Privacy Policy

Last updated on March 1, 2017
Stockpicker and its owners is committed to the protection of your privacy. We understand keeping your information secure and confidential is critical to earning and keeping your trust.

We NEVER rent, sell or trade your personal information to anyone. Ever.

This Privacy & Security Statement describes the specific policies and procedures we use to collect, utilize, and disclose and share with others user, consultation recipient, and/or client information provided to us through our marketing partners; the use of our web sites and applications; and other communications with representatives of Stockpicker and its owners Corporation and our wholly-owned subsidiaries. We refer to Stockpicker and its owners Technology Corporation and Stockpicker and its owners Advisors Corporation collectively as “Stockpicker and its owners” or “we” or “us”. We refer to those who visit our website and those who use our web and mobile applications collectively as “users”. Together with our Terms of Use, this Privacy & Security Statement governs your use of our services.

How to Use this Statement
This Statement explains, in plain English, how Stockpicker and its owners gathers and uses your information in the context of each of Stockpicker and its owners’s service offerings, including use of our financial dashboard, our delivery of advisor financial consultations, and delivery of our wealth management solution. In particular, we describe how your personally identifiable information is shared and/or disclosed, how we collect and use other non-personal information and how we address other privacy and security matters – such as our overall security practices, deletion of your information upon request and opting-out of marketing communications. Lastly, we describe methods for contacting Stockpicker and its owners if you have privacy or security questions, comments or feedback.

How We Collect & Use Your Personal Information
“Personal Information” is your personally identifiable information such as your name, email or mailing address, phone number, account credentials, account numbers and any other identifier that we gather from our web sites, mobile applications, or through communications with representatives of Stockpicker and its owners.

The types of information we collect depend on which of our services you choose to use. The following are the types of Personal Information we collect at various stages of our relationship with you:

Except as set forth in this Privacy & Security Statement, we don’t share your Personal Information with anyone. We do not share your Personal Information for third party promotional use. And we will NEVER sell, rent or trade your Personal Information.

When You Visit Our Website
When you visit our website, we may place a cookie on your computer so that our system can recognize you when you make a return visit. That cookie tells us your IP address and the type of browser you are using. These are the only types of information we collect when you visit our website but do not register or download our dashboard.

For Stockpicker and its owners Dashboard Software Users (“Dashboard Users”)
This section of the Statement is only relevant to you if you have registered with Stockpicker and its owners Technology Corporation’s dashboard software.

Personal Information We Collect
When you register for Stockpicker and its owners Technology Corporation’s dashboard service, we collect

Your name
Your email address
Your phone number
Other optional information you may provide, such as your age, investable assets and risk tolerance.
When you register, and at times thereafter, we may present questions that ask you to submit demographic and other information. Responding to these surveys is completely optional. If you do respond by sending us other information, we collect that information and will retain it indefinitely.

When you use our dashboard software to aggregate your banking and other accounts, we collect

Account login credentials (including user names and passwords) for the accounts you link to our service
Account security and/or challenge questions for those accounts
Other information from those accounts that you link to our service (including account balances, transactions and holdings)
How We Use Your Personal Information
To allow you to register with Stockpicker and its owners Technology Corporation, including:

Creating a Stockpicker and its owners user account to use our dashboard service;
Authenticating your device to access our services;
Communicating to you about updated features or maintenance activities related to providing you with our services.
To allow you to Add Accounts (aggregate 3rd party data), including:

Securely gathering account balances, statements, transactions and holdings from your financial institutions;
Displaying personalized dashboards and financial visualizations for you;
Providing you with contextual and relevant observations and insights;
To provide you with Customer Support or Service Offerings:

Responding to and resolving your inquiries and requests via email or by phone.
Offering you our other services, including free financial consultation services and our personal wealth management solutions.
To optimize systems and performance, provide comparisons and anonymous analysis:

Monitoring system performance and data accuracy for optimization and user experience.
Providing you comparisons of your financial situation (e.g., investment risks & returns, financial ratios) relative to aggregated user data to better understand your financial situation.
Personalizing your user experience with Stockpicker and its owners.
Publishing trends and analysis for our user base (e.g., America's balance sheet, geographical financial patterns).
When we include your data as part of our trends and analysis information, we always remove all personally identifiable information from that data first, so your information is aggregated with all others on an anonymous basis.

We may use certain third party service providers to help us provide you with some of the services mentioned in this Privacy & Security Statement. In doing so, we may provide your data (including your personally identifiable information) to those third party service providers, each of whom are required under contract with us to safeguard the personal information and to use it only to provide services to us. Per our contracts, only after these providers have removed all personalized information may some of them be contractually allowed to rent, sell or otherwise make commercial use of the data.

