PRIVACY POLICY / T&C

This privacy and data policy discloses some or all of the ways Proshare and its associates gathers, uses, discloses, and manages the customer or client's data. Considerable efforts have been made to ensure we comply with the most up to data privacy and data regulation as at the time of issuing this policy statement (including the Data Protection Act 2018).

Specifically, we have ensured we complied with the new General Data Protection Regulation (GDPR) law which came into effect on 25 May, 2018 after being passed by the European Parliament in April 2016.

The legislation should give users of own platform greater control over the way in which companies collect and use their personal data, replacing old rules introduced in 1995 no longer fit for purpose given the subsequent growth of the digital economy.

General Statement

The privacy of our users and visitors is of extreme importance to us at Proshare. This privacy policy statement outlines the types of personal information we receive and collect, and how it is used. This Privacy Policy applies to this Web site, any newsletters or service (Proshare Markets) subscribed to via this Web site, information collected and provided to Proshare when you subscribe digitally to www.proshareng.com or the Proshare Mobile Application, or when in contact with any of the representatives of Proshare Online or Offline.

All data generated by or collected from Proshare or its suite of resources; and its users while visiting 'the website' is the property of Proshare. Any third party collecting or attempting to collect data from Proshare or its users (a "Data Collector") is hereby notified that it is subject to the firms' Privacy Policy.

Any Data Collector is required to contact Proshare at coo@proshareng.com and complete Proshare's data collector certification process. This may include providing additional information about the data being collected and data collecting technology being used; executing the applicable data agreement; and certifying compliance with our technical guidelines and specifications.

Collection and Use Of Your Personal Information

Proshare, or where relevant a designated service provider or staff, collects personal information that you voluntarily provide on this Web site, on our Mobile Application or offline, which may include your name, address, email address, contact information, credit card number, billing information, password etc. For example, Proshare or a designated service provider or staff collects personal information when you register on this Web site, 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.

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.

We use this information for carefully considered business purposes which also benefit our customers and which include some or all of the following:

  • to provide our services and products
  • to communicate with you
  • to help Proshare improve its services and products and develop new services and products
  • to provide support for our services and products, and for Proshare's internal quality control purposes
  • to provide you with offers and promotions about services and products of Proshare or of other parties that may be of interest to you
  • to enhance your experience with this Web site, including to save your preference and login information
  • to analyze web site usage and analyze use of the Web site
  • to protect the interests, rights, safety, or property of Proshare or others and to monitor compliance with and enforce the terms of any agreement with Proshare
  • to operate our services, products, and systems properly.

We use any debit/credit card or payment information we acquire from you to activate your subscription. You may instruct Proshare at any time not to use your personal information covered by this Privacy Policy to provide you with offers and promotions by unsubscribing.

You can also update your personal information however necessary. 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.

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.

Proshare undertakes not to disclose the information provided by the users to any person, unless such action is necessary to:

  • Conform to legal requirements or comply with legal process such as requests of the government, court, tribunal, authority or other regulatory agency and/or required by any law;
  • Protect and defend The Analyst or its Affiliates' rights, interests or property;
  • Enforce the terms and conditions under which its products and/or services are sold; or
  • Act to protect the interests of Proshare, its Affiliates, or its members, constituents or of other persons.

Disclosure Of Your Personal Information

Proshare may share your personal information with our affiliates (including affiliated websites under common ownership or control) and designated service providers, including for the purposes set out in this Privacy Policy. Proshare may share with other third parties information about our Web site users, such as your use of this Web site or other websites, and the services provided on this Web site or other websites, but only on an unattributed and aggregate basis. 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.

If you participate in certain features of this Web site (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.

PProshare 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.

Accuracy, Security, And Retention Of Your Personal Information

Any personal information you provide to Proshare is kept on secure servers. Proshare uses security measures appropriate to the provision of the relevant product or service, such as reasonable administrative, technical, personnel, and physical measures (a) to safeguard personal information against loss, theft, unauthorized use, disclosure, or modification; and (b) to ensure the integrity of the personal information. To help us protect your privacy, you should maintain the secrecy of the logon ID and password you may have set up in connection with your participation in this Web site's service. Personal information is retained for as long as is necessary for the purpose for which it is collected, including legitimate business reasons, and/or legal and regulatory requirements.

Rights With Respect To Your Personal Information

Depending on the jurisdiction, you may have the right to access, correct, delete, or restrict use of certain personal information covered by this Privacy Policy. Depending on the jurisdiction, you may also have the right to request that we refrain from processing personal information. Please bear in mind that if you exercise such rights this may affect our ability to provide our products and services. For inquiries about your personal information, please contact us by clicking here. While Proshare will make reasonable efforts to accommodate your request, we also reserve the right to impose certain restrictions and requirements on such requests, if allowed or required by applicable laws.

