Privacy Policy

Updated: Apr 12, 2022

Proshare is a professional practice focused on delivering research and information services to bridge the gap between investors and markets; by delivering credible, reliable, and timely engagements through its service areas - Impact Research, Market Intelligence, Strategic Advisory, Stakeholder Relations & Digital Media. Central to this mission is our commitment to upholding the highest standards of data protection for our customers in line with extant laws and regulations.

Importantly, the NDPR distinguishes between a “controller” and a “processor”. We note that we are a “controller” for those services where we make decisions on how personal information is used in connection with our services, and we are a “processor” for those services where we only use personal information as allowed by our customers.

Where we make decisions on how personal information is used in connection with our Services (where we are acting as a controller), we are responsible for the obligations of a “controller” under applicable laws in connection with the processing of personal information – for example, we use this Privacy Policy and other notices to provide you with information about our use of personal information, as required by law.

Where we only use personal information as allowed by our customers (where we are acting as a processor), our customers are similarly responsible for the obligations of a “controller” under applicable laws in connection with the processing of personal information, and, if you are using our Services through one of our customers, you should contact them if you have questions or concerns about the processing of your personal information or compliance with applicable laws. This Privacy Policy applies to all websites and mobile/web applications which link to this policy and are published by Proshare Nigeria (“Sites”).

If you have any queries about how we use your personal information, please contact us using this email [email protected]

1.   Information We Collect

Proshare or a designated service provider or staff collects personal information when you register on this Website, request certain Proshare services or products, or submit the information to participate in any other promotion. If you do not provide certain personal information, not all functionality on the site will be available. So also, you may not be able to access some of our services. The personal information we collect includes:

  • Basic personal details – such as name, title and date of birth;
  • Personal contact details – such as delivery address, phone number, and email address;
  • Work details – such as job title, department, company name, company address, work email address and office phone number;
  • Log in details – such as username and password;
  • Usage information and browsing history - such as usage metrics (including usage rates, occurrences of technical
  • rrors, diagnostic reports, settings preferences, content and advertising interactions.
  • Payment card details
  • Information such as your dietary preferences and accessibility requirements when attending a Proshare Nigeria event, which may be considered special categories of personal data.
  • Your opinion of our products and services;
  • Your preferences regarding Proshare’s other services such as newsletter subscription;
  • Your career details
  • Proshare or a designated officer takes photographs for content and security purposes and for inclusion the Quoted Company Investor Relations Pages of Proshare Markets and Gallery of Proshare WebTV, which is available to Proshare users worldwide.

Do not provide information about others unless you are authorized to do so and consent to have all information used, disclosed, and transferred in accordance with this Privacy Policy. By submitting the information about others, you represent and warrant that you are authorized to do so and that you have received authorization from the person about whom you are providing the information and that person has consented to have all information used, disclosed, and transferred in accordance with this Privacy Policy.

2.   Sources of the Information We Collect

We collect personal information about you either directly from you, from certain third parties (such as your employer or the subscriber providing access to our Services), when you:

  • Report a technical error or infringement of intellectual property
  • Request for permissions
  • Want to pre-schedule a meeting at our offices
  • Want to report a data breach
  • Search for, subscribe to, or purchase our Services.
  • Use our Services or otherwise interact with us.
  • Create or maintain a profile or account with us.
  • Purchase, use, or otherwise interact with content, products, or services from third party providers who have a relationship with us.
  • Create, post, or submit user content on our services.
  • Register for or attend one of our events or locations.
  • Request or sign up for information.
  • Communicate with us by phone, email, chat, in person, or otherwise.
  • Complete a questionnaire, survey, support ticket, or other information request form.
  • When you express an interest in working with us or apply for a job or position with us.

We also collect personal information about you from third parties, such as:

  • Your organization and others with whom you have a relationship that provide or publish personal information related to you, such as from our customers when they arrange access to our Services for you or from others when they create, post, or submit user content on our services that may include your personal information.
  • Professional or industry organizations and certification / licensure agencies that provide or publish personal information related to you.
  • Third parties and affiliates who resell or integrate with our Services.
  • Service providers and business partners who work with us in relation to our Services and that we may utilize to deliver certain content, products, or services or to enhance your experience.
  • Marketing, sales generation, and recruiting business partners.
  • Credit bureaus and other similar agencies.
  • Government agencies and others who release or publish public records.
  • Other publicly or generally available sources, such as social media sites, public and online websites, open databases, and data in the public domain.
  • In some circumstances, we collect information about you from our partners or from publicly available websites to help us better understand our audience and enhance the relevance of our content. For example, in some cases we obtain the contact details of potential speakers for Proshare Nigeria events from public websites.

