Data Privacy and Protection Policy

What is Data Privacy and Protection Policy ?

This policy outlines how MBO Capital Management (“MCM”) collects, uses, shares, retains, and protects personal data from individuals and corporate entities it interacts with. It ensures compliance with Nigeria’s Data Protection Regulation (NDPR) and is overseen by the company’s Data Protection Officer.

The Information That We Collect and Where We Get It From

MCM collects personal data directly from data subjects through:

  • Investment initiation and portfolio reviews

  • Financial advisory engagements

  • Recruitment applications and payroll records

  • Vendor registration and visitor logs

  • IT services like email creation

It also gathers data via its website (device info, IP address, browser type) and from third-party sources such as background check providers.

How We Use, Retain, and Share the Information Collected with Third Parties

MCM uses personal data to:

  • Make investment decisions and review company performance

  • Deliver client services and manage business operations

  • Process job applications and comply with legal obligations

  • Prevent fraud and respond to complaints

Data may be shared with affiliated entities, service providers, regulators, and other relevant third parties. Retention depends on legal requirements and the purpose of data collection.

How We Store, Protect, and Secure Information Received from Data Subjects

MCM employs strict physical and digital safeguards:

  • Paper records are securely stored and shredded when no longer needed

  • Electronic data is protected by strong passwords, encryption, firewalls, and secure servers

  • Regular backups and access controls are enforced

  • Staff are trained to handle data responsibly and avoid unauthorized access

The Choices and Rights of Data Subjects

Data subjects have rights to:

  • Access and correct their personal data

  • Request deletion or restrict processing in certain cases

  • Receive their data in a machine-readable format

  • Withdraw consent and lodge complaints with the relevant authority

 
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