Privacy Notice
Privacy information for the Finfora Partners Website and restricted Partners Portal.
Website Privacy Policy
Effective Date: 30 September 2026 | Last Updated: 30 September 2026
1. Who We Are
Finfora Partners LLP, with registered office at 12 Oluseyi Aweda Street, Magodo, Lagos State, is the entity responsible for determining the purposes and means of processing personal data collected through the Website, subject to the role it may assume for particular processing activities.
2. Scope
This Policy applies to personal data collected through finforapartners.com, Website forms, communications and related public-facing digital services. It does not replace the Portal Privacy Notice, which applies to Partner data processed through the Partners Portal.
3. Personal Data We May Collect
Depending on your interaction with us, we may collect name, email address, telephone number, correspondence, enquiry information, organisation or professional information, account-related information, technical information, IP address, browser/device information, Website usage information, cookie identifiers and other information you voluntarily provide.
4. Sources
We may collect data directly from you, automatically from your device or browser, from service providers acting on our behalf, or from other lawful sources where necessary for legitimate business, contractual, legal or regulatory purposes.
5. Purposes
We process personal data to operate and secure the Website; respond to enquiries; communicate with users; administer prospective or existing Partner relationships; provide requested information; improve Website functionality; prevent fraud and abuse; maintain records; comply with legal obligations; establish, exercise or defend legal claims; and perform other purposes disclosed at collection.
6. Lawful Bases
Depending on the circumstances, processing may be based on performance of a contract or steps requested before entering a contract, compliance with a legal obligation, legitimate interests that are not overridden by the rights and interests of the data subject, consent where required, or another lawful basis recognised by applicable data-protection law.
7. Marketing
Where marketing communications require consent, Finfora will seek the appropriate consent and provide a practical means of withdrawing it. Withdrawal of marketing consent does not affect processing lawfully carried out before withdrawal.
8. Disclosure
Personal data may be disclosed to employees and authorised officers, technology and hosting providers, payment providers, professional advisers, auditors, insurers, regulators, law-enforcement authorities and other service providers where disclosure is lawful and necessary for the relevant purpose.
9. Processors
Where a third party processes personal data on Finfora’s behalf, Finfora will take reasonable steps to ensure that the processing is governed by appropriate contractual and security controls and is limited to authorised purposes.
10. International Transfers
Where personal data is transferred outside Nigeria, Finfora will apply the safeguards and lawful transfer mechanisms required by applicable data-protection law.
11. Retention
Personal data will be retained only for as long as reasonably necessary for the purpose for which it was collected, to meet contractual and legal obligations, resolve disputes, establish or defend claims, maintain appropriate records, or otherwise as permitted by law. Specific retention periods may be set out in Finfora’s internal retention schedule.
12. Security
Finfora will implement reasonable technical and organisational measures appropriate to the risks of processing, including access controls, authentication, confidentiality controls, secure configuration, monitoring and incident-response measures.
13. Data Subject Rights
Subject to applicable legal limitations, data subjects may have rights to request access to personal data, rectification of inaccurate data, erasure, restriction of processing, objection, portability and other rights provided by applicable law. Requests should be sent to admin@finforapartners.com.
14. Complaints
A data subject may contact Finfora first to seek resolution of a privacy concern. Nothing in this Policy prevents a data subject from exercising statutory rights or making a complaint to the Nigeria Data Protection Commission.
15. Children
The Website is not intended to knowingly collect personal data from children except where permitted by law and with the required safeguards and consents.
16. Automated Decision-Making
Finfora will not subject data subjects to solely automated decisions producing legal or similarly significant effects except where permitted by law and subject to applicable safeguards.
17. Cookies
Cookies and similar technologies are governed by the Cookie Notice.
18. Changes
Finfora may update this Policy from time to time. The updated version will be published with a revised effective date.
19. Contact
Privacy enquiries and rights requests: admin@finforapartners.com.
Portal Privacy Notice
Effective Date: 30 September 2026 | Last Updated: 30 September 2026
1. Scope
This Notice applies to personal data processed through the Partners Portal, including information relating to Partner onboarding, membership administration, dues, investment contributions, investment records, communications, statements, security and support.
2. Categories of Data
Finfora may process identity and contact information; membership information; contribution and dues records; investment and transaction information; payment and bank-related information where required; correspondence; login and authentication data; device and security logs; and other information necessary to administer the Partner relationship.
3. Purpose
Processing is undertaken to admit and administer Partners; perform the Partnership/Membership Agreement; record contributions and dues; administer investments; communicate notices and statements; provide Portal functionality; prevent fraud; maintain audit trails; comply with legal and regulatory obligations; resolve disputes; and protect Finfora, Partners and third parties.
4. Lawful Basis
Depending on the processing, Finfora may rely on contractual necessity, legal obligation, legitimate interests, consent where required, or another lawful basis recognised by the NDP Act and applicable regulations or directives.
5. Financial Information
Financial and investment information will be handled subject to appropriate confidentiality and access controls. Access will be limited according to role and operational necessity.
6. Payment Providers
Where Partner dues or other authorised payments are processed through a third-party payment provider, relevant data may be transmitted to that provider for payment processing, fraud prevention, reconciliation and related purposes. Payment-card credentials should be handled directly by the payment provider where the technical architecture permits.
7. Lead Partners and Authorised Personnel
Lead Partners and designated personnel may have access to Partner information to the extent necessary to perform authorised governance, investment-management, administrative, accounting, legal, compliance or support functions.
8. Service Providers
Finfora may use hosting, cloud, analytics, communications, identity verification, payment, security, professional and other service providers. Appropriate contractual and security controls should apply to third-party processing.
9. International Processing
Where processing involves a transfer or access from outside Nigeria, Finfora will implement the safeguards required by applicable data-protection law.
10. Retention
Partner records may need to be retained for the duration of membership and thereafter for accounting, audit, legal, dispute, tax, corporate-record and other lawful purposes. Specific retention periods should be maintained in Finfora’s internal data-retention schedule.
11. Security
Finfora will maintain appropriate technical and organisational safeguards, including authentication, access controls, logging, secure development and incident-response procedures appropriate to the risk.
12. Data Subject Rights
Subject to statutory limitations, Partners may request access, correction, erasure, restriction, objection, portability or other rights available under applicable law by contacting admin@finforapartners.com.
13. Correction of Partner Data
Partners must promptly notify Finfora of material changes to personal information. Requests to correct Portal information will be assessed and implemented where appropriate.
14. Data Breaches
Finfora will manage personal-data incidents in accordance with applicable law and its internal incident-response procedure, including notification to the NDPC or affected persons where legally required.
15. Privacy Complaints
Complaints should first be submitted to admin@finforapartners.com. A data subject retains any statutory right to complain to the NDPC.
16. Changes
This Notice may be updated from time to time. Material changes will be communicated through reasonable means.