We also collect personal information through cookies and similar technologies

We, including our service providers, use cookies (and similar technologies) and analytics tools across our Sites to collect statistical or other information about you and your use of the Sites. This information can be used to improve the performance of the site, make advertising more relevant and enhance your user experience, such as:

  • Your location – we use cookies to display information that is most relevant to your location.
  • Your usage – we use cookies to understand how our customers use our Sites and interact with our communications and journalism. For example, we use technology on our Sites, which records user movements, including page scrolling, clicks and text entered. (It does not record payment details.) This helps us to identify usability issues and improve the assistance we can provide to users and is also used for aggregated and statistical reporting purposes.
  • Your device – we use cookies to understand what type of device you are using to show you the best version of the site. For instance, if you visit our Site on a mobile device, our technology ensures that you see a version that is optimized for mobile viewing and interaction.
  • Your engagement with advertisements – we use cookies to understand what advertisements you have been shown, or clicked on, to bill our advertising partners, and to present you with advertisements that are more relevant to you.

Some of the additional we may also collect using cookies and other electronic tools include information about the IP address of your computer, browser type, language, operating system, your mobile device, device ID, geo-location data, the state or country from which you accessed the Sites the web pages visited, the date and the time of a visit, the websites you visited immediately before and after visiting the Sites, the number of links you click within the Sites, the functions you use on the Sites, the databases you view and the searches you request on the Sites, the data you save on or download from the Sites and the number of times you view an advertisement.

Proshare and the parties with whom we work may use the information collected for various reasons, either on behalf of Proshare or for the other parties' own purposes, including research, analysis, to better serve visitors to the Sites (such as by enabling log-in, providing access to certain sections of this Site providing customized content, or presenting online advertising on the Sites or other websites tailored to your interests as described further below), to compile aggregate and anonymous information about usage of the Sites, other statistics, etc. However, if you have deleted and disabled cookies, these uses will not be possible to the extent they are based on cookie information. To opt out of Google Analytics, including Demographics and Interest Reporting, please click here.

To assist us with the uses described in this Privacy Policy, information collected about your use of the Sites may be aggregated, analyzed or combined with personal or other information about you from other online or offline sources. If you prefer that we not combine non-personal information that has been collected, through cookies, about your use of the Sites with personal or other information about you, then please delete and disable cookies for each browser, on each computer you use to surf the Web.

Most browsers are set to accept cookies by default. If you prefer, you can usually set your browser to disable cookies, or to alert you when cookies are being sent. Likewise, most mobile devices allow you to disable the ability for geo-location information to be collected from your mobile device. The help function on most browsers and mobile devices contains instructions on how to set your browser to notify you before accepting cookies, disable cookies entirely, or disable the collection of geo-location data. You need to set each browser on each device you use to surf the Web.

Thus, if you use multiple browsers (e.g., Chrome, Safari, Internet Explorer, Firefox, etc.), you are encouraged/should repeat this procedure with each one. Similarly, if you connect to the web from multiple devices (e.g., work and home), you need to set each browser on each device. Depending on your jurisdiction, you may be able to utilize additional cookie management tools. However, if you disable cookies or refuse to accept a request to place a cookie, it is possible that some parts of the Sites, such as the polls, surveys, contests, and product sales, and certain areas of the Sites for which you need to log in, will not function properly, and the advertising you receive when you visit the Sites may not be advertisements tailored to your interests.

Please note that the use and collection of your information by these third-party service providers, and third-party advertisers and their advertising servers is not covered by this Privacy Policy. Proshare adheres to the industry's Self-Regulatory Principles for Online Behavioral Advertising.

To "opt out" of advertising cookies placed by participating companies in the Self-Regulatory Program for Online Behavioral Advertising, and thereby limit the tracking of your online activity and the targeted advertising you receive, please click here. To "opt out" of advertising cookies placed by the Network Advertising Initiative's ("NAI") online behavioral advertising member networks, and thereby limit the tracking of your online activity and the targeted advertising you receive, please click here. To opt out of advertising cookies for Your Online Choices if you are based in the EU, please click here.

