General Overview of Our Privacy Notice 

---

Background and Scope 

UMB Stockbrokers Ltd. (UMB SL) recognises the importance of privacy and security of personal information that is shared with us whilst executing our business and providing services to our clients. While new technologies have dramatically changed how information is gathered, used, and stored, preserving customer trust and the privacy of personal information at UMB SL remains a core objective. 

This privacy policy provides information about how we process, share, and protect your personal information in line with our obligations and your rights under the Data Protection Act, 2012 (Act 843), as well as any amendments thereto and the General Data Protection Regulation.

Definitions

---

In this privacy policy, the following terms have the following meaning:

“Data Controller” is a person who, either alone, jointly with other persons, or in common with other persons, or as a statutory duty, determines the purposes for and the way Personal Data is processed or is to be processed.

“Processor” is any person other than an employee of the data controller who processes the data on behalf of the Data Controller.

“Data Subject” is an individual who is the subject of Personal Data.

“Personal Data” is data about an individual who can be identified (a) from the data or (b) from the data or other information in possession of or likely to come into the possession of the Data Controller.

“Processing” is an operation, activity, or set of operations, by automatic or other means, concerning data or Personal Data.

Who we are

---

UMB SL is an investment management and advisory firm licensed by the Securities and Exchange Commission (SEC) and registered with the National Pensions Regulatory Authority (NPRA) as a pension fund manager.

Unless otherwise stated, UMB SL is the Data Controller for the information we process and, at some point, a data processor. 

Our Location and Contact Address
No. 1 Abdul Diouf Street 
South Ridge, Accra - Ghana
GPS Address: GA-052-5000

If you do have any complaints, requests, or questions regarding your personal information and about how it is being processed, please contact the Data Protection Supervisor via: 

Email: info@umbcapital.com  
Telephone: +233 (0)30 225 1137 / +233 (0)30 225 1138 
Postal Address: P O Box CT 1317, Accra, Ghana
Website: https://umbstockbrokers.com

How we obtain your Personal Data

---

UMB SL collects personal information directly from you when you engage with us through various channels. When we collect your personal information indirectly from you, we will inform you about how we obtained the information. The following are some of the various ways we collect information from you:

• When you enroll on to any of our investment products. 
• When you subscribe to our services across all channels, including digital platforms.
• When you make an enquiry, complaint, or give feedback.
• When you are captured by our closed-circuit television (CCTV) surveillance technology when you visit our office.
• When you apply for a job with UMB SL.
• When you visit our website.
• Through any other interaction you have with us.

You are not obliged to provide us with your personal information. However, certain basic information may be required from you to enable us to provide you with our services or attend to your requests. Where this is the case, we will advise you when obtaining the information. 

The type of information we collect

---

We collect personal information that is necessary, relevant, and reasonable for the purpose of processing.  The type of personal information that we may collect and process about you when you interact with us includes the following:

• Your name
• Telephone number(s)
• Email address
• Residential and/or business address
• Identity card
• Bank details
• Survey or course evaluation and responses
• Cookies
• IP address

Purpose of processing

---

The purpose for which we process your Personal Data may include any of the following and we certify that the data obtained will be used for its intended purpose only:

• To enable us to manage your investment portfolio.
• To provide information you have requested or that may be relevant to a service or product you have shown interest in.
• Interact with you to process financial transactions for purchasing and commissioning products and/or services.
• To fulfill a contract, we have executed with you or the entity you represent. In these circumstances, your entity, rather than yourself, may have provided us with your Personal Data to fulfill the contract.
• To safeguard the security of our website and underlying business infrastructure. 
• To manage our communication with you.

Legal Basis and Consent

---

UMB SL would only process your Personal Data for the specific purpose that we state at the point of Personal Data collection in accordance with the law. Your Personal Data may be used in any of the following circumstances:

• To enable us to prepare a contract that we are about to enter or have entered with you.
• Where we have legitimate legal interests, provided it does not conflict with your interests and fundamental rights.
• Where we need to comply with a legal obligation or statutory requirement.
• Where you consent.

We have set out (in the below table) a description of the ways we may use your Personal Data and the legal bases and have identified what our legitimate interests are, where appropriate:

Type of Processing Activity	Lawful Basis
Make available our services to you	Legitimate interest
To contact you, following your enquiry, reply to any questions, suggestions, issues, or complaints you have contacted us about	Legitimate interest
Marketing /mailing list /subscriptions	Consent
Fulfillment of a contract or to provide you with an agreed service	Performance of a contract
To contact you, following your enquiry, reply to any questions, suggestions, issues,or complaints you have contacted us about	Legitimate interest

 

Retention (How long we keep your data)

---

• UMB SL will only retain your Personal Data for as long as is reasonably necessary to fulfill the purposes we collected it for, including to satisfy any legal, regulatory, tax, accounting, or reporting requirements.
• We may retain your Personal Data for an extended period in the event of a complaint or if we reasonably believe there is a prospect of litigation.
• Specific details of the retention periods of your Personal Data are available in our retention policy which you can request from us.

