Privacy Policy
Last updated: April 2026
1. Introduction
FSDH Capital Limited ("FSDH Capital", "we", "us", or "our") is committed to protecting the privacy and personal data of our investors, clients, and users in compliance with the Nigeria Data Protection Regulation (NDPR) 2019 and the Nigeria Data Protection Act (NDPA) 2023.
This Privacy Policy explains how we collect, use, store, and protect your personal information when you interact with our investment management platform.
2. Personal Data We Collect
We collect the following categories of personal data:
Identity Information
Full name, investor type (individual/corporate/institutional), Bank Verification Number (BVN), Tax Identification Number (TIN), RC Number (for corporates).
Contact Information
Email address, phone number, physical address.
Financial Information
Bank name, account number, account name, investment commitments, face values, transaction history.
Technical Information
IP address, browser type, access timestamps (collected automatically for security and audit purposes).
3. Purpose of Data Processing
We process your personal data for the following purposes:
- Managing your investment portfolio and commitments
- Generating allocation and confirmation notices
- Sending transaction-related communications via email
- Compliance with regulatory requirements (SEC, CBN, FIRS)
- Know Your Customer (KYC) verification
- Maintaining audit trails for financial accountability
- Fraud prevention and security monitoring
4. Legal Basis for Processing
We process your personal data based on:
- Consent: You have given explicit consent for us to process your data
- Contractual necessity: Processing is necessary for the performance of your investment agreement
- Legal obligation: Processing is required to comply with Nigerian financial regulations
- Legitimate interest: Processing is necessary for fraud prevention and platform security
5. Data Storage & Security
Your data is stored securely using industry-standard encryption and access controls, ensuring that data access is restricted to authorized personnel only.
- Data is encrypted at rest and in transit (TLS 1.2+)
- Access is controlled via role-based authentication
- All data access is logged in our audit trail
- Regular security reviews are conducted
6. Data Retention
We retain your personal data for as long as your investment relationship is active, plus an additional period as required by Nigerian financial regulations (minimum 6 years after the last transaction). After this period, your data will be securely deleted or anonymized.
7. Your Rights
Under the NDPR and NDPA, you have the right to:
Right of Access
Request a copy of all personal data we hold about you
Right to Rectification
Request correction of inaccurate or incomplete data
Right to Erasure
Request deletion of your personal data (subject to regulatory retention requirements)
Right to Data Portability
Receive your data in a structured, machine-readable format
Right to Object
Object to the processing of your personal data
Right to Withdraw Consent
Withdraw your consent at any time without affecting prior processing
To exercise any of these rights, please contact your account manager or email us at privacy@fsdhcapital.com.
8. Third-Party Data Sharing
We do not sell your personal data. We may share your data with:
- Regulatory bodies (SEC, CBN, FIRS) as required by law
- Email service providers for transactional communications
- Cloud infrastructure providers for secure data hosting
All third-party processors are bound by data processing agreements that ensure NDPR compliance.
9. Contact Us
For questions about this Privacy Policy or to exercise your data rights, contact:
Data Protection Officer
FSDH Capital Limited
Email: privacy@fsdhcapital.com
Web: www.fsdhcapital.com