Privacy Policy

This Policy applies to all personal data processed by Quinoa in connection with:

• Investment management services (discretionary and advisory)
• Client onboarding and KYC processes
• Website and digital platforms
• Business relationships with vendors and partners

We may collect and process the following categories of personal data:

a. Identification Information

• Full name, date of birth, gender
• National identification number (NIN), passport, or other ID

b. Contact Information

• Residential and mailing address
• Email address and telephone number

c. Financial Information

• Bank account details
• Investment portfolio details
• Source of funds and wealth information

d. Transactional Data

• Investment transactions and instructions
• Risk profile and investment preferences

e. Technical Data

• IP address, browser type, device information (for website users)

f. Compliance Data

• AML/CFT documentation
• Politically Exposed Person (PEP) status
• Sanctions screening data

We process personal data for the following purposes:

• To provide investment management and advisory services
• To conduct client onboarding, KYC, and due diligence checks
• To comply with legal and regulatory obligations (including SEC and AML requirements)
• To manage client relationships and communications
• To process transactions and maintain records
• To improve our services and digital platforms
• To prevent fraud and ensure security

We process personal data based on:

• Contractual necessity: To perform our obligations under client agreements
• Legal obligation: Compliance with regulatory requirements
• Legitimate interest: Business operations, risk management, and service improvement
• Consent: Where required, particularly for marketing communications

We may share personal data with:

• Regulatory authorities (e.g., SEC Nigeria, CBN, NDPC)
• Custodian banks and financial institutions
• External auditors, legal advisers, and consultants
• Technology service providers and data processors
• Law enforcement agencies where required by law

All third parties are required to maintain confidentiality and comply with data protection obligations.

Where personal data is transferred outside Nigeria, we ensure that:

• The recipient country has adequate data protection laws; or
• Appropriate safeguards (e.g., contractual clauses) are in place

We retain personal data only for as long as necessary to:

• Fulfill the purposes outlined in this Policy
• Comply with legal, regulatory, and contractual obligations

Typically, client records are retained for a minimum period as required under Nigerian financial regulations.

We implement appropriate technical and organizational measures to protect personal data, including:

• Encryption and secure data storage
• Access controls and authentication mechanisms
• Regular system monitoring and audits

Despite these measures, no system is completely secure, and we cannot guarantee absolute security.

Under applicable data protection laws, you have the right to:

• Access your personal data
• Request correction of inaccurate data
• Request deletion (subject to legal limitations)
• Object to or restrict processing
• Withdraw consent where applicable
• Lodge complaints with the Nigeria Data Protection Commission (NDPC)

Requests can be made via the contact details below.

We use cookies and similar technologies to remember your preferences and improve your experience on our website. This section describes the cookies we set today. Analytics or advertising cookies may be added in future with an updated version of this policy.

Cookies we use

• cookie_consent — stores your cookie preference (accepted or rejected). Retained for 1 year. Set when you respond to the cookie banner.
• newsletter_popup — remembers that you dismissed or subscribed via the newsletter popup so we do not show it again. Retained for 30 days. Set only if you accepted non-essential cookies.

If you reject non-essential cookies, we do not set the newsletter popup preference cookie and the popup will not appear. You can still subscribe using the newsletter form in the site footer at any time.

You can withdraw consent or reset preferences by clearing cookies in your browser settings. After the consent cookie expires, the banner will appear again on your next visit.

For more information about how we handle personal data, including email addresses collected through newsletter sign-up, see the other sections of this Privacy Policy.

Our services are not directed at individuals under the age of 18. We do not knowingly collect personal data from minors without appropriate consent.

We may update this Privacy Policy periodically. Updates will be published on our website and, where necessary, communicated directly to clients.

For questions, requests, or complaints regarding this Privacy Policy or our data practices, please contact:

Administrator (Data Controller)
info@quinoawealth.com

This Privacy Policy shall be governed by and construed in accordance with the laws of the Federal Republic of Nigeria.

By engaging with Quinoa Asset Managers Limited, you acknowledge that you have read and understood this Privacy Policy.