1. About this Notice
2. Who We Are
3. The Data We Collect About You?
4. How We Use Your Personal Data
5. Legal basis for the processing of Personal Data
6. How We Share Your Personal Data
7. International Transfers
8. Data Retention
9. Data Security
10. Your Legal Rights
11. Data Controllers & Contact
1. About this Notice
1. This Privacy Notice provides information on how GLICO Capital collects and processes your personal data when you visit our website or mobile applications. It outlines what we do with your personal data and how we keep it secure and explains the rights that you have about your personal data.
2. Who We Are
1. GLICO Capital is a subsidiary of GLICO Group Ltd, incorporated in 2003 to operate as a Fund Management company. We are licensed by the Securities and Exchange Commission (SEC) and the National Pensions Regulatory Authority. We currently operate from No. 48 J. A. Kuffour Avenue, Avenor - Accra.
2. As a financial management expert, GLICO Capital provides Fund Management services founded on deep technical knowledge, extensive experience in wealth creation, and time-tested systems and processes. Our services include the management of Institutional and Individual funds, Pension funds, Provident funds, Welfare Administration, and Corporate Finance Advisory.
3. This website and/or mobile app is operated by Group IT of the GLICO group of companies, the ultimate holding company of GLICO Capital. Information on our subsidiaries can be found on GLICO Group’s website.
4. Any personal data provided or collected by GLICO Capital is controlled by GLICO Capital the subsidiary that the website and/or mobile app relates to.
3. The Data We Collect About You?
1. Personal data means any information that can be used to identify directly or indirectly a specific individual. We collect your personal data in order to provide tailored products and services and in order to analyze and continually improve our products and services. We may collect, use, store and transfer different kinds of personal data for promotional, marketing and personal data optimization purposes. GLICO Capital may also use Google Digital Marketing to propose targeted offers for certain products and services to our customers.
2. You provide us with your personal data when you register your personal details on our website, account opening forms, withdrawal forms and portals and transact with the same.
3. The personal data we collect includes: Name, Date of Birth, Hometown, Occupation, Employment status etc.
4. A. Information you provide to us: We receive and store the information you provide to us including your identity data, contact data, biometric data, delivery address and financial data. These types of personal data may include:
i. contact details (such as your name, postal addresses, residential address, phone numbers and email addresses etc),
ii. demographic information (such as your date of birth, age or age range, marriage status, country, residential status, gender etc),
iii. payment information (such as your bank account number and mobile money account number),
iv. information provided as part of online questionnaires (such as responses to any customer satisfaction surveys or market research etc),
v. competition entries/submissions, and
vi. in certain cases, your marketing preferences.
B. Information we automatically collect/generate or obtain from third parties: We automatically collect and store certain types of information regarding your use of the GLICO Capital website, including information about your searches, views, downloads and purchases. In addition, we may receive information about you from third parties, including our bankers, payment service providers, and merchants.
5. We strive to provide you with choices regarding the Personal Data that you provide to us. Where required by law, if you wish to have your Personal Data used by GLICO Capital to provide you with a personalized experience/targeted advertising & content, you can indicate so through the relevant tick-box(es) located on the registration form or by answering the question(s) presented by GLICO Capital representatives. If you decide that you no longer wish to benefit from this personalization, you can opt out or adjust your preferences at any time by closing your account or by sending an email to info@glicocapital.com or P. O. Box GP 4251 Accra - Ghana. You can close your account by sending us an official email to the email address provided above. Once your account is closed, all products and services that you access through your account will no longer be available.
4. How We Use Your Personal Data
1. We use your personal data to operate, provide, develop and improve the products and services that we offer, including the following:
A. Registering you as a new customer.
B. Processing your investment.
C. Process your withdrawal
D. Managing your relationship with us.
E. Enabling you to participate in promotions, competitions and surveys.
F. Improving our website, applications, products and services.
G. Recommending/advertising products or services which may be of interest to you.
H. Enabling you to access certain products and services offered by our partners and other subsidiaries.
I. Complying with our legal obligations, including verifying your identity where necessary.
J. Detecting fraud.
5. Legal basis for the processing of Personal Data
1. We will only process your personal data where we have a legal basis to do so. The legal basis will depend on the purposes for which we have collected and used your personal data. In almost every case the legal basis will be one of the following:
A. Consent: For example, where you have provided your consent to receive certain marketing from us. You can withdraw your consent at any time, including by clicking on the “unsubscribe” link at the bottom of any marketing email we send you
B. Our legitimate business interests: Where it is necessary for us to understand our customers, promote our services and operate effectively, provided in each case that this is done in a legitimate way which does not unduly affect your privacy and other rights.