Please note that it may take some time to process your request, consistent with applicable law.

Disclosure of Data Breaches

We are required, indeed obliged to report any data breaches or cyberattacks within 72 hours of our becoming aware of it.

Transfer Of Your Personal Information To Other Countries

Some of the uses and disclosures mentioned in this Privacy Policy may involve the transfer and processing of your personal information to and in various countries that may have different levels of privacy protection than your country. By using our products and services, you consent to such transfers and processing, including to and in Nigeria.

Use Of Cookies And Other Electronic Tools

Proshare and the parties with whom we work (e.g., service providers, business partners, advertisers and advertising servers) may place, view, and/or use "cookies", Web server logs, Web beacons, or other electronic tools to collect statistical and other information about your use of this Web site and other websites. This information may 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 this Web site, the Web pages visited, the date and the time of a visit, the websites you visited immediately before and after visiting this Web site, the number of links you click within this Web site, the functions you use on this Web site, the databases you view and the searches you request on this Web site, the data you save on or download from this Website 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 this Web site (such as by enabling log-in, providing access to certain sections of this Web site, providing customized content, or presenting online advertising on this Web site or other websites tailored to your interests as described further below), to compile aggregate and anonymous information about usage of this Web site and other websites, 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 this Web site or other websites 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 this Web site or other websites 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 this Web site, such as the polls, surveys, contests, and product sales, and certain areas of the Web site for which you need to log in, will not function properly, and the advertising you receive when you visit this Web site may not be advertisements tailored to your interests.

Proshare Nigeria

Advertisements

Proshare, its designated service providers, or third-party advertisers or their advertising servers may also place or recognize unique cookies on your computer or use other electronic tools in order to help display advertisements that you see on this Web site or on other websites. Information about your visits to, and activity on, this Web site and other websites, an IP address, the number of times you have viewed an advertisement, and other such usage information is used, alone or in combination with other information, to display on your device screen advertisements that may be of particular interest to you. We may use Web beacons, provided by third-party advertising companies, to help manage and optimize our online advertising and product performance. Web beacons enable us to recognize a browser's cookie when a browser visits this Web site, and to learn which banner ads bring users to this Web site.

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.

ADVERTISING CODE & GUIDELINES

The Proshare Advertising Code & Guidelines ("the Code") adopted by Proshare sets the criteria for acceptable advertising on all proshare suites/domains.

Created since 2009 to promote the professional application of best practice advertising guidelines for an investment portal, the Code is the cornerstone of our ethical application of self-regulation in the discharge of our responsibilities.

Administered by the board of directors, the Code is regularly updated to ensure it is current and keeps pace with consumer, regulatory and societal expectations. It contains 28 clauses that set the criteria for acceptable advertising that is truthful, fair and accurate.

More than that, it provides a clear-cut resolution of possible conflict of interest, role and opinion that may arise where journalists, analysts and researchers issue news, reports and opinion on entities previously, currently or proposing to advertise with, and on the proshare platform(s).

Proshare recognizes that when used professionally and fairly, online advertising provides the consumer/client with needed and useful information; and investors the basis to use such communication as they deem fit. Proshare therefore believes that online advertising for a market data firm should be patterned along the following guidelines:idelines:

General Policies

  • The intent and connotation of the adverts placed would be to inform and never to discredit or unfairly attack competitors, competing products and services..
  • The advert would compare related or similar properties of the product or service dimension to dimension and feature to feature.
  • The identification promos for the advert would be for honest comparison purposes and not simply to upgrade by association.
  • In all cases, the advert would be supportive of its claims in its communication effect and purpose.
  • The advert by its very nature will not distort facts and by implication not convey to the consumer information that misrepresents the truth.
  • The advertisement would never use partial or insignificant results to cause improper conclusion for consumers.
  • The advertisement would be fairly and properly communicated but never in a manner or tone that reduces the objectives or philosophy of the organization.
  • Comparatives delivered through the use of testimonials would not imply that the testimonials are more than one individual's thoughts unless, that individual represents a sample of the majority view point.
  • Comparisons, if made would be significant in terms of value or usefulness of the product or service to the consumer.
  • Advertiser will promptly respond to any complaints by consumers/clients on a particular advert or campaign
  • Refunds will not be made for suspended or truncated campaigns. Proshare however may consider in rare cases saving the paid charges of such a campaign for another future campaign.

