The following Policy applies to current and former individual clients who have or had a brokerage account with BGL Plc. or BGL Plc & Co. Incorporated and those individual clients who are also current and former advisory clients of BGL Plc and to current and former individual investors in certain Nigerian funds advised by BGL Plc.
This Policy is not applicable to partnerships, corporations, trusts or other non-individual clients or account holders, nor is this Policy applicable to individuals who are either beneficiaries of a trust for which we serve as trustee or participants in an employee benefit plan administered or advised by us. This Policy is, however, applicable to individuals who select us to be a custodian of securities or assets in individual retirement accounts.
Please note that we may amend this Policy at any time, and will inform you of any changes to this Policy as required by law.
WE RESPECT YOUR PRIVACY
We appreciate that you have provided us with your personal financial information. We strive to maintain the privacy of such information while we help you achieve your financial objectives.
This Policy describes what non-public personal information we collect about you, why we collect it, and when we may share it with others.
It also discusses the steps you may take to limit our sharing of information about you with affiliated BGL Plc companies, including but not limited to our local and international financial services affiliates that are part of our integrated securities and investment management business, We hope this Policy will help you understand how we collect and share non-public personal information that we gather about you.
Throughout this Policy, we refer to the non-public information that personally identifies you or your accounts as “personal information.”
1. WHAT PERSONAL INFORMATION DO WE COLLECT ABOUT YOU?
To serve you better and manage our business, it is important that we collect and maintain accurate information about you. We obtain this information from applications and other forms you submit to us, from your dealings with us, from consumer reporting agencies, from our Web sites and from third parties and other sources.
We collect information such as your name, address, e-mail address, telephone/fax numbers, assets, income and investment objectives through applications and other forms you submit to us.
We may obtain information about account balances, your use of account(s) and the types of products and services you prefer to receive from us through your dealings and transactions with us and other sources.
We may collect background information from and through third-party vendors to verify representations you have made and to comply with various regulatory requirements.
2. WHEN DO WE DISCLOSE PERSONAL INFORMATION WE COLLECT ABOUT YOU?
To provide you with the products and services you request, to serve you better and to manage our business, we may disclose personal information we collect about you to other BGL Plc companies and to non-affiliated third parties as required or permitted by law.
a. Information we disclose to other BGL Plc companies
In order to manage your account(s) effectively, including servicing and processing your transactions, to let you know about products and services offered by us and other BGL Plc companies, and as otherwise required or permitted by law, we may disclose personal information to other BGL Plc companies. Offers for products and services from other BGL Plc companies are developed under conditions designed to safeguard your personal information.
b. Information we disclose to third parties
We do not disclose personal information that we collect about you to non-affiliated third parties except to enable them to provide marketing services on our behalf, to perform joint marketing agreements with other financial institutions, or as otherwise required or permitted by law. For example, some instances where we may disclose information about you to third parties include: for servicing and processing transactions, to offer our own products and services, to protect against fraud, for institutional risk control, to respond to judicial process or to perform services on our behalf. When we share personal information with these companies, they are required to limit their use of personal information to the particular purpose for which it was shared and they are not allowed to share personal information with others except to fulfill that limited purpose.
3. HOW DO WE PROTECT THE SECURITY AND CONFIDENTIALITY OF PERSONAL INFORMATION WE COLLECT ABOUT YOU?
We maintain physical, electronic and procedural security measures to help safeguard the personal information we collect about you. We have internal policies governing the proper handling of client information. Third parties that provide support or marketing services on our behalf may also receive personal information, and we require them to adhere to confidentiality standards with respect to such information.