Thank you for visiting NASD PLC and using any of our associated platforms and subsidiaries- (Our Site or Platforms App, VentureRamp, NASD Trading Platform, NASD Private Market, NASD Cooperative Exchange, NASD Services Limited and NASD Technologies. NASD PLC is an Over the Counter Securities Exchange licensed by the Securities and Exchange Commission and is a central infrastructure provider of liquidity and transparency in the capital market. Throughout this document, “we”, “us”, “our” and “ours” refer to NASD PLC and its associated platforms and subsidiaries. “NASD” also has the same meaning described above. Site refers to the website or associated platforms of NASD PLC.
YOUR PRIVACY IS OUR PRIORITY
Personal Identifiable Information we collect directly from you
We may collect personal identifiable information from you in a variety of ways, including, but not limited to, when you visit our site, register on the site, submit membership or issuer registration documents, subscribe to our newsletter, and in connection with other activities, services, features or resources we make available on our Site. You may be asked for, as appropriate the following information:
a. Identity and contact information: includes but not limited to information such as; Name, address, office address, signatures, biometric data, date of birth, nationality, citizenship, country of birth, copies of identity cards (“ID”), contact details, email ID, professional association details such as of the Chartered Institute of Stockbrokers, etc.
b. Financial details/circumstances: includes but not limited to; Trading account details, Trading account number, Clearing House Number, bank account details, credit/debit card details (including card brand, expiration date), bank verification number (BVN), employment/occupational information, risk profile, financial objectives, financial knowledge and experience, preferences and any other information to assess the suitability of our products to you. We shall verify your BVN data and by your use of the relevant Services, you consent to the validation of your BVN data. We store only very limited, if any, financial information that we collect. Otherwise, all financial information is stored by our payment processors with whom we have entered separate agreements.
c. Other Personal Information
• We may also ask you for information which could identify you when you report a problem with any of our platforms or services, personal information contained in your correspondence with us (such as e-mail, log files and screenshots).
• Responses to surveys that we might ask you to complete for research and/or improvement purposes.
• Information relating to transactions or trades you carry out through any of our platforms.
The information above may be provided directly by you or by somebody designated by you to set up and administer your account with NASD. If you are unable to or choose not to provide us with the personal information required for the performance of a service to you, we may be unable to provide you with a particular service.
Information We Collect Automatically
As you navigate through and interact with the Site, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns. We use this information for our internal analytics purposes and to improve the quality and relevance of the Site to our users. Examples of this information include:
a. Details of your use, including related traffic data, location data, logs, age, gender, market segment, interests (e.g., what securities and products you trade), and other communication data and the resources that you access and use on any of our Platforms.
b. Data related to trading activities such as billing information, trader IDs, and statistical and other aggregated data derived from your use of any of our Platforms.
c. Information about your device, computer and network connection, including your IP address, operating system, hardware version, device settings, battery and signal strength, and browser type.
d. Device locations, including specific geographic locations, such as through GPS, Bluetooth, or WIFI signals. e. Connection information such as the name of your mobile operator or ISP, language and time zone, and mobile phone number.
Information We Obtain from Third Parties
From time to time, we may receive personal information about you from third party sources, subject to a written contract between NASD and the third party. The types of information we may collect from third parties include your name, contact details and trading identification and we use the information we receive from these third parties to allow you to use our services and maintain and improve the accuracy of the records we hold about you.
Who Is Responsible for Your Personal Information?
Why does NASD need to collect and store personal data?
For us to provide you with a service or carry out a specific task, we need to collect personal data. In any event, we are committed to ensuring that the information we collect, and use is appropriate for this purpose, and does not constitute an invasion of your privacy.
How we use collected information
NASD may collect and use your personal information for the following purposes:
• To personalize your experience: We may use information in the aggregate to understand how you use the services and resources provided on our Site.
• Respond to your queries and feedback (for example, if you’ve asked a question or submitted feedback via the site)
• To improve our Site: We may use feedback you provide to improve our products and services.
• Developing and providing trading facilities, products or services (whether made available by us or through us)
• assessing and processing applications, instructions or requests from you;
• communicating with you, including providing you with updates on changes to products and services (whether made available by us or through us) including any additions, expansions, suspensions and replacements of or to such products, services and facilities and their terms and conditions, in line with your communications preferences;
• Protect our business, reputation, resources and equipment, manage network and information security and prevent and detect fraud, dishonesty and other crimes (for example, to prevent someone trying to steal your identity);
• providing access to restricted pages or contents of our Site or Platforms;
• managing our infrastructure and business operations and complying with internal policies and procedures;
• responding to queries or feedback; and addressing or investigating any complaints, claims or disputes;
• verifying your identity for the purposes of providing products or services;
• conducting credit checks, screenings or due diligence checks as may be required under applicable law, regulation or directive;
• enforcing obligations owed to us;
• monitoring products and services provided by or made available through us;
• complying with obligations and requirements imposed by us from time to time by any credit bureau or credit information sharing services of which we are a member or subscriber; and creating and maintaining credit and risk related models;
• financial reporting, regulatory reporting, management reporting, risk management (including monitoring credit exposures), audit and record keeping purposes;
• enabling any actual or proposed assignee or transferee, participant or sub-participant of NASD’s rights or obligations to evaluate any proposed transaction; or in the event of a merger, sale of NASD’s assets, financing, or acquisition of all or a portion of our business to another company, subject to execution of a confidentiality agreement with such third party; and/or
• seeking professional advice, including legal advice.
We also use information to meet our compliance obligations, to comply with other laws and regulations and to share with regulators and other authorities that NASD is subject to. This may include using it to help detect or prevent crime (including terrorism financing, money laundering and other financial crimes). We’ll only do this on the basis that it’s needed to comply with a legal obligation, it’s in our legitimate interests and that of others or to prevent or detect unlawful acts.
How we protect your information
The security and confidentiality of your personal information matters to us. We adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure, or destruction of your personal information. We require our staff and any third parties who carry out any work on our behalf to comply with appropriate compliance standards including obligations to protect any information and applying appropriate security measures for the use and transfer of information. Even so, despite our reasonable efforts, no security measure is ever perfect or impenetrable. We cannot guarantee the security of your personal information transmitted to our Site. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on any of our Sites.
Will NASD share my personal data with anyone else?
NASD may pass your personal data to third-party service providers contracted by us. Any third parties that we may share your personal data with is under an obligation to secure your details and use them only to fulfil the service for which they were contracted. When they no longer need your details to fulfil this service, the data will be disposed in line with NASD’s procedures and regulatory requirements.
NASD will process and store personal data in accordance with our retention policy.
Your rights as a data subject
At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:
• Right of access – you have the right to access the information we hold about you and how we process it.
• Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
• Right to be 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 of portability – you have the right to have the data we hold about you transferred to another organisation.
• Right to object – you have the right to object to certain types of processing and request that we restrict our processing in some circumstances.
• Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling. You will not have to pay a fee to access your personal data (or to exercise any of the above rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. We endeavour to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated. If you wish to exercise any of the rights set out above, please reach us at the ‘How to Contact Us’ portion of this Policy.
Your acceptance of these terms
By using this Site, you signify your acceptance of this Policy and terms of service. If you do not agree to this Policy, please do not use our Site. Your continued use of the Site following the posting of changes to this policy will be deemed your acceptance of those changes.
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