Conflict of Interest Disclosures

  • The advertising service is separate and distinct from the Independent Analyst Service rendered by Proshare; ensuring that advertising services do not conflict with the analyst's opinion.
  • The research analyst(s) are primarily responsible for the preparation and content of all or any identified portion of this research report hereby certifies that all of the views expressed herein accurately reflect their personal views about those issuer(s) or subject securities.
  • Each research analyst(s) also certify that no part of their compensation was, is, or will be, directly or indirectly, related to the specific recommendation(s) or view(s) expressed by that research analyst in any given report; unless otherwise disclosed.
  • In situations where Proshare is not satisfied that our arrangements to handle conflicts are sufficient to prevent a conflict from potentially harming your interests, we will disclose the nature and source of the conflict to you and if appropriate, obtain the permission of the advertiser to proceed with the service.
  • For further information on how we handle conflict of interest, see our policy below.

Creative Work /Technical Guidelines

  • All creative work and technical details including words, service propositions and deliverables carried on Proshare website are the sole responsibility of advertisers.
  • Proshare however reserves the right to reject or deny any claim it knows, believes or considers to be or appear as a misrepresentation of reality to the public's it serves.
  • Where Proshare agrees to use its competence to design, create and load adverts for and on behalf of advertisers, it does so with the client/advertisers acknowledgment of liability for the message(s) promoted.

Links to Other Websites

  • Proshare website may contain links or references to other websites. Please be aware that Proshare does not control other websites and that our terms and conditions relating to third party websites apply here. We are not responsible for, nor do we endorse, the contents of these other websites. If you in any way rely on information obtained from any such websites, you do so at your own risk.

Approved 3rd Party Advertising & Ad Merchants

  • Currently Proshare does not have any affiliation with third party Ad merchants and do not carry adverts not directly sourced from clients that comply with the code.
  • By the nature of our service, we work with and through partners whom we support by promoting their businesses through mentions and hyperlinks. This is in no way an endorsement but a business courtesy we consider appropriate to reflect their commitment and application to providing high quality content for the site.
  • Generally, online social media resources are interactive tools that enable you to collaborate and share information with others. Social media resources include but are not limited to social networks, discussion boards, bulletin boards, blogs, wikis, and referral functions to share web site content and tools with a friend or colleague. Proshare deploys these resources and encourages users to sign up for them. We may share advertising on the site as may be deemed necessary to bring users into awareness of new developments in the market or promotional campaigns that they may benefit from..

Space Rental & Revolving Door Options

  • Our AD-Space Rental option allows advertisers to run multiple campaigns off the spaces provided for tenure-bound adverts at no extra cost. This is done to avoid a situation where advertisers are exploited for choosing to change their minds or seek to reduce their cost per space paid for.
  • The revolving door option signposts the process through which the AD manager manages adverts on the site in such a way as to ensure that advertisers are not giving undue preferences over the other for same services. Adverts are attached weights which are pre-approved by the management based on a model guiding the advert rates submitted to clients.

Commissions & Trade Discounts

  • Commissions are only approved for members of staff of Proshare and Ad Agencies duly appointed by Proshare and supported by an agreement of service contract.
  • Proshare does not pay commissions to members of staff of client companies.
  • Trade discounts are as advised by the Business & Markets unit, approved by the board of directors and administered by the Finance function. It categorically recognizes three scenarios repeat customers, cash-paying customers and partner advertisers who pay ahead for contracts of one year and more. The credit for the discount so granted is to the account of the advertising entity/client; and is reflected on invoices issued.

Proshare Nigeria

Links To Third-Party 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.

For how long is your personal information retained by us?

Unless we explain otherwise to you, we'll hold your personal information based on the following criteria:

  • For as long as we have reasonable business needs, such as managing our relationship with you and managing our operations
  • For as long as we provide goods and/or services to you and then for as long as someone could bring a claim against us; and/or
  • Retention periods in line with legal and regulatory requirements or guidance.

What are your rights under data protection laws?

Here is a list of the rights that you have under the data protection laws. They don't apply in all circumstances. If you wish to use any of them, we'll explain at that time if they are engaged or not. Contact market@proshareng.com to clarify your position. The right of data portability is only relevant from May 2018.

  • The right to be informed about the processing of your personal information
  • The right to have your personal information corrected if it is inaccurate and to have incomplete personal information completed
  • The right to object to processing of your personal information
  • The right to restrict processing of your personal information
  • The right to have your personal information erased (the "right to be forgotten")
  • 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")
  • Rights in relation to automated decision making which has a legal effect or otherwise significantly affects you

Questions Regarding this Privacy Policy

If you have questions regarding this Privacy Policy, please contact us by sending an e-mail to info@proshareng.com. Please include "Privacy Policy" in the subject line of your inquiry.

