Fidelity Securities Limited (“us”, “we”, or “our”) is a company limited by shares and licensed by the Securities and Exchange Commission (“SEC”) as a Fund Manager in Ghana. We manage Institutional Funds (Pensions, Provident Funds, and Endowments among others), Collective Investment Schemes and Individual Wealth portfolios of our customers (data subjects). For this purpose, FSL may also be referred to as the data controller for the information we process unless otherwise stated.
This privacy policy governs your use of our service, and explains how we collect, process, safeguard and disclose information about you.
We will only process information where you have given us the information directly as a data controller or by our partners where we are processors in accordance with their instructions and in line with our obligations and your rights under the Data Protection Act, 2012 (Act 843), the EU General Data Protection Regulation (GDPR) and other Jurisdictional Data Protection laws that are applicable.
We only collect personal information that is necessary, relevant, and not excessive for the purpose of our processing. The type of personal information that we may collect and process about you when you interact with us includes the following:
We may, in specific circumstances, process other information such as your subscriptions and services used.
You are under no obligation to provide us with your personal information; however, certain basic information may be required for us to be able to provide you with the service or request made by you. Where this is the case, we will advise you at the point of obtaining the information.
We collect personal information directly from you when you complete the account opening forms or engage with us through various channels. Where we collect your personal information indirectly from you, we will contact and inform you of where we obtained the information from. The following are the various
ways we collect information from you.
When you contact us for assistance through our contact center or other channels
The purposes for which we process your personal data include one or more of the following;
We will only process your personal data for the specific purpose that we state at the point of collection and when the law allows or requires us to do so. Most commonly, we will use your personal data in the following circumstances:
Below is a description of the ways we may use your personal data, and the legal basis upon which we may do so. We have also identified what our legitimate interests are, where appropriate.
Type of processing activity | Lawful basis |
To enable us create an investment account for you. | Performance of a contract |
To enable us provide investment related services to you | Performance of a contract |
To fulfill a contract that we have entered into with you or with the entity you represent. In these circumstances, it may be your entity, rather than yourself, that has provided us with your personal data for us to fulfill the contract. | Performance of a contract |
To ensure the security safeguard of your data and underlying business infrastructure. | Legitimate interest |
To manage any communication between you and us. | Legitimate interest |
Marketing /mailing list /subscriptions to newsletters | Consent |
We will not share your information with third parties unless any of the following circumstances apply;
If you require details of the third parties your data has been shared with and how this information is used please contact us at fidelitysecurities@fsl.com.gh or Hotlines: 0241695296, 0257960724
Security safeguards are of high importance to us, and therefore, we believe we have appropriate technical and organizational security measures and controls in place to protect your information. Some of the steps that we have implemented include implementing access controls and encryption to our information technology and systems. We do not, however, have any control over what happens between your device and the boundary of our information infrastructure. You should be aware that there are many information security risks that exist and take the appropriate steps to protect your own information.
We will retain your personal information only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your personal information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
Your personal information, may be transferred to, and maintained on computers located outside of your country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.
Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.
We will take all the steps reasonably necessary to ensure that your information is treated securely and in accordance with this Privacy Policy and no transfer of your personal information will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.
The Data Protection Act, 2012 (Act 843) provides some basic rights to data subjects. These are;
You have the right to be informed about the processing of your personal information (personal data) that we do. This privacy notice is a way of ensuring we meet our obligations to enable you exercise your right to be informed.
You have the right to access the personal information that we hold about you. This is sometimes termed a ‘Data Subject Access Request’. We will ask for proof of identity and sufficient information about your interactions with us so that we can locate your personal information when you make such a request. If you want to exercise this right, please contact us as set out below.
Where information we hold about you is inaccurate, incomplete, or out of date, you may ask us to correct or update it at any. You also have the right to block us from further processing of your personal data where we do not have any legitimate or legal basis for processing your personal data. In certain circumstances, you may also instruct us to delete your personal data. The right of erasure or destruction is not absolute and only applies in certain cases. If you would like to exercise this right, please get in touch with us as set out below.
Under this right, you can give us notice in writing to cease or not or not start processing your personal data for a specific purpose or manner which will cause or is likely to cause any unwarranted damage or distress. You can also prevent us from processing your information for direct marketing purposes.
Where we rely on your consent to process your personal data, you have the right to withdraw it at any time by contacting us or using any details provide in our communication with you.
As with all the other rights above, you may write to complain if you believe any of your rights have not been met or we fail to meet our obligations as a data controller.
We will ensure the various rights of data subjects where we operate are respected and take our obligations seriously. Where we process personal data of other jurisdictions, we undertake a privacy assessment to identify any potential risk of noncompliance.
You can at t any time give notice in writing to us to exercise your rights. We will within twenty-one (21) days after receipt of a notice, inform you in writing that we have complied or intend to comply with your notice or the reasons if we cannot comply with the request. If you would like to exercise this right, please contact us as set out below.
Email: fidelitysecurities@fsl.com.gh Hotlines: 0241695296, 0257960724
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes or if we change our business in a way that affects personal data protection. Any changes we make will be published and indicated by version number.
