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Privacy Policy

FIRST ICON MUTUAL CAPITAL LIMITED
Effective Date: 08.05.2025

 

  1. Introduction

FIRST ICON MUTUAL CAPITAL LIMITED (“the Company”, “we”, “our”, or “us”) is committed to respecting your privacy and safeguarding your personal data. This Privacy Policy outlines how we collect, process, use, store, share, and protect personal information in the course of our capital market, financial advisory, and investment management activities.

 

  1. Scope

This Policy applies to all personal data processed by FIRST ICON MUTUAL CAPITAL LIMITED, whether from clients, investors, employees, vendors, partners, or other stakeholders, through our physical, digital, and online platforms.

 

  1. Personal Data We Collect

We may collect the following categories of personal data:

  • Identification Data: Full name, gender, date of birth, nationality, NIN, BVN, passport number, or other government-issued IDs.
  • Contact Data: Phone number, email address, residential and business addresses.
  • Financial Data: Bank details, payment history, investment records, creditworthiness, and tax identification numbers.
  • Professional/Employment Data: Occupation, employer, job title, qualifications.
  • Transaction Data: Securities transactions, investment portfolio details, and related capital market activities.
  • Digital Data: IP address, browser type, cookies, geolocation, and usage data from our website and portals.

 

 

  1. Legal Basis for Processing

We process personal data based on one or more of the following legal grounds:

  • Consent of the data subject.
  • Performance of a contract or pre-contractual obligations.
  • Compliance with legal or regulatory obligations (SEC, NDPC, CBN, FCCPC, AML/CFT laws).
  • Legitimate interests pursued by the Company.
  • Protection of vital interests of the data subject.

 

  1. Purposes of Data Processing

We collect and process personal data for purposes including:

  • Onboarding and verifying clients (KYC/AML compliance).
  • Capital market transactions, investment management, and financial advisory services.
  • Loan, credit, and securities processing.
  • Reporting to regulators (SEC, NDPC, CBN, FCCPC, etc.).
  • Employment and human resource management.
  • Fraud detection, internal audits, and risk management.
  • Marketing, research, and client relationship management.
  • Enhancing our digital platforms and service delivery.

 

  1. Data Sharing & Third-Party Disclosure

Personal data may be shared with:

  • Regulators: NDPC, SEC, CBN, FCCPC, law enforcement agencies.
  • Service Providers: IT support, cloud storage, payment processors, and consultants.
  • Business Partners: Capital market operators and financial institutions.
  • Credit Bureaus & Auditors.

We do not sell or rent personal data to third parties.

 

  1. Data Subject Rights

In line with the NDP Act 2023, you have the following rights:

  • Right to be informed about processing activities.
  • Right of access to personal data.
  • Right to rectification of inaccurate or incomplete data.
  • Right to erasure (“right to be forgotten”).
  • Right to restrict processing.
  • Right to object to processing (including marketing).
  • Right to data portability.
  • Right to lodge complaints with the Nigeria Data Protection Commission (NDPC).

 

  1. Data Security & Retention

We implement technical and organizational measures to ensure the confidentiality, integrity, and availability of personal data.

Data is retained only for as long as necessary to fulfil contractual obligations, meet regulatory requirements, or pursue legitimate business interests.

 

  1. International Data Transfers

Where personal data is transferred outside Nigeria, FIRST ICON MUTUAL CAPITAL LIMITED ensures adequate safeguards in compliance with NDP Act 2023 and GAID 2025 (such as Standard Contractual Clauses or adequacy decisions).

 

  1. Use of Cookies & Digital Platforms

Our website and digital platforms may use cookies, tracking technologies, and analytics tools to personalize services, monitor usage, and improve performance. Users may opt-out or adjust cookie preferences via browser settings.

 

 

  1. Breach Notification

In case of a data breach that poses a risk to individual rights and freedoms, FIRST ICON MUTUAL CAPITAL LIMITED will notify the NDPC within 72 hours and affected individuals promptly, in line with NDP Act 2023 and GAID 2025.

 

  1. Contact Information

For questions, complaints, or to exercise your data rights, please contact:

Data Protection Officer (DPO)
FIRST ICON MUTUAL CAPITAL LIMITED

29 Parakou Crescent, Wuse 2, Abuja, Nigeria.
Email: info@firsticon.com
Phone: +2348133779704

 

  1. Policy Review & Updates

This Privacy Policy will be reviewed periodically and updated where necessary to reflect changes in regulatory requirements or business practices. Updated versions will be made available on our official website and digital platforms.