C. Performance of a contract with you: This would also apply where we need to take steps prior to entering into a contract with you. For example, where you have purchased an investment product or service from us and we need to use your contact details and payment information in order to process your investment purchase and withdrawal to you.
D. Compliance with law: Where we are subject to a legal obligation and need to use your personal data in order to comply with that obligation.
6. How We Share Your Personal Data
1. A. We may need to share your personal data with third parties for the following purposes:
i. Processing of investment purchase and withdrawal: In order to transfer and send a withdrawal request, we may be required to provide your personal data to such third parties such as banks and payment service providers.
ii. Working with third-party service providers: We engage third parties to perform certain functions on our behalf. Examples include analyzing data, providing marketing
assistance, processing payments, providing customer service, transmitting content, assessing and managing credit risk, sending SMS and sending souvenirs.
iii. Business transfers: As we continue to develop our business, we might sell or buy other businesses or services. In such transactions, customer information may be transferred together with other business assets.
iv. Detecting fraud and abuse: We release account and other personal data to other companies and organizations for fraud protection and credit risk reduction, and to comply with applicable law.
2. B. When we share your personal data with third parties we:
o require them to agree to use your data in accordance with the terms of this Privacy Notice, our Privacy Policy and in accordance with applicable law; and
o only permit them to process your personal data for specified purposes and in accordance with our instructions. We do not allow our third-party service providers to use your personal data for their own purposes.
7. International Transfers
1. We may transfer your personal data to locations in another country, if this is permissible pursuant to applicable laws in your location. There are inherent risks in such transfers.
2. In the event of international transfers of your personal data, we shall put in place measures necessary to protect your data and ensure the same level of protection available in the country of data origin. We shall continue to respect your legal rights pursuant to the terms of this Privacy Notice and applicable laws in your location.
8. Data Retention
1. We will take every reasonable step to ensure that your personal data is processed for the minimum period necessary for the purposes set out in this Privacy Notice. Your personal data may be retained in a form that allows for identification only for as long as:
A. We maintain an ongoing relationship with you. This will enable us to improve your experience with us and to ensure that you receive communications from us
B. Your Personal Data is necessary in connection with the purposes set out in this Privacy Notice and we have a valid legal basis,
C. The duration of: (i) any applicable limitation period as required by law and our regulators (i.e., any period during which a person could bring a legal claim against us), and
2. We will actively review the personal data we hold and delete it securely, or in some cases anonymize it, when there is no longer a legal, business or consumer need for it to be retained.
9. Data Security
1. We have put in place security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed.
2. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
3. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
10. Your Legal Rights
1. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us or when we periodically request for such updates.
2. Under certain circumstances, you have rights under data protection laws in relation to your personal data, including the right to access, correct or erase your personal data, object to or restrict processing of your personal data, right to ask that we transfer your personal data to a third party, and unsubscribe from our emails and newsletters.
3. Where you wish to permanently delete your data from our website and other applications, you can choose the option of closing your account. You can close your account by sending us an official email to info@glicocapital.com or an official letter mail to us via P. O. Box GP 4251, Accra - Ghana. Once your account is closed, all products and services that you access through your account will no longer be available.
4. We can refuse to accede to your request where it is unreasonable or where you have failed to provide additional information necessary to confirm your identity.
11. Data Controllers & Contact
1. If you have any questions or concerns about GLICO Capital’s Privacy Notice or you are looking for more information on how we process your personal data, or wish to exercise your legal rights in respect of your personal data, please contact the Data Protection Supervisor by email at info@glicocapital.com or P. O. Box GP 4251 Accra – Ghana.
2. We will investigate any complaint about the way we manage Personal Data and ensure that we respond to all substantiated complaints within prescribed timelines.
