This Privacy Policy explains how First Ally Asset Management Limited (“FAAM”) collects, uses, discloses, and safeguards personal data when individuals access or interact with this Application. It is prepared in accordance with the Nigeria Data Protection Act (NDPA) 2023 and the General Application and Implementation Directive (GAID) issued by the Nigeria Data Protection Commission (NDPC).
When users visit or navigate the Application, FAAM may collect non-personal, aggregated information such as:
The Application does not automatically collect personal data.
Non-persistent cookies may be used to support functionality during a single session only. These cookies do not store personal identifiers and are not retained after the session ends.
FAAM may collect personal data when users submit it directly (e.g., completing a contact form, sending an email, or making an enquiry).
This may include:
FAAM processes such information only for the specific purpose for which it was provided.
FAAM processes personal data on one or more of the following legal bases:
Personal data voluntarily provided through the Application is processed for the following purposes:
FAAM will not process personal data for purposes beyond those stated, except where required by law or with the user's further consent.
FAAM retains personal data only for as long as necessary to fulfil the purpose for which it was collected, or to comply with a legal requirement.
Electronic submissions (emails, forms, and related correspondence) may be retained to enable follow-up communication or record-keeping.
In line with the NDPA-GAID, FAAM implements appropriate technical and organisational measures to safeguard personal data against:
However, FAAM cannot guarantee absolute security of data transmitted over the internet.
FAAM may share aggregated, non-personal analytical information with affiliates or authorised service providers strictly on a need-to-know basis.
Personal data will only be shared where:
FAAM does not sell or disclose personal data to third parties for marketing purposes.
If any cross-border transfer of personal data becomes necessary, FAAM will ensure compliance with NDPC-approved safeguards, including:
During the account verification process, we may collect and process temporary facial geometry data, such as facial landmark points, depth and movement detection, and head-position information, through your device's camera. This data is used solely for liveness verification, to confirm that the person completing the verification is a real, physically present individual, and to prevent fraudulent or automated account creation.
All facial data is processed in real time on your device and is immediately deleted once the liveness check is completed. FAAM does not store, retain, reuse, or profile users using this data.
We do not use facial data for any purpose other than liveness detection, and we do not share, transfer, or disclose this data to any third party. This data is never used for marketing, analytics, training of algorithms, or any unrelated processing activity.
Users have the right to:
Requests may be made by contacting FAAM through the details provided below.
By using this Application and voluntarily submitting personal data, users consent to FAAM's processing of their information as described in this Privacy Policy.
FAAM may modify this Privacy Policy from time to time. Updates will be published on the Application and shall take effect upon publication. Users are encouraged to review the Policy periodically.