Privacy policy
This Privacy Policy explains how SolomonHills Investment Limited (“we”, “us”, “our”)
collects, uses, discloses, and protects personal information (Personal Data) when you
use our website or interact with us, regardless of means of access. Kindly review the
Privacy Policy to stay informed about our practices whenever you interact with us.
Last updated: December 13, 2023
Introduction
SolomonHills is an investment platform that simplifies investing and makes it easy and
affordable for Nigerians to access investments and achieve their financial goals.
SolomonHills respects your privacy and is committed to protecting your Personal Data.
Our goal with this Privacy Policy is to provide a clear and concise explanation of the
Personal Data we collect as you access our Services, and how we use and share it.
By accessing and using SolomonHills services, you agree to the practices described in
this Privacy Policy. You may access or use our Services through a laptop, desktop,
mobile phone, tablet, or another electronic device (collectively, a “Device”).
This Privacy policy applies to the use of our websites and other online services and/or
any related services, sales, marketing, events, and social media activities (collectively,
our “Services) by our consumer users (“User”). This Privacy Policy also applies to offline
interactions with SolomonHills.
Information we collect
We collect the Personal Data you share with us when you create an account with
SolomonHills or communicate with us about your SolomonHills account. The Personal
Data we collect may include your name, address, mobile phone number, email address,
date of birth, banking details, next of kin details, image, and other information that
identifies you.
As a User, we’d also ask you to create login information for your SolomonHills accounts
such as username and password. In general, we collect the Personal Data you share
with us by filling in forms or interacting with us via our website, phone call, email, social
media posts, or otherwise.
- Information about your transactions with us
We collect Personal Data as you use your SolomonHills account to perform financial
transactions. The Personal Data we collect during financial transactions include the
Naira amount, transaction time, and transaction details.
- Personal Data from Third Party Sources
When you create an account on SolomonHills, we may collect additional information
about you from non-affiliated third-party sources to further verify you and prevent fraud.
We may also collect your Personal Data from a User where your details are filled in a
Next-of-Kin form.
- Information we collect automatically from our services
When you access or use our services, we automatically collect Personal Data and other
information such as your statistical information (“Analytics”) that are correlated with your
Personal Data. Analytics that are directly or indirectly correlated with Personal Data will
be considered as Personal Data for the purpose of this Privacy Policy.
The Personal Data we collect automatically as you access or use our services include:
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Device Information: We may collect information about the Device you use to
access our services, such as hardware model, operating system version, unique
device identifiers, and mobile network information. These pieces of information
may be associated with your SolomonHills account.
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Log Information: We may record or log information from your devices about your
use of our Services including your Device’s Internet Protocol (IP) address, the
type of browser you use, access times, pages viewed, date and time stamps of
transactions, and other interactions with our Services such as the page you
visited before navigating to our Services.
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Location Information: We may collect your location information from your Device
as you access our Services
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Information Collected through Cookies and Other Technologies: We use various
technologies to personalize our Services for you, and this may include sending
cookies to your Device. Additional information about cookies and how they work
is available here. You can find more information about how we use cookies and
your related choices in our Cookies policy. We may also collect information using
tracking pixels to understand usage, campaign effectiveness, and the open rate
of the emails we send.
Do-Not-Track Signals
We (indicate whether “allow” or “do not use technologies that recognize”) Do-Not-Track
browser configurations which may alter the tracking technologies we use.
How we use personal data
SolomonHills is based in Nigeria and so, we consider the lawful basis for using your
Personal Data as set out in the Nigeria Data Protection Regulation (NDPR) and will only
use your data if we have a proper reason for doing so. According to this, we may use
your Personal Data as follows:
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To verify your identity and prevent fraud.
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For our general commercial purposes, including offering products and services that we think might interest you.
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To improve our Services and give you a better experience.
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Monitor and analyze activities in connection with our Services.
We may also use your email address to respond to your inquiries and provide
information about our Services. You may choose to opt out from receiving our offers and
promotional emails by contacting us or by following the “unsubscribe” instructions from
any communication you receive from us. As a User, if you unsubscribe from receiving
promotional emails from us, we may still send you non-promotional emails such as
emails about your SolomonHills account and our ongoing business relations.
How long we store personal data
All Personal Data shared with us is stored on our secure cloud storage solution and the
storage of Personal Data is dependent on the purpose of processing:
- For requests, questions and consultations, we will store your Personal Data for
as long as it takes us to answer your request, question, and/or consultation.
