Igun Africa Privacy Policy

January 2023

Information about our organisation and websites

Our Privacy Statement covers Igun Incorporated and Igun Limited (together, “Igun”) and their websites including http://www.igunafrica.com/. It also covers any email communications that we may send to you or your company. Igun is based in Canada and Nigeria.

We are committed to protecting your privacy. This Privacy Statement describes the ways in which we collect information from you and what we use it for. Please read the policy to check how your information will be treated. It also describes your data protection rights, including a right to object to some of the processing which Igun carries out. More information about your rights, and how to exercise them, is set out in the Your Rights section.

This Privacy Statement may be updated periodically. We will update the date at the top of this Privacy Statement accordingly. On some occasions, we may also actively advise you of specificata handling activities or significant changes to this Privacy Statement, as required byapplicable law.

The terms of this statement should be read together with our Website Terms and Conditions, any additional terms and conditions, disclaimers or other contractual terms you have entered into with us and any applicable mandatory laws and regulations, as amended from time to time.

Personal Data we collect

Information collected directly:

If you are enquiring about, registering for, or using our services, consultancy, courses, websites or databases, then we will process your personal data - including your name, address, e-mail address and phone number, preferences (e.g. metals you are interested in) and service usernames and passwords.

If you attend one of our events or express interest in doing so you may provide us with your name, contact information, interests and marketing preferences.

You may give us information about you when you complete a form on our site or by corresponding with us by phone, e-mail or other electronic means, or in writing.

We use CCTV cameras in our premises, which may capture images including your personal data.

We also undertake video and audio recordings of activity at our offices, physical locations, virtual meetings, and record certain phone lines.

When we send or receive email from you we collect the address and content of the emails, the success or failure of our attempts to send you email, and information about when you receive, open or click on content in emails we send you and any subsequent visits you or other recipients make to our websites.

Information we collect about you from third parties:

Under the Igun Membership Agreement, Contract Agreement and any other on-boarding or service-delivery processes, our members and prospective members, and our clients, members' clients and prospective clients, may provide us with personal data of their clients, staff, Directors and shareholders – including name, address, e-mail address and phone number, job titles and responsibilities, other information set out in a CV, passports and national identification documents, emails, phone texts, mobile app messaging, financial information (bank statements and debit/credit card statements), incorporation documents, utility bills and share certificates.

In relation to our market data products, our licensees will provide us with information about end users (name, e-mail address and end user account number), in order for us to ensure that the terms of the licence are complied with and to track usage.

Our suppliers and warehouse companies also provide us with personal data about their staff (names and contact information) which we process as necessary to manage our relationship with he supplier and to ensure their suitability.

With regard to each of your visits to our site we may automatically collect the following information:

Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, b rowser plug-in types and versions, operating system and platform; and

information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); services or issues you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.

Information we receive from other sources:

We undertake commercial and legal due diligence checks on our members and prospective members, clients and prospective clients, which involves obtaining personal data on staff, Directors and shareholders from third parties which provide background checking services. The data we obtain may in limited cases include information about criminal offences or convictions of individuals. Further information about these checks is included in our membership information pack.

We may combine the information we have collected from with information from other sources, such as public records or bodies, or private organisations.

Public Health Alerts and Pandemic

You may be required to undergo certain limited screening before entering the Igun’s premises. This could include temperature scanning, health questions or other limited screening to minimise the transmission of certain notorious diseases. We will only ever process this data in accordance with applicable data privacy laws and will not share this data outside of the organisation.

Purpose and legal basis

We use personal data for the following purposes:

(1) Where this is necessary for purposes which are in our, or third parties, legitimate interests. These interests are:

- To undertake all necessary commercial due diligence on our members and prospective members;

- To develop our business by managing our relationships with actual or prospective: clients, members, members’ clients, warehouse operators, logistics firms, vendors, market data distributors, producers, dealers, purchasers of market data and other products and services we provide, and any other key stakeholders;

- To provide users with access to our websites and features on the websites;

- To market to certain individuals in a business to business context;

- To send individuals information they have requested;

- To ensure the security of our websites and our systems, by trying to prevent unauthorised or smalicious activities;

- To enforce compliance with Igun Membership Agreement, and other contracts and policies;

- To send service messages to our members;

- To ensure the safety and security of our staff and premises through the use of CCTV cameras;

- To ensure the suitability of individuals, companies or group who are permitted to trade and/or access any of our services; and

- To undertake internal analysis on, and improvements of, our business.

(2) For purposes which are required by law:

- To collect and hold certain personal data in order to comply with our legal responsibilities under the Law- To carry out anti-money laundering and other due diligence checks required for compliance with the law and our regulatory responsibilities;

- To monitor and report suspicious trading activity in accordance with our regulatory obligations; and

- In response to requests by government or law enforcement authorities conducting an investigation.

