1. Introduction/Scope

Thank you for choosing Octave Partners Limited (“Octave”, “we”) values your Personal Data and we are committed to protecting the personal data of individuals, clients, vendors, and even third parties that interact with us. This Privacy Policy is prepared in accordance with the provisions of the Nigerian Data Protection Act (NDPA) and, by extension, the EU General Data Protection Regulation (GDPR). Please read this Privacy Notice (Notice) to understand our policies, processes and procedures regarding the processing of your personal data.

By this Notice, we explain to you how your Personal Data is collected, used, managed and transferred by Octave Partners Limited and explain how you can update your Personal Data with us and exercise your rights in respect of the Personal Data provided to us.

2. Who We Are

At Octave Partners Limited we bridge the gap between providers of capital, entrepreneurs & companies that require it. We provide finance-related services to clients in Africa and beyond through:

  • Financial Advisory
  • Business Accelerator
  • Business Advisory
  • Investment Advisory

We bring local and international experience and leverage partnerships to assist our clients to achieve their financial and business goals. Due to the nature of our business, we are required to collect and process the personal data of our clients

3. About The Policy

We appreciate your interest in our products and services and your visit to this website. Your privacy is important to us, and we want you to feel comfortable with how we use and share your personal information. This policy sets out how Octave handles your personal information, including when and why it is collected, used and disclosed and how it is kept secure.

This policy may change, we advise you to check this page from time to time to ensure that you are satisfied with any changes.

4. Why Do We Need the Data?

Octave ensures that the personal data collected and processed is necessary for the purpose of collection and shall not collect or process more data than is reasonably required for a particular processing activity. In addition, every processing purpose has at least one lawful basis for processing to safeguard the rights of the data subjects, as listed below:

Purpose of Processing Lawful Basis of Processing
Account creation, identity verification and

maintenance of records

 Compliance with a legal obligation in which

Octave is subject/contract.
Vendor validation/information processing Contract
Employment Contract

Where Legitimate Interest is considered the legal basis for processing personal data, Octave shall follow the steps below in carrying out a Legitimate Interest Assessment.

a. Determine the Purpose for Processing

In carrying out the purpose test, Octave will establish the exact reason for the processing and how it benefits the organization. Answers to the following shall be provided to determine the exact purpose for processing:

  • Description of the processing objective
  • The likelihood of meeting the objective and how to determine if the objective was met
  • The benefits of the processing and the significance to the organization
  • Description of the possible impact of not processing and any other issues that might be relevant

b. Determine the Necessity of the Processing

Octave will establish why the processing must take place, how the processing relates to the expected benefits, and any other alternatives and why they were not considered.

c. Balance the identified interest with the Privacy Interest of the Data Subjects

The following questions will be addressed under the balance test:

  • Who are the data subjects (category)?
  • What is the relationship between Octave and the data subject
  • What personal data is to be processed
  • How will the processing impact the data subject
  • How will the data subject react to the processing

Octave records this information in line with this policy, data protection impact assessment, and data inventory.

5. How and What Information We Collect

Octave will request for your personal information which includes your name, contact details (such as phone number, email address and physical address), enquiry details and your opinion of our products and services. The information about you that you give to us via our websites or our social media pages or by corresponding with us by phone, email or otherwise and is provided entirely voluntarily.

In addition to the above we will also store your personal information only if you share that information; for instance, by filling out a registration form, contact form, survey, contest entry or to execute a contract. In such cases, we will store only the data we are allowed to keep based on consent given by you or in accordance with the Nigeria Data Protection Act (“NDPA”). While there exists no binding legal or contractual imperative mandating the disclosure of your personal information, it is crucial to acknowledge that specific functionalities inherent to our digital platform might be contingent upon the divulgence of said personal data. Failure to furnish such information in these particular instances could potentially preclude your access to these features, rendering them either wholly inaccessible or substantially diminished in operational capacity.

6. Utilization of Your Personal Information

We may use and process your personal information where you have consented for us to do so for the following purposes:

  • to share your personal information with our authorized employees for contract/engagement purposes
  • to contact you via email, text message, post or telephone with marketing information about Octave products and services
  • to provide personalized financial advice and investment recommendations based on your financial profile, risk tolerance, and investment objectives
  • to conduct financial analysis, portfolio monitoring, and performance reporting to support ongoing client relationship management
  • to fulfill regulatory compliance requirements including client due diligence, anti-money laundering checks, and regulatory reporting obligations
  • to complete other processing activities that you have expressly requested us to complete, or you have expressly agreed to us performing.

