Privacy Policy

PRIVACY POLICY

NCL Investments Ltd

Effective Date: 24 October 2026
Last Updated: 24 October 2026
Website: https://ncl.stock-sofitrade.com/

1. Introduction

NCL Investments Ltd (“NCL Investments,” “NCL,” “we,” “our,” or “us”) respects your privacy and is committed to protecting the personal information of individuals who visit our website, create an account, use our services, or communicate with us.

This Privacy Policy explains how we collect, use, store, disclose, and protect your personal information when you access our website at https://ncl.stock-sofitrade.com/ or interact with our investment-related services.

By accessing our website or using our services, you acknowledge that you have read this Privacy Policy. Where applicable law requires consent for particular processing activities, we will seek that consent separately.

We aim to handle personal information transparently, responsibly, and in accordance with applicable data-protection laws, including the Nigeria Data Protection Act 2023 where applicable.

2. Information We Collect

Depending on how you interact with our website and services, we may collect the following categories of information.

2.1 Personal Identification Information

This may include:

  • Full name and username.

  • Email address and telephone number.

  • Residential or contact address.

  • Date of birth and other identity-verification information where required.

  • Government-issued identification details where necessary for identity verification or legal compliance.

2.2 Account Information

When you register for an account or use our platform, we may collect:

  • Account registration details and login credentials.

  • Account preferences and profile information.

  • Account status and account activity records.

  • Information required to administer your relationship with us.

We do not intend to collect passwords in readable form. Where passwords are used, they should be protected using appropriate security practices.

2.3 Financial and Transaction Information

Where relevant to the services provided, we may process information relating to:

  • Deposits and withdrawals.

  • Investment selections and account balances.

  • Transaction dates, amounts, and reference numbers.

  • Payment status and transaction history.

  • Records necessary to investigate disputes, prevent fraud, or meet applicable legal obligations.

Payment card details, banking credentials, or other sensitive payment information should be handled by appropriately secured payment providers where applicable. We will describe any relevant third-party processing arrangements in accordance with our actual practices.

2.4 Technical and Usage Information

When you visit our website, certain technical information may be collected automatically, depending on the website technologies in use. This may include:

  • Internet Protocol (IP) address.

  • Browser type and operating system.

  • Device information.

  • Pages visited and approximate access times.

  • Referral information and website interaction data.

  • Security logs and information about attempted unauthorised access.

2.5 Communications and Support Information

If you contact us, we may retain your name, contact details, messages, complaints, enquiries, and related correspondence to respond to your requests and maintain appropriate service records.

3. How We Use Your Information

NCL Investments may use personal information for the following purposes:

  1. Account registration and management: To create, maintain, authenticate, and administer user accounts.

  2. Service delivery: To provide requested investment-related platform services and manage account activity.

  3. Transaction processing: To record, verify, reconcile, and administer deposits, withdrawals, and other supported transactions.

  4. Identity verification: To verify identity where necessary for fraud prevention, security, or applicable legal requirements.

  5. Security and fraud prevention: To detect suspicious activity, protect accounts, investigate potential misuse, and safeguard our website.

  6. Customer support: To respond to enquiries, resolve complaints, and communicate important account information.

  7. Legal and regulatory compliance: To comply with applicable laws, lawful requests, recordkeeping obligations, and other legal requirements.

  8. Website improvement: To understand website performance, identify technical issues, and improve usability where appropriate.

  9. Service communications: To provide transaction notifications, account updates, security alerts, and policy changes.

  10. Marketing communications: To send promotional information where permitted by law and, where required, with your consent.

We will not use your personal information for purposes that are incompatible with the purposes for which it was collected unless permitted by applicable law.

4. Legal Grounds for Processing Personal Information

We process personal information only where an appropriate legal basis applies. Depending on the circumstances, these grounds may include:

  • Consent: Where you have freely agreed to a particular use of your information.

  • Contractual necessity: Where processing is necessary to provide requested services or perform our contractual obligations to you.

  • Legal obligation: Where processing is necessary to comply with applicable laws or lawful regulatory requirements.

  • Legitimate interests: Where processing is necessary for legitimate business purposes, such as website security, fraud prevention, or service improvement, provided your rights and interests are appropriately considered.

  • Other lawful grounds: Where another legal basis recognised by applicable data-protection law applies.

Where we rely on consent, you may withdraw it at any time. Withdrawal does not affect the lawfulness of processing carried out before the withdrawal or processing that has another valid legal basis.

5. Disclosure and Sharing of Information

We do not treat your personal information as a publicly available resource. We may share it only where reasonably necessary for legitimate purposes and subject to applicable legal requirements.

Depending on the services and arrangements in place, recipients may include:

  • Payment service providers: To facilitate and verify supported transactions.

  • Technology and hosting providers: To host, maintain, secure, or support our website and platform.

  • Identity verification and fraud prevention providers: Where verification or risk assessment is required.

  • Professional advisers: Such as legal, accounting, auditing, or compliance advisers who require relevant information.

  • Regulatory and law enforcement authorities: Where disclosure is required or lawfully permitted.

  • Business successors: In connection with a proposed or completed merger, restructuring, acquisition, or transfer of business, subject to applicable privacy requirements.

We expect relevant service providers to handle personal information appropriately and to use it only for authorised purposes.

We do not sell personal information to third parties as a business practice. If our data-sharing practices change materially, we will update this Privacy Policy and provide any notices required by law.

6. Cookies and Similar Technologies

Our website may use cookies and similar technologies to support website functionality, maintain sessions, remember preferences, enhance security, and understand website usage.

Cookies may include:

  • Essential cookies: Necessary for core website functionality, account sessions, and security.