2. Who We Are
3. The Data We Collect About You?
4. How We Use Your Personal Data
5. Legal basis for the processing of Personal Data
6. How We Share Your Personal Data
7. International Transfers
8. Data Retention
9. Data Security
10. Your Legal Rights
11. Data Controllers & Contact
1. About this Notice
1. This Privacy Notice provides information on how GLICO Capital collects and processes your personal data when you visit our website or mobile applications. It outlines what we do with your personal data and how we keep it secure and explains the rights that you have about your personal data.
2. Who We Are
1. GLICO Capital is a subsidiary of GLICO Group Ltd, incorporated in 2003 to operate as a Fund Management company. We are licensed by the Securities and Exchange Commission (SEC) and the National Pensions Regulatory Authority. We currently operate from No. 48 J. A. Kuffour Avenue, Avenor - Accra.
2. As a financial management expert, GLICO Capital provides Fund Management services founded on deep technical knowledge, extensive experience in wealth creation, and time-tested systems and processes. Our services include the management of Institutional and Individual funds, Pension funds, Provident funds, Welfare Administration, and Corporate Finance Advisory.
3. This website and/or mobile app is operated by Group IT of the GLICO group of companies, the ultimate holding company of GLICO Capital. Information on our subsidiaries can be found on GLICO Group’s website.
4. Any personal data provided or collected by GLICO Capital is controlled by GLICO Capital the subsidiary that the website and/or mobile app relates to.
3. The Data We Collect About You?
1. Personal data means any information that can be used to identify directly or indirectly a specific individual. We collect your personal data in order to provide tailored products and services and in order to analyze and continually improve our products and services. We may collect, use, store and transfer different kinds of personal data for promotional, marketing and personal data optimization purposes. GLICO Capital may also use Google Digital Marketing to propose targeted offers for certain products and services to our customers.
2. You provide us with your personal data when you register your personal details on our website, account opening forms, withdrawal forms and portals and transact with the same.
3. The personal data we collect includes: Name, Date of Birth, Hometown, Occupation, Employment status etc.
4. A. Information you provide to us: We receive and store the information you provide to us including your identity data, contact data, biometric data, delivery address and financial data. These types of personal data may include:
i. contact details (such as your name, postal addresses, residential address, phone numbers and email addresses etc),
ii. demographic information (such as your date of birth, age or age range, marriage status, country, residential status, gender etc),
iii. payment information (such as your bank account number and mobile money account number),
iv. information provided as part of online questionnaires (such as responses to any customer satisfaction surveys or market research etc),
v. competition entries/submissions, and
vi. in certain cases, your marketing preferences.
B. Information we automatically collect/generate or obtain from third parties: We automatically collect and store certain types of information regarding your use of the GLICO Capital website, including information about your searches, views, downloads and purchases. In addition, we may receive information about you from third parties, including our bankers, payment service providers, and merchants.
5. We strive to provide you with choices regarding the Personal Data that you provide to us. Where required by law, if you wish to have your Personal Data used by GLICO Capital to provide you with a personalized experience/targeted advertising & content, you can indicate so through the relevant tick-box(es) located on the registration form or by answering the question(s) presented by GLICO Capital representatives. If you decide that you no longer wish to benefit from this personalization, you can opt out or adjust your preferences at any time by closing your account or by sending an email to info@glicocapital.com or P. O. Box GP 4251 Accra - Ghana. You can close your account by sending us an official email to the email address provided above. Once your account is closed, all products and services that you access through your account will no longer be available.
4. How We Use Your Personal Data
1. We use your personal data to operate, provide, develop and improve the products and services that we offer, including the following:
A. Registering you as a new customer.
B. Processing your investment.
C. Process your withdrawal
D. Managing your relationship with us.
E. Enabling you to participate in promotions, competitions and surveys.
F. Improving our website, applications, products and services.
G. Recommending/advertising products or services which may be of interest to you.
H. Enabling you to access certain products and services offered by our partners and other subsidiaries.
I. Complying with our legal obligations, including verifying your identity where necessary.
J. Detecting fraud.
5. Legal basis for the processing of Personal Data
1. We will only process your personal data where we have a legal basis to do so. The legal basis will depend on the purposes for which we have collected and used your personal data. In almost every case the legal basis will be one of the following:
A. Consent: For example, where you have provided your consent to receive certain marketing from us. You can withdraw your consent at any time, including by clicking on the “unsubscribe” link at the bottom of any marketing email we send you
B. Our legitimate business interests: Where it is necessary for us to understand our customers, promote our services and operate effectively, provided in each case that this is done in a legitimate way which does not unduly affect your privacy and other rights.