You may possess the prerogative to revoke your consent for the utilization of your information in any of the aforementioned manners at your discretion and at any given moment. We may use and process your personal information where it is necessary for the performance of a contract with you or in order to take steps at your request before entering into a contract with you including, but not limited to, for the following purposes:

  • to exchange information with potential investors who have an interest in what you do and are willing to invest
  • to exchange information with financial institutions who have an interest in what you do and are willing to invest

Your personal information will be utilized in accordance with our legal responsibilities, which include, but are not restricted to:

  • aiding governmental agencies, law enforcement bodies, or any other relevant public authority or entities engaged in criminal investigations
  • confirming your identity when you make contact with us; and
  • validating the accuracy of the data we retain about you.

We may use and process your personal information where it is necessary for us to pursue our legitimate interests as a business for the following purposes:

  • aiding governmental agencies, law enforcement bodies, or any other relevant public authority or entities engaged in criminal investigations
  • to inform our marketing strategy, and to enhance and personalize your customer or visitor experience
  • for market research in order to continually improve the products and services that we deliver to you
  • to administer our websites and for internal operations, including troubleshooting, testing, and statistical purposes
  • for marketing activities (other than where we rely on your consent) e.g. to tailor marketing communications or send targeted marketing messages via social media platforms
  • for the prevention of fraud and other criminal activities
  • to correspond and communicate with you
  • to create a better understanding of you as a customer or visitor
  • for network and information security in order for us to take steps to protect your information against loss or damage, theft or unauthorized access
  • to comply with a request from you in connection with the exercise of your rights (for example where you have asked us not to contact you for marketing purposes, we will keep a record of this on our suppression lists in order to be able to comply with your request)
  • for the purposes of corporate restructuring or reorganization or sale of our business or assets
  • for efficiency, accuracy or other improvements of our databases and systems e.g. by combining systems or consolidating records we hold about you
  • to enforce or protect our contractual or other legal rights or to bring or defend legal proceedings; and
  • or general administration including managing your queries, complaints, or claims, and to send service messages to you.

7. Data Retention

We shall retain your personal information for a duration deemed essential, in accordance with the initial intent of its acquisition, (including as required by applicable law or regulation).

Subsequently, upon the point at which your personal data no longer serves a requisite or pertinent function in our defined objectives, or upon your express indication of disinterest in maintaining communication with us, we shall ensure the secure and thorough disposal of said personal data.

8. Data Security

We have established technical and organizational security measures designed to safeguard your personal information against inadvertent loss, unauthorized utilization, unpermitted access, unauthorized alteration, or inadvertent disclosure and we are continuously improving our security measures in line with technological advancements.

Octave restricts access to your personal data exclusively to employees who possess a business necessity for such information. These individuals will exclusively manage your personal data in accordance with our explicit directives and are bound by a stringent obligation of confidentiality.

We have instituted formal procedures for addressing any suspected breaches of personal data security and will promptly apprise you and any relevant regulatory authority of such breaches, in adherence to all legal obligations.

9. Newsletter

If you subscribe to a newsletter offered on our website, the information provided during registration for the newsletter will be used solely for the purpose of mailing the newsletter unless you consent to its use for additional purposes. You may cancel the subscription at any time by using the option to unsubscribe contained in the newsletter.

10. Legal Rights

It is imperative that the personal information we maintain about you remains accurate and up to date. Kindly keep us informed of any changes to your personal data throughout our engagement. Under specific circumstances outlined in the NDPA, you possess certain rights concerning your personal information. These rights encompass the ability to access, rectify, or delete your personal data, object to or restrict its processing, and opt out of our email communications and newsletters.

In the event you desire to permanently remove your data from our website and other associated applications, you can opt to close your account. This can be done by clicking on the link provided and following the instructions provided. Please be aware that once your account is closed, all the products and services accessible through your account will no longer be available. We retain the right to decline your request if it is deemed unreasonable or if you have failed to furnish the necessary additional information required to verify your identity.

11. Data Controllers & Contact

If you have any questions or concerns about Octave’s Privacy Notice or you are looking for more information on how we process your personal data, or wish to exercise your legal rights in respect of your personal data, please contact the Data Privacy Officer by email at contact@octavepartners.com