Whom we might share your information with

---

Generally, UMB SL will not share your information with third parties. However, UMB SL may share your Personal Data in any of the following circumstances:

• When required by any governmental authorities (including law enforcement) and/or regulators in accordance with applicable laws. 
• By UMB SL’s internal team members during the execution of their roles.
• To administer a contract or service we are providing to you.
• Financial institutions through which your transactions are processed.
• Other companies and financial institutions that we work with to provide services to you.
• Third parties with accruing legal obligations, including trustees and executors, guarantors, anyone holding a power of attorney to operate an account on your behalf, and joint account holders.

Security safeguards and cookies

---

• Security safeguards are important to UMB SL. Therefore, we have appropriate technical and organizational security measures in place to protect your Personal Data. Whenever you visit our website, we will use “cookies” to enhance your interaction with our products and services. This is a step towards safeguarding data.
• UMB SL will not be liable for your electronic and/or non-electronic privacy settings. We do not have any control over what happens between your device and the boundary of our information infrastructure. However, we have established procedures to deal with any suspected Personal Data breach. We will notify you and any applicable regulator of a breach where we are legally required to do so.

Your rights as a data subject under the law

---

Act 843 provides some basic rights to Data Subjects.  These include the:

• Right to be informed.
• Right of access to Personal Data. 
• Right to give and withdraw consent.
• Right to amend (rectification, blocking, erasure, and destruction).
• Right to prevent processing.
• Freedom from automated decision-making.
• Freedom from processing for direct marketing.
• Right to compensation.
• Right to complain.
• Other rights under different jurisdictions across Africa and beyond. 

Right to be informed 

You have the right to be informed about processing your personal information (Personal Data).  This privacy notice ensures we meet our obligations to enable you to exercise your right to be informed. 

Right to access your personal information 

You have the right to access the personal information that we hold about you. This is sometimes termed a ‘Data Subject access request.’ UMB SL will ask for proof of identity and sufficient information about your interactions with us to locate your personal information when you make such a request. If you would like to exercise this right, please contact us as set out below. 

Right to rectification, blocking, erasure, and destruction

Where information we hold about you is inaccurate, incomplete, or outdated, you may ask us to correct or update it at any time.  You also have the right to block us from further processing your Personal Data where we do not have any legitimate or legal basis for processing it. 

You may also ask us to delete your Personal Data in certain circumstances.  The right to erasure or destruction is not absolute and only applies in certain circumstances. If you would like to exercise this right, please contact us as set out below. 

Right to prevent processing  

Under this right, you can give us written notice to not start or cease 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.  

Right to give and withdraw consent 

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 provided in our communication with you.  

Right to complain and compensation 

The Data Protection Commission (DPC) regulates data protection and privacy matters in Ghana. They make a lot of information accessible to citizens or consumers on their website, and they ensure that the registered details of all Data Controllers, such as us, are publicly available. 

You may contact DPC to lodge a complaint if you are not satisfied with how your complaint(s) or concerns are being addressed, if you believe any of your rights have not been met, or if we fail to meet our obligations as a Data Controller through the following address:

Email: info@dataprotection.org.gh 
Telephone: +233 (0) 30 222 2929 
Website: www.dataprotection.org.gh

Other rights under different jurisdictions

---

UMB SL will ensure that the various rights of Data Subjects are respected and taken seriously wherever we operate. Where we process Personal Data from other jurisdictions, we undertake a privacy assessment to identify any potential risk of non-compliance.

Notice to Exercise Rights

---

You can, at any time, give written notice to us to exercise your rights.  Within twenty one (21) days after receipt of a notice, we will 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. 

Governing law and jurisdiction 

---

Act 843 governs this privacy notice. Any legal issues or actions arising in connection with this privacy notice will be submitted to the courts of Ghana.

Changes to this Privacy Notice

---

We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes or we change our business in a way that affects Personal Data protection. Any changes we make will be published and indicated by a version number. We, therefore, encourage you to review our privacy policy regularly for updates.

Our Comments

---

Your Personal Data is important to us, and we are committed to protecting and safeguarding it. We aim to ensure the integrity and be responsible and accountable for your data. We adhere to the general principles of data protection and international best practices in relation to data protection and are not only guided by Act 843.
 Rest assured that we shall employ all the necessary technical and organizational measures to secure and treat your personal information in accordance with this privacy notice and maintain and ensure the accuracy of your Personal Data.