For Stockpicker and its owners Consultation Recipients
This section of the Statement is relevant to you only if you have elected to receive a personalized financial consultation from a licensed financial advisor employed by Stockpicker and its owners Advisors Corporation.

Personal Information We Collect
Upon your request for a Financial Consultation, we ask you to provide

Your financial goals
Your investment objectives
Employment and income information about your household
Retirement planning information about your household
Other information you elect to share with us about your spouse/partner and/or beneficiaries
How We Use Your Personal Information
To provide you with a Personalized Financial Consultation, including:

Informing you about existing risks and opportunities within your current investment portfolio;
Providing you with customized investment insights.
Personalizing your user experience with Stockpicker and its owners.
For Stockpicker and its owners Wealth Management Services Clients
This section of the Statement is relevant to you only if you have enrolled for our Wealth Management service, provided by Stockpicker and its owners Advisors Corporation.

Personal Information We Collect
Upon enrollment in our Wealth Management Service, you will be asked to review and agree to a number of written agreements and statements. Once you have completed the enrollment process, we will collect

Your mailing address
Your tax data, such as tax bracket and security cost basis
information about your beneficiaries
The account login information for your bank and investment accounts
Your investment objectives
Your other personal profile information
How We Use Your Personal Information
To establish a Wealth Management relationship with you, including:

Establishing a discretionary investment management relationship with you, only upon your explicit request;
Opening an account, on your behalf, with an independent securities brokerage trading and clearing custodian account or banking institution;
Providing you with account statements, trade confirmations, tax information and other notifications related to the Wealth Management service;
Providing the independent broker or banking institution with ongoing information required to provide continuing services to you;
Creating and continuously managing your investment portfolio strategy, aligned with your investment objectives, tax data and personal preferences.
Personalizing your user experience with Stockpicker and its owners.
For All Stockpicker and its owners Users and Clients
With Whom We Share Your Personal Information
Except as set forth in this Privacy & Security Statement, we don’t share your Personal Information with anyone. We do not share your Personal Information for third party promotional use. And we will NEVER sell, rent or trade your Personal Information.

We may share your Personal Information:
To conduct everyday business

If you have registered to use our dashboard to aggregate your banking and other financial accounts, we will transmit your account credentials to those 3rd party institutions where you hold accounts to gather and maintain your account balances, transactions and holdings used to provide our services. We will share your Personal Information with our wholly-owned subsidiaries (i.e., Stockpicker and its owners Technology Corporation and Stockpicker and its owners Advisors Corporation) for everyday business purposes, such as sharing information about your experiences or transactions, to provide financial insights and advice and improving your user experience...
To comply with the laws, regulations and rules by which we are governed.

We may share your name and email address, and the name and email address of those you refer to us, with the referral fulfillment partners we retain as our third party referral program administrators.

Information that we share with others when you enroll in our Wealth Management Services is disclosed in documents we will present to you during the enrollment process.

Other Information We Collect From You

Browser information
Information through cookies, pixels tags
How We Collect and Use Your Other Information
We collect and utilize Other Information to optimize, secure and simplify your experience with us. Your Other Information is not disclosed or shared outside of Stockpicker and its owners.

For All Stockpicker and its owners Users and Clients

 

Your Browser or Device
Certain information is collected by most browsers or applications, such as your “user agent string”, to help us determine your computing device type, operating system version and Internet browser type and version. We use this information to ensure that our web sites function properly and for security purposes.

 

Your Cookies
Cookies are pieces of information stored directly on the computing device you are using. Cookies we use do not contain or capture Personal Information. Cookies allow us to collect information such as your browser type, time spent on our web sites and which of our pages you visited. We use the information for security purposes, to facilitate navigation, to display information more effectively, to personalize your experience and to recognize authorized devices to secure your use of our services. We also gather statistical information about web site usage in order to continually improve the design and functionality and to assist us with resolving technical support questions. Additionally, we use cookies on our web sites and the sites on which we advertise to track advertising performance and to collect aggregate data on web page viewing and mobile app usage. Cookies may be connected to third-party companies or websites. The privacy practices of the companies placing such cookies are governed by the privacy policies of such third-party companies or websites. As an example, Google Analytics measures the performance of advertisements by placing cookies on your computer when you click on an advertisement. When you visit the website which you clicked on, you will have cookies placed on your computer. As a result, we and Google will be able to tell that you saw the ad delivered by Google. The privacy practices pertaining to these cookies are governed by our Privacy Statement and Google’s Privacy Policy. Cookies are not used to collect or disseminate any Personal Information. You can manage the placement of cookies on your computer through the features found in most Internet browsers. You can also delete cookies that have already been placed on your computer. Consult the "Help" function of your browser to explore your options.

