where any provision of this Policy is inconsistent with a law, regulation or convention, such provision shall be subject to the overriding law, regulation or convention. Contact us : Fidelity Pension Managers strives to resolve your privacy complaints and concerns as quickly as possible. If you have a concern, complaint or questions regarding this Privacy Notice, you may contact us through the following means:

Our Address

For more information contact us. Plot 688, Amodu Tijani Street, Off Sanusi Fafunwa, Victoria Island, Lagos.
info@fidelitypensionmanagers.com
02018889722