PRIVACY POLICY

This privacy and data policy discloses the ways Proshare and its associates gather, use, disclose, and manage 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.

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 and the Nigeria Data Protection Regulation (NDPR) law which came into effect on the 25th of January, 2019.

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.

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.

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

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