1.  Introduction

The Argentil Group and all its constituent entities (collectively referred to as “Argentil”, “we”, “us”, or “our”) are committed to protecting the privacy and personal data of all individuals who interact with our services. This Privacy Policy describes how we collect, use, store, and protect your personal data in accordance with applicable law.

This policy is issued in compliance with the Nigeria Data Protection Act (NDPA) 2023, the Nigeria Data Protection Regulation (NDPR) 2019, and applicable provisions of the General Data Protection Regulation (GDPR) (EU) 2016/679.

2.  Scope

This Privacy Policy applies to all personal data collected, processed, or stored by any Argentil entity in connection with:

• Use of our websites, portals, and digital platforms
• Engagement with our investment, advisory, and asset management services
• Submission of deal enquiries, registration forms, or contact requests
• Any communication with our staff, agents, or representatives

3.  Personal Information We Collect

3.1  Types of Personal Data

We may collect and process the following categories of personal data:

• Identity data: name, date of birth, nationality, government-issued ID
• Contact data: email address, phone number, postal address
• Financial data: bank details, investment history, income and asset information
• Business data: company name, role, deal information, transaction records
• Technical data: IP address, browser type, cookies, usage data from our platforms
• Communication data: records of correspondence with our teams

3.2  How We Collect Information

We collect information in two ways:

(a)  Directly Provided Data — when you fill out forms, register for services, submit a deal, or communicate with us directly.

(b)  User Authorised Data — where permitted by your account or privacy settings on third-party platforms (e.g. social media integrations or location data from your device).

We do not collect or process sensitive personal data unless you voluntarily provide it and give your explicit consent.

4.  How We Use Your Data

We use personal data for the following purposes:

• Providing, managing, and improving our financial and investment services
• Evaluating deal submissions and conducting due diligence
• Compliance with regulatory and legal obligations (including AML/KYC requirements)
• Communicating with you regarding our services, products, and opportunities
• Internal research, reporting, and analytics
• Fraud prevention, risk management, and security

5.  Data Retention

We retain personal data only for as long as necessary to fulfil the purposes outlined in this policy. In compliance with Securities and Exchange Commission (SEC) and Central Bank of Nigeria (CBN) regulations, financial transaction records and client identification data are retained for a minimum of seven (7) years following the termination of a business relationship.

Data may be retained beyond this period where required by law, to resolve disputes, or to prevent fraud.

6.  Data Sharing & Third Parties

We do not sell or rent your personal data to third parties. We may share your information with:

• Professional advisors (lawyers, auditors, tax advisors)
• Regulatory authorities (SEC, CBN, NDPC, law enforcement) where legally required
• IT service providers supporting our infrastructure (cloud storage, hosting, identity management)
• Affiliated entities within the Argentil Group, where relevant to service delivery

All third-party service providers are contractually required to maintain appropriate data protection standards consistent with applicable law.

7.  Your Rights

As a data subject, you have the following rights:

• Right of access — to request a copy of the personal data we hold about you
• Right to rectification — to correct inaccurate or incomplete data
• Right to erasure — to request deletion of your data, subject to legal obligations
• Right to object — to object to certain processing activities
• Right to data portability — to receive your data in a portable format
• Right to complain — to lodge a complaint with the Nigeria Data Protection Commission (NDPC) or another relevant authority

To exercise any of these rights, please contact us using the details in Section 10.

8.  Cookies

Our digital platforms use cookies to improve your browsing experience and to personalise content. Cookies are small files stored on your device. You may disable cookies through your browser settings; however, this may affect functionality.

We use session cookies (which expire when you close your browser) and, where applicable, persistent cookies to remember your preferences. We do not use cookies to collect information that identifies you personally beyond what you have provided directly.

9.  Data Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, destruction, or disclosure. These include access controls, encryption, and staff training on data handling.

In the event of a data breach that poses a risk to your rights, we will notify you and the relevant regulatory authority in accordance with applicable law.