  • Preference cookies: Used to remember selected settings or preferences.

  • Analytics cookies: Used, where enabled, to understand how visitors interact with the website.

  • Marketing cookies: Used, where applicable, to support advertising or marketing measurement.

Where required by law, we will obtain consent before placing non-essential cookies or using similar tracking technologies.

You can manage cookies through your browser settings and, where available, our website's cookie preference controls. Disabling certain cookies may affect the functionality of some website features.

7. Data Storage and Retention

We retain personal information only for as long as reasonably necessary to fulfil the purposes described in this Privacy Policy, provide our services, resolve disputes, enforce applicable agreements, and comply with legal or regulatory obligations.

Retention periods may vary depending on the type of information and the reason it was collected. For example, account records, financial transaction records, identity-verification records, and security logs may be subject to different retention requirements.

When personal information is no longer required, we will take reasonable steps to delete, anonymise, or securely dispose of it, subject to applicable law and any legitimate requirement to preserve the records.

Closing an account does not necessarily mean that all associated records can be deleted immediately.

8. Information Security

We recognise the importance of protecting personal and financial information against unauthorised access, disclosure, alteration, loss, or destruction.

Depending on the systems and services in use, appropriate safeguards may include access restrictions, secure authentication, encryption where appropriate, monitoring, backups, and security assessments.

However, no website, electronic transmission, or storage system can be guaranteed to be completely secure. We therefore cannot promise absolute security.

You are responsible for keeping your login credentials confidential, using appropriate security measures on your devices, and promptly notifying us if you suspect unauthorised access to your account.

If a personal data breach occurs, we will assess and respond to it in accordance with applicable legal requirements.

9. International Transfers of Personal Information

Some of our technology providers or service providers may process or store personal information outside Nigeria or your country of residence.

Where personal information is transferred across borders, we will take steps required by applicable law to ensure that the transfer has a valid legal basis and that appropriate safeguards are in place.

Where required, we will provide information about relevant transfers, recipients, and safeguards upon request, subject to applicable legal restrictions.

10. Your Privacy Rights

Subject to applicable law and any lawful limitations, you may have the right to:

  • Access: Request information about the personal information we hold about you.

  • Correction: Request the correction of inaccurate or incomplete information.

  • Deletion: Request deletion of personal information where the applicable legal conditions are satisfied.

  • Restriction: Request that certain processing activities be restricted in appropriate circumstances.

  • Object: Object to processing carried out on certain legal grounds, including certain direct-marketing activities.

  • Withdraw consent: Withdraw consent where processing relies on your consent.

  • Data portability: Request a copy of eligible personal information in a commonly used, machine-readable format where the law provides this right.

  • Complain: Lodge a complaint with the relevant data-protection authority where you believe your privacy rights have been infringed.

To exercise your rights, contact us using the contact details provided in Section 16. We may need to verify your identity before responding.

We will respond to valid requests within the period required by applicable law. Certain requests may be declined or limited where a lawful exemption or other legal obligation applies, and we will explain this where required.

11. Direct Marketing and Communications

We may send service-related communications necessary to administer your account, process transactions, communicate security issues, or provide important notices.

Where permitted, we may also send promotional communications about our services. You may opt out of marketing communications by using the unsubscribe facility, where available, or by contacting us directly.

Opting out of marketing messages will not prevent us from sending essential service, security, transactional, or legally required communications.

12. Third-Party Websites and Services

Our website may contain links to third-party websites, payment services, or other external platforms.

Those third parties may have their own privacy policies, security practices, and terms of service. We do not control the privacy practices of independent third parties and are not responsible for their policies or content.

We encourage you to review the relevant privacy policy before submitting personal information to any external website or service.

13. Children's Privacy

Our investment-related services are not intended for individuals who are below the minimum age legally permitted to use those services.

We do not knowingly collect personal information from children in circumstances where such collection is prohibited by applicable law. Where we discover that personal information has been collected unlawfully from a child, we will take appropriate steps to address the matter.

Where age restrictions, parental consent, or additional safeguards are required by law, those requirements will apply.

14. Automated Processing and Account Monitoring

We may use automated systems or technical tools, where implemented, to support account security, identify suspicious transactions, detect misuse, and assess operational risks.

Where applicable law grants you rights concerning decisions made solely through automated processing that significantly affect you, you may request information about the relevant processing and exercise any available rights, including requesting human intervention where legally applicable.

We will handle such requests in accordance with applicable law.

15. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our services, data-handling practices, technology, or legal obligations.

When we make changes, we will publish the revised version on this page and update the “Last Updated” date.

Where a material change requires additional notice or consent under applicable law, we will take the appropriate steps.

We encourage you to review this page periodically to remain informed about how your personal information is handled.

16. Contact Us

If you have questions about this Privacy Policy, wish to exercise your privacy rights, or have a complaint concerning the handling of your personal information, please contact:

NCL Investments Ltd

Website: https://ncl.stock-sofitrade.com/
Privacy enquiries email: [Insert official privacy email address]
General support email: [Insert official support email address]
Business address: [Insert registered business address]
Telephone: [Insert official contact number]

Please include sufficient information to help us understand your enquiry. Do not send passwords, full payment card details, or other unnecessary sensitive information in an ordinary email.

17. Applicable Law

This Privacy Policy shall be interpreted in accordance with applicable data-protection and privacy laws, including the Nigeria Data Protection Act 2023 where applicable, together with any other laws that apply to our operations and your relationship with us.

Nothing in this Privacy Policy is intended to exclude or restrict any privacy rights that cannot lawfully be excluded or restricted.

End of Privacy Policy


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