Revision to this Privacy Policy

Proshare reserves the right to change or modify this Privacy Policy at any time in order to reflect changes in the law and/or our privacy practices. Such changes will be effective immediately after posting, whether dated or not. We encourage you to check this notice whenever you visit our website - www.proshareng.com

Security

The user shall cooperate with Proshare in order to ensure the security of the information, and we recommend that the users necessarily choose their passwords carefully such that no unauthorized access is made by a third party. The users should undertake not to disclose their password to anyone or keep any written or other record of the password such that a third party could access it.

Proshare Nigeria

COPYRIGHT POLICY

If you are a copyright owner or an agent thereof and believe that any content on this site infringes upon your copyrights, your may submit a notification pursuant to the Digital Millennium Copyright Act ("DMCA") by providing our designated agent or responsible official with the following information in writing:

  • The name(s) and contact of the person authorized to act on behalf of the owner of an exclusive right that is allegedly infringed for necessary courtesy;
  • Identification of the copyrighted work claimed to have been infringed, or, if multiple copyrighted works on the site are covered by a single notification, a representative list of such works on the site;
  • Identification of the material that is claimed to be infringing or to be the subject of infringing activity and that is to be removed or access to which is to be disabled, and information reasonably sufficient to permit us to locate the material;
  • Information reasonably sufficient to permit us to contact you, such as an address, telephone number, and, preferably an e-mail address;
  • A statement that you have a good faith belief that use of the material in the manner complained of is not authorized by the copyright owner, its agent or the law; and
  • A statement that the information in the notification is accurate, and under penalty of perjury, that you are authorized to act on behalf of the owner of an exclusive right that is allegedly infringed.

Written notification of claimed infringement must be submitted to:

The Chief Operating Officer, Proshare, Proshare Nigeria Limited, The Upper Room, Plot 1, Lekan Asuni Close, Off Toyin Omotosho Street, Omole Phase II, Isheri LGA, P.O. Box 18782, Ikeja, Lagos, Nigeria. Phone: +234 1 762 4131 E-mail: info@proshareng.com

If you are seeking permission to use our content or trademark or copyrighted work, kindly contact us via info@proshareng.com or/and at the address above by submitting a letter titled: "Conformation of Compliance with Best Practice Reprint and Reuse" addressed to the Chief Operating Officer (COO), Proshare.

Comments in Discussion Forum / Site

These rules describe the community practices of Proshare. Registration for our website forums, blogs and social media linkages is free, but we do expect you to observe our usage terms and conditions, which are intended to make your use of this website professional and informative.

Please read them carefully. If you post comments on Proshare website you are agreeing to adhere to these terms; and it applies every time you post a comment.

  • You are responsible for keeping your passwords and usernames safe and if a posting is made using your name and password it will be considered to have been posted by you.
  • You agree that you will not post any messages on any of our Discussion Forums and site that is either unlawful, threatening, abusive, harassing, defamatory, libelous, deceptive, fraudulent, invasive of another's privacy, sexually explicit, pornographic or otherwise breaches the terms stated here and/or the subscriber agreement, terms & conditions of the website, and privacy policies

We want to encourage creative, original and thought-provoking discussions. The comments in our forums, blogs and news posts are not to be used as a free platform for the following:

  • Personal attacks on others, to make disparaging remarks about any person or entity..
  • Interfere with anyone else's use and enjoyment of the website.
  • Content which abuses, threatens, promotes, or instigates physical harm or death to others, or yourself;
  • Victimise, harass, degrade or intimidate an individual or group of individuals on the basis of religion, gender, sexual orientation, race, class, education, ethnicity, age, or disability.
  • Infringe on any patent, trademark, copyright, right of publicity, or other intellectual property right of any party.
  • Contains software viruses' computer codes, files or programs to disrupt, damage, or limit the functioning of any software, hardware, or telecommunications equipment or to damage or obtain unauthorised access to any data or other information of any third party.
  • Impersonate any person or entity. Including any of our employees or representatives.
  • Disrupt normal flow of dialogue.
  • Contain non related comments to the topic, subject or news under discussion.
  • Discussion is not acceptable in any other language except English, and must not be in a manner deemed inappropriate by ourselves.
  • You agree you will never intentionally create market abuse by making false, misleading statements relating to investment prices and performances. Market abuse is an offence which could lead to fines or imprisonment.
  • You agree that you will not post, either intentionally or otherwise, any material that could have the effect of manipulating the market value of any investment.
  • You must not offer to buy or sell any investment or product or use the discussion boards to advertise any product or service.
  • You agree that you will not post information that you know to be confidential or sensitive or otherwise in breach of the law. You should only post material that you know to be public knowledge. If you have any doubts do not post it on the site.
  • You will not retaliate to offensive posts. This causes problems for other users. You must report such messages to us and we will fully investigate every report we receive.