- For sign-ups and use of our Services, we will store your Personal Data for the
purpose for which it was collected.
- For commercial or promotional communications, we will store your Personal Data
until your objection.
How we share personal data
Privacy is our priority. Our main focus is to help you achieve financial security and
freedom, not to sell your data. We do not sell or rent Personal Data to marketers. We
may, however, share your Personal Data with affiliated and non-affiliated third parties as
follows:
- With another user, when you sign up on SolomonHills using a voucher, the user
that sent you the voucher may receive information indicating that you have used
the voucher received.
- With non-financial companies, such as email service providers through which we
perform marketing services.
- With another user, when you sign up on SolomonHills using a referral link.
The user that referred you may receive information indicating that you have
signed up for our Services.
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With a non-affiliated third-party financial service provider to access and transmit
your personal and financial information from a relevant financial institution.
With non-affiliated companies for our everyday business purposes, we may share your Personal Data:
- To process transactions and maintain accounts.
- In response to court orders and legal investigations.
- In response to a request for Personal Data, if we are required by any applicable
law or regulation.
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With relevant law enforcement officials or other third parties, such as
investigators or auditors, if we believe it is appropriate to investigate fraud.
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With your consent or at your direction, including if we notify you that the Personal
Data you provide will be shared in a particular manner and you provide such
Personal Data.
We will not share your Personal Data with other third parties without your consent.
Your Rights
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Account information
We recommend that you provide accurate information about your Personal Data
and as such, you have the right to edit it by logging into your account via our
Services. Any changes will affect only future uses of your Personal Data and we
may need to verify the accuracy of the new data you provide to us. If you wish to
delete or deactivate your SolomonHills account, please contact us. We may,
however, retain certain Personal Data as required by law or for legitimate
purposes.
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Promotional Communications
You may opt-out of receiving our offers and promotional emails by following the
“unsubscribe” instruction in any communication you receive from us. Please note
that as a User, if you unsubscribe from receiving promotional emails from us, we
may still send you non-promotional emails such as emails about your
SolomonHills account and our ongoing business relations.
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Cookies
Most web browsers are set to accept cookies by default. You have the right to set
your browser to reject browser cookies. Please note that rejecting cookies may
affect the functionality of our Services.
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Social sharing features
Our Services include social sharing features for common social networks to
enable users to share content with friends or the public. These features are
served by third-party services that may serve their cookies and we have no
control over these. For more information about the purpose and scope of data
collection and processing in connection with social sharing features, please visit
the privacy policies of the entities that provide these features.
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Other rights
According to the Nigeria Data Protection Regulation (NDPR), you have a right to
consent to this Privacy Policy and to withdraw your consent at any time. You also
have a right to freely transfer your data received from us to any other person. For
more information about your rights over your Personal Data, you may visit your
NITDA’s website. If you wish to exercise your rights, please write to us at
hello@solomonhills.com
Links to Third-Party Websites
We may allow third-party websites to link to our Services. We are not responsible for the
privacy policy of any third parties or content of linked websites, but we do encourage
you to read the applicable privacy policies and terms of use of such parties and
websites. This Privacy Policy only applies to our Services
Changes to our Privacy Policy
Subject to applicable law, we may revise this Privacy Policy at any time and at our sole
discretion. When we revise this Privacy Policy, we will update the date at the top of this
Privacy Policy. The revised Privacy Policy will be effective upon posting via our Services
unless otherwise required by applicable law. You are free to decide whether or not to
accept a revised version of this Privacy Policy, but accepting it is required for you to
continue accessing or using our Services.
Cookies
Last updated: June 1, 2022.
How we use cookies
We use various technologies to personalize our Services for you, and this may include
sending cookies to your Device. We use cookies for record-keeping purposes to
improve your experience with our Services. For example, when you log in to your
SolomonHills account, cookies will help to recognize and keep you logged in as you
browse the website. These are technical cookies that are strictly necessary for the
smooth running of our Services.
We also use the following types of cookies:
- Analytical and performance cookies
These cookies are small data files stored on your Device memory to allow us to
see how you use our Services and the popular features of our Services you visit
the most. It allows us to recognize and count your visits to our website and see
how you browse around our website. This is required to help us improve our
Services to suit your needs.