Other designated service providers assist Proshare with advertisement display functions and related analytics for this Web site. To opt out of Google Analytics for Display Advertising, please click here. To opt out of Facebook advertising on OTT devices, please click here. Note that even if you exercise choice for targeted advertising, you will still receive online advertising.

3.   Lawful Basis for Processing

We only process personal information where we have a lawful basis for doing so, such as the following:

  • User consent – This is where you have given us explicit permission to process personal information for a given purpose.
  • Contractual necessity – This is where we have to process personal information to meet our contractual obligations.
  • Legal obligation – This is where we have to process personal information in order to comply with the law.
  • Protection of vital interests – This is where we are constrained to process your information in order to protect your interests or those of another person
  • Public interest – This is where there is an overriding public interest or we have been vested with an official public mandate to take certain action in the interest of the public.

4.   How We Use Your Personal Information

We collect personal information for the following main reasons:

  1. To provide our service
  2. To improve and maintain performance
  3. To bill our customers
  4. To monitor compliance with our policies and terms
  5. To personalize our products and services
  6. To communicate product changes and offers
  7. For the purpose of advertising
  8. Recruitment
  9. To build directories
  10. To administer prize draws and competitions
  11. To address a data breach
  12. To prepare for your visit to our offices
  13. To fix a technical error
  14. To address a breach of laws relevant to our business
  15. To protect our systems

You can also update your personal information by sending us an email using this address [email protected]. Please note that if you exercise choice in this manner, you will continue to receive communications concerning your account and products and services you requested, and in response to any requests for information by you. Please also note that this opt-out process may take some time to complete, consistent with applicable law.

5.   Who We Share Your Personal Information With?

We disclose personal information to facilitate the running of our business or to provide specific services you have requested. We may share personal information with service providers like fulfilment providers for delivery of our digital content and marketing; customer service agencies; hosts, organizers and sponsors of our events; organizations that host our Sites or databases; and providers of online surveys.

We may also share with advertisers. We, and our advertising partners, use cookies to collect personal information and serve you with advertisements that we believe are relevant to you and your interests. We may share personal information with institutional customers. For instance, if your subscription is provided under a group subscription or trial, we may provide our client with information about your activity on our Site(s) for the purposes of user management, licence administration, content suggestion and billing. We may also make online tools available to our client for these purposes. Information about your activity is provided at a high level and our client cannot track exactly what articles you have read. We may also provide current or prospective clients with activity information about individual subscribers who registered using that entity’s email address.

We will always contact individual subscribers before doing so and will respect any requests not to share this information. We also share personal information with social media platforms, where for instance, you log in to our Sites via a social media account. Please note that our Sites are publicly accessible and anyone around the world who accesses our Sites will be able to see anything you post, such as comments about an article. We encourage you to use a pseudonym when commenting on our Sites if you do not wish to be identifiable to other readers. If you participate in certain features of our Sites (e.g., sharing news stories of interest), please note that any information you or others voluntarily disclose through use of these features, becomes available to the public and/or other users whom you have designated. If you choose to provide access to designated individuals, please be aware that any information you post will be visible to such individuals for their use.

Proshare is not responsible for the information that you or others choose to disclose publicly on this Web site, and neither Proshare's nor others' use of such information is subject to this Privacy Policy. Proshare may also share your personal information (excluding security photographs) with a sponsor or other third party ("Third-Party Provider") that provides you with offers or promotions that may be of interest to you. You may instruct Proshare at any time not to share your personal information covered by this Privacy Policy with such Third-Party Providers by Unsubscribing or contacting us.

Please note that (i) this opt-out process may take some time to complete, consistent with applicable law; and (ii) even after such opt-out process is completed, your personal information may continue to be shared with our affiliates (including affiliated websites under common ownership or control) and designated service providers. Proshare may share with other third party’s information about our Sites users, such as your use of this Web site or other websites, and the services provided on the Sites but only on an unattributed and aggregate basis. In this event, we will take reasonable steps to ensure that it cannot identify as an individual before sharing. We may also share personal information within the Proshare Nigeria Group to provide our services and to better understand the relationship between our products. More information about Proshare is in the “About Us” section of our Site.