NB: If you see or receive any communication in our website that does not comply with these Terms or that you consider is inappropriate, please report this immediately to info@proshareng.com. We do not monitor the comments nor do we exercise any form of editorial control or censorship of any message on our news posts, forums and blogs but will act once such is noticed or brought to our attention.

  • Never attempt to gain unauthorized access to any area of the site. This is known as hacking and it is illegal.
  • You must not create multiple identities, this is strictly prohibited. Any user found to have multiple identities will be removed from our website permanently.
  • Remember, the details you supply and all messages are recorded and kept, including your originating IP address and this information may have to be disclosed to any regulatory or criminal authority or third party, and law enforcement agencies will be able to trace your activity to a specific machine, whether or not you use a fake or real name or email address.
  • You expressly understand and agree that neither Proshare nor its affiliates and principal will accept any responsibility for information posted on the website or any investment decisions made based on any information posted on the website. You further understand that we make no warranties in respect of, nor do we guarantee the accuracy, integrity or quality of any content posted.
  • If we receive notice that any posting or your intended use of the Discussion Forum is not in keeping with these Terms, Proshare may remove that posting and/or any other related postings and/or disable your user name and password, permanently or temporarily and take all such steps as may be necessary to protect the company's position.

*Disclaimer: Quotes from the website including comments made thereon may be used in news articles as these are purely for editorial comment.

Proshare Nigeria

CONFLICT OF INTEREST

There may be various points when we provide services to you where our interests and or those of our staff conflict with your interests. Equally, your interests may occasionally compete with those of other clients.

Where we are aware, including being made aware, that we are faced with a situation of competing interests, we will undertake all reasonable steps to protect your interests and ensure your fair treatment, in line with the duties we owe you as our client.

Proshare has a policy in place to handle conflicts of interest so that we act with an appropriate degree of independence from our own interests when transacting with you or dealing on your behalf. The policy ensures that we identify, prevent and manage conflicts of interest, including ongoing monitoring of the effectiveness of the arrangements. The policy is regularly reviewed by senior management to ensure our arrangements remain robust and fit for purpose.

Some of the conflicts that could arise are shown below, we expect you to consent to us acting in these situations:

Examples of such situations include:

  • where we carry out business for and on behalf of other clients, partners and entities;
  • where we deal on your behalf through an associate or where an associate is otherwise receiving an agent's commission;
  • where we effect or arrange transactions in which we or an associate benefits from a commission, fee, mark-up or markdown and/or in respect of which we, or an associate, may also be remunerated by the counterparty to the transaction;
  • where we match your transaction with that of another client by acting on their behalf as agent as well as yours;
  • where we execute a transaction in circumstances where we have knowledge of other actual or potential transactions in the investment concerned;
  • where we or our associates are involved in or act in respect of a new issue, rights issue, takeover or any other transaction or have any other relationship with an issuer of investments which is relevant to investments in which we deal on your behalf or make recommendations

We will ensure that transactions into which we enter on your behalf are on terms that are not materially less favourable to you than if no potential conflict had existed.

When conducting business for you, we may receive from or pay to a third party commissions or other benefits in relation to that business. For any such commissions or benefits, we will ensure that these arrangements provide for an enhancement of the service to which they relate and that they do not prevent us from acting in your best interests.

For any business where you are introduced by a third party, we may have made a payment to the introducer or pay ongoing commissions. You may request details of these payments.

We provide a range of services and may possess information of a confidential or non-public nature which we are under a duty not to disclose or use for our own benefit or anyone else. We will therefore be unable to use this information on your behalf or disclose it to you. In providing our services under the Agreement, we are not obliged to disclose or take into consideration any information, fact or matter that disclosure of which would be a breach of a duty of confidentiality to any other person or result in a breach of any applicable law or regulation.

Proshare Nigeria

CONTENT PARTNERSHIP

To help us serve you better, Proshare actively seeks and identifies quality relationships and joint venture engagements between service providers, operators, researchers, data owners, brands, broadcasters, publishers and independents to create original content for dissemination across our platforms.

Some of these relationships are paid for either as sponsorship packages or as barter arrangements that allow parties co-finance and share the exploitation rights to that content and its intellectual property.

Interested collaborators should kindly contact market@proshareng.com or/and coo@proshareng.com to discuss how they can participate.

For further information on this Privacy and Data Policy, feel free to call us at 0700 PROSHARE or e-mail contact@proshareng.com

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