- Targeting cookies
These cookies allow us to see the pages and links you visited before accessing
our Services. This helps us understand where the bulk of our traffic comes from
and enables us to provide more relevant ads.
- Google Analytics cookies
These cookies identify and analyze website trends but do not identify you
individually. They are simply “session cookies” and end as soon as you close
your website browser
How to change your preferences
Except for technical cookies which are strictly necessary for the smooth running of our
Services, you may choose to accept or reject cookies.
You can set your browser to reject browser cookies. However, if you reject all our
cookies (including the technical cookies), you may not be able to access all of our
Services. You can learn more on how to opt out of Google Analytics site activity tracking
by clicking
here .
Security
SolomonHills takes adequate measures to protect your Personal Data from loss, theft,
misuse, and unauthorized access. Additionally, SolomonHills implements policies that
protect the confidentiality and security of your nonpublic Personal Data, including this
Privacy Policy. Access to your Personal Data is limited only to employees with a
business reason to know, and security procedures are set in place to protect the
confidentiality and security of such Personal Data and prohibit unlawful disclosure.
We have taken measures to provide security facilities for the protection of your Personal
Data through the setup of firewalls, limited access to specified authorized individuals,
and encryption. We have also enabled a default two-factor authentication (2FA) on
all SolomonHills accounts to protect you from unauthorized access.
When your bank account information is transmitted via our Services, it will be protected
by encryption technology, such as Secure Sockets Layer (SSL) and all sensitive
Personal Data is encrypted with Advanced Encryption Standard (AES) 256 bit
encryption. We, therefore, have digital and physical security measures to eliminate the
possibility of data privacy breach incidents. We have put in place procedures to deal
with any suspected Personal Data breach and will notify you and any applicable
regulator of a breach where we are legally required to do so.
For passwords chosen to access certain parts of our Services, you are responsible for
keeping this password confidential. Please safeguard your username and password for
your SolomonHills account login information. You agree to notify us immediately of any
unauthorized use of your SolomonHills account or any other breach of security.
Location Data Collection Disclosure for Solomonhills Mobile App
To ensure a secure and tailored experience for our users, our app may collect and use your device's location data both in the foreground and in the background. Please review the following disclosure to understand how we handle your location information.
Why do we collect your location data?
Solomonhills utilizes location data not only to enhance your app experience but also to strengthen fraud prevention and monitoring mechanisms. The purposes include:
- Enhanced Security: Strengthening fraud prevention by monitoring location anomalies and flagging suspicious activities.
- Personalized Content: Recommending financial services, investment opportunities, and promotions based on your current location.
- Geographical Context: Improving the accuracy of identifying your location for added security layers, especially during financial transactions.
- The quality of any products, services, information, or other material purchased or obtained by you through the services will meet your expectations; OR
How do we collect location data?
We employ various technologies, such as GPS, Wi-Fi, Bluetooth, and cellular network information, to collect location data. This information is anonymized and used in aggregate to respect your privacy.
When is your location data collected?
Location data is collected when the app is in use and has your explicit permission to access your device's location services. This permission can be managed through your device settings.
How is your location data used?
Your location data is used for providing a secure, personalized app experience and for fraud prevention. Solomonhills does not share your precise location information with third parties without your consent.
Fraud Prevention and Monitoring:
We actively employ location data as part of our fraud prevention measures. Monitoring location patterns and identifying unusual activities helps us protect your financial information and transactions.
Your Control and Options:
- Permission Control: Manage app permissions through your device settings to control when Solomonhills can access your location data.
- Opt-out: If you wish to stop sharing your location data, you can disable location services for the app. Please note that this may impact the functionality of certain features.
Your Privacy Matters:
We prioritize the security and privacy of your data. Solomonhills adheres to strict security measures to protect your location data. Refer to our Privacy Policy for comprehensive information on how we handle and safeguard your personal information.
By continuing to use the Solomonhills app, you consent to the collection and use of your location data for the stated purposes, including fraud prevention. If you have any questions or concerns, please contact our Privacy Team at privacy@solomonhills.com.
Thank you for choosing Solomonhills and entrusting us with your location data for a secure and personalized digital savings experience.
SolomonHills is the leading online platform in Nigeria that enables people to save and invest. Our customers have been saving and investing with their principal and interest guaranteed.
SolomonHills Investment Limited - RC 1816520