(3) To fulfil a contract, or take steps linked to a contract:

- To process an individual's registration on our websites; and

- To send individuals information about their use of our websites and changes to our terms or policies.

(4) Where you give us consent:

- Where you ask us to send marketing information to you via a medium where we need your consent (for example, email marketing to private email addresses);

- Where you give us consent to place cookies and to use similar technologies. and

- On other occasions where we ask you for consent, for the purpose which we explain at that time.

We have carried out balancing tests for all the data processing we carry out on the basis of our legitimate interests, which we have described above. You can obtain information on our balancing tests by contacting us using the details set out later in this notice.

Confidentiality / Security

We have implemented security policies, rules and technical measures to seek to protect the personal data that we have under our control from:

unauthorised access;

improper use or disclosure;

unauthorised modification; and

unlawful destruction or accidental loss.

All our employees and data processors who have access to and are associated with the processing of personal data are obliged to respect the confidentiality of your personal data.

Data Sharing

The personal data we process will be shared as follows:

with companies providing services to us which require the processing of personal data, such as training providers, insurance brokers, payment processors, identity verification and security providers, and IT hosting, IT platform and/or IT maintenance providers, marketing agencies, email management suppliers, and service providers which assist with our commercial and legal due diligence processes;

with our parent company, Igun Incorporated, who store personal data on our behalf on shared servers;

with government authorities and/or law enforcement officials if required for the purposes above, if mandated by law or if required for the protection of our legitimate interests in compliance with applicable laws;

to regulators as requested or required under applicable laws;

if your personal data has been provided to Igun; and

in the event that our business is sold or integrated with another business, your personal data may be disclosed to our advisers and any prospective purchaser's adviser and will be passed to the new owners of the business.

Except where you have explicitly given us permission, we will not pass your details onto any other organisations (except as noted above) or publish them publicly. Where you have requested us to pass on details to related organisations we will require them to comply with this privacy policy.

International Transfers

Your personal data will be processed in or accessed from jurisdictions outside Canada, Nigeria including a country that does not have equivalent data protection laws to those in Canada, United Kingdom and Nigeria. We will also transfer your personal data for the above-stated purposes to suppliers, producers, regulators, investors or stakeholders in other jurisdictions.

When we transfer your data, we make use of standard contractual data protection clauses, which have been approved by the Law. For further information, including to obtain a copy of the documents used to protect your information, please contact us as described in the Privacy Support section below. We continue to monitor for updates in this area and may change our transfer mechanisms as appropriate.

Your Rights

You have the right to ask us for a copy of your personal data; to correct, delete or restrict processing of your personal data; and to obtain the personal data you provide in a structured, machine readable format.

In addition, you can object to the processing of your personal data in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement). Where we have asked for your consent, you may withdraw consent at any time. If you ask to withdraw your consent to us processing your data, this will not affect any processing which has already taken place at that time.

You can object at any time to our use of your personal data for direct marketing purposes, by contacting us using the information below.

These rights may be limited, for example if fulfilling your request would reveal personal data about another person, or if you ask us to delete information which we are required by law or have compelling legitimate interests to keep. If you have unresolved concerns, you have the right to complain to a data protection authority in the country in which you live or work, or alternatively in the countries we are registered in.

Retention

We retain records related to actual or prospective: clients, members, members’ clients, warehouse operators, logistics firms, vendors, market data distributors, producers, dealers, purchasers of market data and other products and services we provide, and any other key stakeholders, for an indefinite period of time, where such records are pertinent for Igun to ensure the orderly functioning of its marketplace and general operations, and service delivery.

Personal data relating to investment decision makers of our clients, members' clients will be retained for as long as the relevant client is registered to use our services, or is bound by a Contract or Agreement with Igun.

Where we process personal data for marketing and client relationship management purposes or with your consent, and you remain an active user of our websites or services, we process the data until you ask us to stop and for a short period after this (to allow us to implement your requests). We also keep a record of the fact that you have asked us not to send you direct marketing or to process your data indefinitely so that we can respect your request in future. Where you cease to be an active user of our websites or services, we will retain your data used for marketing and client relationship management purposes.

Recordings of telephone calls

We may record:

(a) telephone calls, mobile app calls, virtual/online calls made or received by representatives of Igun; and

(b) the telephone number from which callers telephone Igun, together with the time, date and content of the call,

for the purpose of complying with our legal and regulatory obligations.

We may maintain records relating to (a) and (b) above, in each case in accordance with Igun’s policies from time to time and applicable law.

Privacy support

If you have any questions or concerns about our privacy policy, please contact:

Canada

By post: 263 Hanover st Oakville L6kOh3.

Phone: +1 (647) 677-6687

Email: business@igunafrica.com

Nigeria

By post: 53b Akintunde Adeyemi Drive, Lekki Phase 1, Lagos

Phone: +234 81-6268-8922

Email: business@igunafrica.com