Envest | Privacy Policy

1. Introduction

Goldenbridge Asset Management Company Limited and its subsidiaries ("Goldenbridge", "we", "our", or "us") are committed to maintaining the privacy, confidentiality, and protection of your personal data.

This Privacy Policy explains how we collect, use, disclose, store, process, and protect your personal information when you access or use the Envest Digital Investment Platform.

Envest is Goldenbridge's digital investment platform through which eligible users may access selected asset management and stockbroking products and services.

This Privacy Policy should be read together with the Platform's Terms and Conditions and any applicable product-specific agreements.

We process personal information in accordance with the Nigeria Data Protection Act (NDPA), 2023, and other applicable Nigerian laws.

2. Scope & Application

This Policy applies to personal information collected through Envest, including during:

Account registration
Digital onboarding
KYC verification
Investment account management
Stockbroking transactions
Subscriptions and redemptions
Customer support interactions
Use of the mobile application
Communications with the Company

This Privacy Policy applies to all users of the Envest Platform.

3. Legal Basis for Processing Personal Data

We process your personal information based on one or more lawful grounds, including:

Your consent
Performance of a contract
Compliance with legal obligations
Protection of vital interests where applicable
Legitimate business interests that do not override your rights and freedoms

4. Personal Information We Collect

Personal Information

Full name
Gender
Mother's maiden name
Date of birth
Nationality
Residential and business address
Email address
Telephone number
Passport photograph
Signature

Identity Verification Information

Bank Verification Number (BVN)
National Identification Number (NIN)
Driver's License
International Passport
Permanent Voter's Card
Other government-issued identification documents

Financial Information

Bank account details
Investment account information
Portfolio information
Transaction history
Payment information
Investment preferences
Account balances

Mobile App & Technical Information

When you use Envest, we may automatically collect:

Device model
Operating system version
Unique device identifiers
IP address
Mobile network information
Browser type
Application version
Login history
Device security information
Crash reports
System logs
Usage analytics

Where enabled by your device settings, the Platform may also collect approximate location information for fraud prevention, security monitoring, or regulatory compliance.

5. How We Collect Your Information

We collect information:

During registration
When completing KYC onboarding
When updating your profile
When submitting investment instructions
Through your use of the mobile app
Through customer support interactions
Through fraud monitoring systems
From identity verification providers
From regulators and publicly available sources where permitted by law

6. How We Use Your Information

We use your information to:

Open and manage investment accounts
Verify your identity
Comply with KYC, AML, and regulatory obligations
Process subscriptions and securities transactions
Provide investment services
Generate statements
Send important account notices
Prevent fraud and cyber threats
Improve Platform security
Enhance customer experience
Support audits and regulatory reporting

7. Data Retention

We retain personal information only for as long as necessary to fulfil legal, contractual, and regulatory obligations.

Customer records are generally retained for a minimum of seven (7) years, or longer where required by applicable law.

8. Disclosure of Personal Information

We may disclose personal information to:

Regulatory authorities
Law enforcement agencies
Courts
Auditors
Tax authorities
Legal advisers
Goldenbridge affiliates
Payment service providers
Cloud hosting providers
Identity verification providers
Custodians
Registrars
CSCS
NGX
Technology service providers operating under confidentiality obligations

We do not sell your personal information or disclose it for unrelated third-party marketing purposes.

9. Cookies & Similar Technologies

Envest may use cookies, SDKs, and device identifiers to:

Authenticate users
Maintain secure sessions
Remember preferences
Improve performance
Analyze usage
Detect fraudulent activity

10. Push Notifications

Where enabled, Envest may send notifications relating to:

Transaction confirmations
Investment updates
Security alerts
Maintenance notices
Regulatory communications
Other essential service notifications

11. Third-Party Services

The Platform may integrate with trusted providers for:

Payment processing
Identity verification
Banking services
Cloud hosting
Communication services
Market infrastructure
Fraud detection
Regulatory reporting

12. Third-Party Website Links

Our Platform may contain links to third-party websites.

We are not responsible for their privacy practices and encourage users to review their privacy policies.

13. Your Data Protection Rights

Under applicable law, you may have the right to:

Access your personal data
Correct inaccurate information
Request deletion where legally permissible
Object to certain processing
Request data portability
Withdraw consent where applicable
Lodge a complaint with the Nigeria Data Protection Commission (NDPC)

We may request proof of identity before processing such requests.

14. Data Security

We employ appropriate technical and organizational safeguards, including:

Secure servers
Encryption
Role-based access controls
Regular backups
Security monitoring
Staff confidentiality obligations

While we strive to protect your information, no system is completely foolproof. Users should also safeguard their own devices and credentials.

15. Children's Privacy

Envest is intended for persons legally capable of entering binding contracts under Nigerian law.

We do not knowingly collect personal information from minors except where legally permitted and accompanied by appropriate consent.

16. International Data Transfers

Where transfers outside Nigeria become necessary, we will ensure appropriate safeguards in accordance with the Nigeria Data Protection Act, 2023.

17. Policy Updates

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, or legal requirements.

Updates will be published with a clearly indicated effective date.