Privacy Policy
Last updated Nov 20, 2025
Privacy Policy
This Privacy Policy explains how we collect, use, disclose, rectify, and restrict your Personal Data when you use the Platform. It also outlines how we maintain the quality, accuracy, and security of your data in line with the Nigeria Data Protection Act (NDPA) 2023 and the General Application and Implementation Directive (GAID) 2025.
We are committed to protecting your privacy and ensuring that your data is processed lawfully, fairly, and transparently. Your consent will be obtained at every stage of data collection and processing, and you will be provided with clear options to verify, update, or rectify your data at any time.
We do not use or share your information except as described in this Privacy Policy or as required by law.
Information Collection and Use
When you use the Platform, we may collect Personal Data such as your name, email address, phone number, postal address, date of birth, photograph, bank details, and usage data. This information is collected to provide services, improve user experience, and meet legal obligations. Sensitive personal data (e.g., racial or ethnic origin, religious beliefs, political opinions, health information, or criminal records) will only be collected with your explicit and informed consent, and only when necessary for a lawful purpose.
You will have the opportunity to verify and confirm the accuracy of your data before submission, and you may rectify or update your data at any time through your account settings or by contacting our support team.
Log Data
When you access the Platform via a mobile device, we may automatically collect technical information such as your device type, unique device ID, IP address, operating system, browser type, and usage statistics. We may use third-party analytics tools (e.g., Google Analytics) to monitor and analyze this data to improve Platform functionality. These third parties are subject to their own privacy policies and are required to process data in compliance with applicable laws.
Location Information
With your permission, we may collect and use location data to provide location-based features and improve your experience. You can enable or disable location services at any time via your device settings.
Purpose of Data Use
We may use your Personal Data for the following purposes:
- To fulfill contractual obligations and provide requested services
- To communicate with you about products or services similar to those you’ve used or requested
- To send marketing communications (only with your consent)
- To personalize content and improve Platform presentation
- For internal operations including troubleshooting, analytics, and research
- To measure advertising effectiveness and deliver relevant ads
- To comply with legal obligations and regulatory requirements
- To prevent fraud, verify identity, and ensure Platform security
- To provide location-based services and personalized experiences
Where data is processed based on legitimate interest, it will be pseudonymized and aggregated to prevent identification. You have the right to object to such processing, although this may affect the availability of certain services.
Legal Basis for Processing
We process your data based on one or more of the following legal grounds:
- Your explicit consent
- Performance of a contract
- Compliance with a legal obligation
- Protection of your vital interests
- Performance of a task in the public interest
- Our legitimate interest in fraud prevention, service improvement, and regulatory compliance
Fraud Prevention and Regulatory Reporting
It is imperative that your data with us is current and accurate. You may request for the rectification of any personal data that we hold about you so as to enable you to correct any incomplete or inaccurate data we hold about you. Such requests may be sent to dpo@boazexchange.com . We may, however, need to verify the accuracy of the new data you provide to us.
Changes to Personal Data
In consideration of SGCL (and its owners, suppliers, consultants, advertisers, affiliates, partners, employees, or any other associated entities, all collectively referred to as ‘associated entities' hereafter) acting on any mandates given via the Platform and all other approved electronic channels regarding Your trading account (the "Services"), you hereby confirm and accept that:
Platform Providers
We may employ third party companies and individuals to facilitate our Platform, to provide the Platform on our behalf, to perform Platform-related Platforms or to assist us in analyzing how our Platform is used.
These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
Communications
We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send.
Compliance with Laws
We will disclose your Personal Data where required to do so by law or subpoena or if we believe that such action is necessary to comply with the law and the reasonable requests of law enforcement or to protect the security or integrity of our Platform.
Business Transaction
If BESL is involved in a merger, acquisition or asset sale, your Personal Data may be transferred. We will provide notice before your Personal Information is transferred and becomes subject to a different Privacy Policy.
Security and Retention
The security of your Personal Data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
We will retain your data for as long as necessary for the said purpose of the processing, and after that, we will keep your data as long as the law requires.
International Transfer
Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction. However, our collection, storage and use of your Personal Data will continue to be governed by this Privacy Policy and comply with the Nigeria Data Protection Act (2023) and the General Application and Implementation Directive (GAID) 2025 in respect of such transfers
If you are located outside Nigeria and choose to provide information to us, please note that we transfer the information, including Personal Data, to Nigeria and process it there.
Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.
Links To Other Sites
Our Platform may contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit.
We have no control over, and assume no responsibility for the content, privacy policies or practices of any third party sites or Platforms.
Children’s Privacy
Our Platform does not address anyone under the age of 18 ( "Children").We do not knowingly collect personally identifiable information from children under 18. If you are a parent or guardian and you are aware that your Children has provided us with Personal Information, please contact us. If we become aware that we have collected Personal Information from a children under age 18 without verification of parental consent, we take steps to remove that information from our servers.
How We Protect Your Data
BESL will take reasonable steps to ensure that the personal information that we hold about you is kept confidential and secure, including by:
- having a robust physical security of our premises and databases/records;
- taking measures to restrict access to only personnel who need that personal information to effectively provide services to you;
- having technological measures in place (for example, anti-virus software and fire walls)
Your Legal Rights
You have the right to:
- Be informed about how we collect, use, and protect your data. This is to enable you have a clear and transparent information about our data practices. Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. Except as otherwise provided by any public policy or Regulation, information provided to you and any actions taken shall be provided free of charge. However, where requests from you are manifestly unfounded or excessive, in particular because of their repetitive character, we may either:
- Charge a reasonable fee considering the administrative costs of providing the information or communication; or
- Respond with a letter of refusal, stating the ground of refusal, with National Information Technology Development Agency in copy.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
If you want us to establish the data's accuracy,- Where our use of the data is unlawful but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or Platforms to you. We will advise you if this is the case at the time you withdraw your consent.
Changes to This Privacy Policy
We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.
You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
Contact Us
If you have any questions about this Privacy Policy, please send us an email at (dpo@boazexchange.com). Or contact our Data Protection Officer, ********** at (…………………..).
Disclaimer
The Platform may include links to or integrations with third party merchants, service providers, or external systems. We do not control and are not responsible for the actions, omissions, representations, or failures of such third parties.
All engagements with third party entities are at the user's sole risk. We make no warranties, express or implied, regarding the accuracy, reliability, legality, or quality of third party content, products, or services.
This disclaimer applies universally across all stages of user interaction with the Platform, including registration, browsing, purchasing, delivery, and post-sale support.