Privacy Policy

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 Last update: 1st August 2023

Earning your trust is FiNSEED’s top priority. The privacy of your information is essential to earning and keeping that trust. All the decision we make about how we gather, store, and use any information we obtain from you is driven by this principle. Your personal information will never be traded, rented, or sold to anyone.

FiNSEED Investment Management (“FiNSEED”, “we”, “us” and/or “our”) operates an Automated Investment Management Platform (“Platform”). The Platform is available on our website, mobile application, and USSD. This Privacy Policy details how FiNSEED handles your personal information whenever you use our Platform. Throughout this agreement, a Visitor refers to a person who uses our Platform to assess our Platform, or for purpose of gaining information. On the other hand, a Client is a person who signs our Investment Management Agreement and sets up an investment account with us. This Privacy Policy governs your use of our Platform.

The kind of information we collect depends on whether you are a Visitor or a Client. We collect Personal Information from you when you voluntarily provide information to us. Examples of instances when we collect Personal Information include when you answer questions on our website to select your goal and determine your risk tolerance and the recommended investment portfolio if you were to become a Client. The information collected includes some information that you voluntarily provide such as; age. We may also collect your name, email address, and/or telephone number whenever you choose to engage with us through our website, mobile application, USSD, email, text message or telephone. This information is collected whenever you are in the process of registering to open an investment account when you contact us through the landing page or inside your account when you become a Client. At whatever point FiNSEED collects Personal Information, we make sure to link to this Privacy Policy and other relevant policies, like our Terms of Use. Specifically, we collect this information from Visitors and Clients:

• Visitor Information collected
  To use our Platform, we may collect certain personal information such as name, address, telephone number, and email address. We also collect some information that you voluntarily provide such as age bracket, investable assets, financial goals and objectives, income information, and other critical financial planning information. We may collect your name, e-mail address and/or telephone number whenever you choose to engage with us through our website, mobile application, USSD, email or telephone.
• Client Information collected
  Because investment management is a highly regulated industry, if you choose to become a Client, besides the information we collect from you as a Visitor, we will also collect information that includes, but is not limited to: full legal name, biographical information such as date of birth contact information, identification documents citizenship and/or country of residence, investment objectives, net worth, and other regulatory disclosures that are required under by the regulators and other government agencies.

Partnerships

If we onboard you from any of our partners (or you interact with our Platform using integration provided by any of our partners) who collect your information, you consent to your user details that are relevant for consuming the services offered by FiNSEED to be transferred to us by our Partner.

Use of Information

The information that is taken from both Visitors and Clients by FiNSEED is stored, processed, and maintained securely. It helps us to provide Client support, roll out innovative products or services and operate within the rules and regulations set by the Capital Markets Authority, Uganda Retirement Benefits Regulatory Authority, and other government agencies. Provision of the information is voluntary, however, if you decide not to provide the requisite information, you will most certainly not be able to use the full functionality of the Platform or even become a Client. Occasionally, we may share the information required to become a Client with third parties such as our custodian, trustee, and brokerage partners specifically to allow them to provide services to you. We may periodically use your Personal Information to relay certain critical information to you about our Platform. If you decide at any time that you do not wish to receive certain marketing information, use the “unsubscribe” steps included in every communication to cause this to stop. However, even when you unsubscribe from receiving marketing information, we will still send periodic administrative information such as billing and Platform notifications as well as obligatory regulatory notifications.

Information Sharing and Exceptions

FiNSEED does not sell, rent, or trade your personal information with any third parties other than with your consent or as required by law. However, to efficiently provide our services and for our business operations, we may share your personal information with third parties, including but not limited to: consumer identification verification services, public accounting firms, and certain other service providers (including companies that perform marketing and analytics services).