Proshare may also disclose your personal information to unaffiliated third parties if we believe in good faith that such disclosure is necessary to: (a) comply with any applicable law, rule, or regulation, or in response to a subpoena, court order, or other legal process, subject to Proshare's Law Enforcement Data Request Statement; (b) protect the interests, rights, safety, or property of Proshare or others; (c) monitor compliance with and enforce any terms of service on this Web site; (d) provide our services and products (including allowing a purchaser of Proshare or a Proshare division to continue to serve you); (e) perform other activities related to such services and products, including billing and collection; (f) provide you with offers or promotions from Proshare; or (g) operate the systems that provide our services and products properly.

The collection, further use, and/or disclosure of your information by Third-Party Providers or by other third parties is not the responsibility of Proshare. Rather, such collection, use, and/or disclosure is governed by the third parties' privacy policies. We will take reasonable steps to ensure that all the third parties we interact with comply with the relevant data privacy laws.

Links to Other Websites

Proshare may provide links to third-party websites, including social networking websites. Since we do not control third-party sites and are not responsible for any information you may provide while on such sites, we encourage you to read the privacy policies on those websites before providing any of your information on such sites. We are not responsible for their content, use of personal information, or security practices.

6.   How Long We Retain Your Personal Information

We retain the majority of your personal information for as long as your account or subscription is active and therefore open. This allows you to continue accessing our content, products and services. If you become inactive and are not a subscriber, we retain your information only for the period within which it is reasonably needed and may delete elements of the information associated with your account. We will normally warn you if your access is going to be withdrawn and give you the opportunity to retain your account. Where we don’t need to keep all of your information in full, we will obfuscate or aggregate it, for example, web activity logs and survey responses. This is to ensure that we do not retain your information for any longer than is necessary. It may be sometimes necessary for us to keep your personal information for longer periods of time, for example:

  • If there is a statutory requirement to retain it;
  • If we require the information for legal reasons or there is a legitimate business need for us to retain it;
  • To ensure we do not contact you if you have asked us not to.

7.   The Security & Transfer of your Personal Information

We have appropriate technical and administrative security measures in place to help ensure that our users’ information is protected against unauthorized or accidental access, use, alteration, or loss. In the event that we transfer your personal information outside your jurisdiction, it would most likely be because we want to ensure the utmost security of your personal information. We put in place safeguards to protect information that is transferred in this way and only transfer your information in line with the lawful bases for data processing outlined above or under the supervision of the appropriate governmental authority, ensuring the country to which we are transferring your data has high standards of data protection, as spelt out in the Nigerian Data Protection Regulations. You agree to cooperate with Proshare in order to ensure the security of your personal information and the Sites, including the information on the Sites. We recommend that the users necessarily choose their passwords carefully such that no unauthorized access is made by a third party. Do not disclose their password to anyone or keep any written or other record of the password such that a third party could access it.

8.   Your rights

Under the relevant data protection laws, you have rights as an individual in relation to the personal data we hold about you. These rights include:

  • The right to object to direct marketing - your preferences, including in relation to direct marketing, can be found in your account;
  • he right to access the personal data that we process about you;
  • he right to request the deletion of your personal information;
  • The right to request the rectification of your personal information - you can manage some of this information in your account.
  • The right to be informed about the processing of your personal information
  • The right to restrict processing of your personal information
  • The right to request access to your personal information and to obtain information about how we process it
  • The right to move, copy or transfer your personal information ("data portability")

You can exercise these rights through your account or by contacting us using the email below. You also have the right to lodge a complaint with a supervisory authority.

If you have a query in regard to the processing of your personal information, please contact us directly using this email at [email protected]


Registered Office
Plot 590B, Lekan Asuni Close, Omole Phase II, Isheri LGA,
P.O. Box 18782, Ikeja, Lagos, Nigeria.

Telephone
0700 PROSHARE (070077674273)

Changes to this Privacy Policy
This policy is effective from April 28, 2022
Any changes we may make to this privacy policy will be posted on this page. If changes are significant, we may choose to notify you by email or to clearly indicate on our home page that the policy has been updated.

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Proshare is a professional practice focused on delivering research and information services to bridge the gap between investors and markets; by delivery on credible, reliable, and timely engagements through the following areas — Impact Research, Market Intelligence, Strategic Advisory, Stakeholder Relations & Digital Media.