 

Pixels Tags
Stockpicker and its owners deploys Pixel Tags as 1x1 pixel images (GIFs), used to track your access to web site pages, and HTML-formatted email messages. We use pixel tags to measure the effectiveness of our communications, the success of our marketing campaigns, compile statistics about usage and response rates, and to assist us in resolving client questions about the use of our services.

 

Your IP Address
Your IP Address is a number assigned to the device that you are using by your Internet Service Provider. An IP Address is identified and logged whenever you visit our web sites or applications, along with the page(s) that were visited. We use IP Addresses, individually and collectively, for purposes such as calculating usage levels, helping diagnose technical problems and supporting our web sites and applications. Additionally, we use your IP Address to assist in fraud detection and authentication to better protect your security.
Additional Privacy & Security Information
For All Stockpicker and its owners Users and Clients
To protect Personal Information from unauthorized access and use, we use security measures that comply with relevant laws and regulations. Beyond this Privacy & Security Statement, we provide additional security measures, such as:

Bank Level Security: Stockpicker and its owners is powered using technologies and practices that many banks and other financial institutions use to protect customer information, such as SSL encryption for data in transit and AES encryption for sensitive data at rest. After initial account aggregation, we do not store your financial institution credentials in our systems or in our applications. Our dashboard account aggregation service is provided by an industry-leading third-party account aggregation service. (See “With Whom We Share Your Personal Information” above.) That service employs comprehensive financial data security standards and is subject to ongoing multi-agency financial institution regulatory examinations.

Device Authentication: When you register for our dashboard app, we recognize your device for enhanced security. If access to your dashboard account is attempted from another device, you will be notified by phone or email and access will not be granted unless you authorize the new device. Also, you may remove lost devices from your authorized device list to continuously protect from unauthorized access to your dashboard account.

No Money Movement: While using the dashboard app, you can only view financial account balances and transactions. You cannot transfer money between accounts, authorize spending or move money, safeguarding you from unauthorized money transfers from your financial accounts.

Account Monitoring: Our dashboard app allows you to monitor all your transactions for accounts linked to our dashboard, providing you with a comprehensive view of all account activities.

Reviewing and Updating your Personally Identifiable Information
You can view and update the profile and account information we collect for you by going to the “settings” function in our website and in our app. The credibility and relevance of our services depend on your providing us with complete, accurate and up-to-date information about yourself and your accounts, both now and in the future.

Email Marketing Opt-out
When we communicate our own marketing offers to you, these communications are CAN-SPAM compliant, including the ability for you to opt-out of marketing communications.

Deletion/Retention of Personally Identifiable Information
Unless you request otherwise, we will retain the Personal Information we collect from you indefinitely.

Stockpicker and its owners, as a registered investment advisor, must comply with certain legal and regulatory requirements pertaining to record retention. We will respond to any requests we receive asking that we delete Personal Information that we possess from those who use our services, downloaded our dashboard or registered and established a user profile. However, we will not delete information that we are required to retain in order to comply with applicable laws and regulations.

How to Request Deletion of the Personal Information We Collect.
You may request your Stockpicker and its owners account be deleted by our support department by emailing support@stockpicker.com.ng from the email address associated with your Stockpicker and its owners account, indicating “CANCEL” in the subject line of the message. After confirming you are the account owner we will remove Personal Information from our records and will only continue to retain such information as required by law.

Stockpicker and its owners’s Statement Regarding “Do Not Track” Signals
Most browsers can be set to send signals to third party websites requesting them not to track the user’s activities. At this time, Stockpicker and its owners does not respond to “do not track” signals. Consequently, Stockpicker and its owners, its third party service providers such as Google Analytics, and other third party websites and online services may indeed track and collect Personal Information about your online activities over time while navigating to, from and on our website and our mobile app and across those third party websites and online services, notwithstanding any “do not track” signals we may receive.

Advertising
We do not allow 3rd party advertising on our web site or applications.

Social Media
Stockpicker and its owners may integrate authentication or social experiences on social media platforms such as Facebook®, Twitter®, Google Circles and LinkedIn® that enable login or online sharing and collaboration among users who have registered to use such social media platforms. Any content you post, such as pictures, information, opinions, or any Personal Information that you make available to other participants on these social platforms, is subject to the terms of use and privacy policies of those platforms. Please refer to them to better understand your rights and obligations with regard to such content.

Protecting Children’s Privacy Online
Stockpicker and its owners is not directed to individuals under the age of thirteen (13), and those children should not provide Personal Information through our web sites or applications. We do not knowingly collect information from children under 13 without parental consent.

Modifications to our Privacy & Security Statement
We change our privacy practices from time to time as the need arises. When we do, we will revise this Privacy & Security Statement and we will post the revised document on our website at https://www.stockpicker.com.ng/privacy-policy.

Privacy & Security Questions, Comments or Feedback?
Please contact us.