• For any third parties we may share your information with, we have entered into agreements that require them to keep this information confidential. In addition, we may disclose your information to other third-party financial institutions, e.g., if you ask us to transfer your assets from FiNSEED to such other financial institutions
• We may also disclose personal information in response to service of legal process, such as court orders, summons, or subpoenas, or as permitted or required by law when we reasonably deem it is necessary or appropriate to investigate, prevent, or take action regarding illegal activities, suspected fraud (including identity theft), front-running or scalping, situations involving potential threats to the physical safety of any person, or suspected violations of our Privacy Policy, Terms of Use or other customer agreements.
• Furthermore, we may disclose personal information in specific other cases with your express consent. In order to provide workplace services to employers or plan sponsors, such as retirement savings plan services and recordkeeping services, we may exchange any information received in connection with such services with the employer or plan sponsor or other authorized service providers. We may also share information, including but not limited to account positions, contributions, and distributions, and with a third-party financial institution that serves as a trustee, or custodian bank.
• You may request deletion of personal information by emailing uganda@myfinseed.com. and providing us with enough information to identify your account and prove that you are the owner of the identified account. We will endeavour to make any deletion request effective as soon as reasonably practicable. However, we may retain residual information related to your account, as well as any data related to your trades, in accordance with applicable laws.
• Under no circumstances will we share any personal information data unless lawfully required by courts of law, the regulators or other government agencies. You may decline to provide personal information to FiNSEED. Declining to provide personal information may disqualify you from accessing FiNSEED services and Site features that require certain personal information.

FiNSEED works diligently to protect your personal information. We deploy several physical and electronic safeguards to keep your information safe and private. We use the strongest available browser encryption, store all of our data on servers in secure facilities, and implement systematic processes and procedures for securing and storing data. For example, we limit access to your personal and financial information to only those employees with authorized access who need to know the information to perform their jobs, and we require third parties who perform services for FiNSEED to agree to keep your information confidential. Moreover, if you decide to close your account or your account is terminated with us, we will continue to adhere to the privacy policies and practices outlined here. Please note that, if you maintain a FiNSEED account that you access through our website, you are responsible for protecting and maintaining the confidentiality of your account and password and restricting access to your computer.

Once you have registered with FiNSEED, you can access your profile, review the information that is stored, and revise that information. If you have any problems, please contact us at uganda@myfinseed.com. However, due to regulatory requirements, we do not delete residual copies of outdated information and must therefore preserve all customer data for a minimum of seven years.

Other important information

FiNSEED takes commercially reasonable steps to protect your Personal Information from loss, misuse, and unauthorized access, alteration, disclosure, or destruction. No Internet, email, or electronic operating system that enables the transmission of data is ever fully secure or error-free. So, please take special care in deciding what information you send to us in this manner.

We do not allow third-party advertising on our website.

This Privacy Policy and these terms apply only to FiNSEED-operated services and applications. This Platform may contain links that access other websites and applications that are not operated or controlled by FiNSEED. The policies described herein do not apply to Third Party websites or applications.

 FiNSEED is not to be used by anyone under the age of 8 and, as such does not knowingly collect Personal Information from anyone under the age of 8. If you are under the age of 8, please do not submit any Personal Information to FiNSEED. If a parent or guardian becomes aware that his or her child under the age of 8 has provided us with personally identifiable information without his or her consent, he or she should contact us at uganda@myfinseed.com and we will delete such information from our files. Minors must be supervised by an adult in navigating our Platform. 

By using and continuing to use the FiNSEED Platform or otherwise providing us with personal information (such as an email address or phone number) you agree to the terms and conditions of this privacy policy and any updates thereto. This Privacy Policy may change from time to time. We will post any Privacy Policy changes here and, if the changes are substantial, we will provide a more prominent notice (including, for certain services, email notification of Privacy Policy changes). Each version of this Privacy Policy will be identified at the top of the page by its “Last Update” date. This document constitutes FiNSEED’s complete Privacy Policy for our Services. If you have questions or comments about this Privacy Policy, please email us at uganda@myfinseed.com.