C. Performance of a contract with you: This would also apply where we need to take steps prior to entering into a contract with you. For example, where you have purchased an investment product or service from us and we need to use your contact details and payment information in order to process your investment purchase and withdrawal to you.
D. Compliance with law: Where we are subject to a legal obligation and need to use your personal data in order to comply with that obligation.
6. How We Share Your Personal Data
1. A. We may need to share your personal data with third parties for the following purposes:
i. Processing of investment purchase and withdrawal: In order to transfer and send a withdrawal request, we may be required to provide your personal data to such third parties such as banks and payment service providers.
ii. Working with third-party service providers: We engage third parties to perform certain functions on our behalf. Examples include analyzing data, providing marketing
assistance, processing payments, providing customer service, transmitting content, assessing and managing credit risk, sending SMS and sending souvenirs.
iii. Business transfers: As we continue to develop our business, we might sell or buy other businesses or services. In such transactions, customer information may be transferred together with other business assets.
iv. Detecting fraud and abuse: We release account and other personal data to other companies and organizations for fraud protection and credit risk reduction, and to comply with applicable law.
2. B. When we share your personal data with third parties we:
o require them to agree to use your data in accordance with the terms of this Privacy Notice, our Privacy Policy and in accordance with applicable law; and
o only permit them to process your personal data for specified purposes and in accordance with our instructions. We do not allow our third-party service providers to use your personal data for their own purposes.
7. International Transfers
1. We may transfer your personal data to locations in another country, if this is permissible pursuant to applicable laws in your location. There are inherent risks in such transfers.
2. In the event of international transfers of your personal data, we shall put in place measures necessary to protect your data and ensure the same level of protection available in the country of data origin. We shall continue to respect your legal rights pursuant to the terms of this Privacy Notice and applicable laws in your location.
8. Data Retention
1. We will take every reasonable step to ensure that your personal data is processed for the minimum period necessary for the purposes set out in this Privacy Notice. Your personal data may be retained in a form that allows for identification only for as long as:
A. We maintain an ongoing relationship with you. This will enable us to improve your experience with us and to ensure that you receive communications from us
B. Your Personal Data is necessary in connection with the purposes set out in this Privacy Notice and we have a valid legal basis,
C. The duration of: (i) any applicable limitation period as required by law and our regulators (i.e., any period during which a person could bring a legal claim against us), and
2. We will actively review the personal data we hold and delete it securely, or in some cases anonymize it, when there is no longer a legal, business or consumer need for it to be retained.
9. Data Security
1. We have put in place security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed.
2. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
3. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
10. Your Legal Rights
1. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us or when we periodically request for such updates.
2. Under certain circumstances, you have rights under data protection laws in relation to your personal data, including the right to access, correct or erase your personal data, object to or restrict processing of your personal data, right to ask that we transfer your personal data to a third party, and unsubscribe from our emails and newsletters.
3. Where you wish to permanently delete your data from our website and other applications, you can choose the option of closing your account. You can close your account by sending us an official email to info@glicocapital.com or an official letter mail to us via P. O. Box GP 4251, Accra - Ghana. Once your account is closed, all products and services that you access through your account will no longer be available.
4. We can refuse to accede to your request where it is unreasonable or where you have failed to provide additional information necessary to confirm your identity.
11. Data Controllers & Contact
1. If you have any questions or concerns about GLICO Capital’s Privacy Notice or you are looking for more information on how we process your personal data, or wish to exercise your legal rights in respect of your personal data, please contact the Data Protection Supervisor by email at info@glicocapital.com or P. O. Box GP 4251 Accra – Ghana.
2. We will investigate any complaint about the way we manage Personal Data and ensure that we respond to all substantiated complaints within prescribed timelines.