this website. We are keenly aware of the trust our users place in us, and our responsibility to protect their
privacy. We believe transparency and choice are the foundations of privacy. We strive to let users know what
information we collect when they use our services and describe how we treat personal information provided.
You accepted this policy when you signed up for our services.
Information we collect and how we use it
Our primary purpose in collecting personal information is to provide you with a safe, smooth, efficient, and
customised experience. When you sign up for an account, we ask you for personal information such as your
name, email address, an account password, credit card or other payment account information which we
maintain in encrypted form on secure servers.
We may use your personal information to:
• Provide the services and customer support you request;
• Process transactions, collect fees and send notices about your transactions;
• Resolve disputes and troubleshoot problems;
• Prevent potentially prohibited or illegal activities, and enforce our terms of service;
• Customise, measure, and improve our services and the content and layout of our website; and
• Compare information for accuracy and verify it with third parties.
When you visit our website, we send one or more cookies – a small file containing a string of characters – to
experience on the website by storing user preferences and tracking user trends, such as how people search.
We send a “session cookie” to your computer when you log in to your account. This type of cookie helps us to
recognize you if you visit multiple pages on our site during the same session, so that we don’t need to ask you
for your password on each page. Once you log out or close your browser, this cookie expires and no longer
When you access our website, our servers automatically record information that your browser sends
whenever you visit a website. These server logs may include information such as your web request, Internet
Protocol address, browser type, browser language, the date and time of your request and one or more
cookies that may uniquely identify your browser. Also, to protect you from fraud and other misconduct, we
may collect information about your interaction with our services. Any such information we collect will only be
used to detect and prevent fraud or other misconduct.
When you send email or other communications to us, we may retain those
communications to process your inquiries, respond to your requests and improve our services.
We only share personal information with third parties in the following limited circumstances:
• We provide such information to IC Asset Managers (Ghana) Limited for investment management and
investment advisory services and IC Securities (Ghana) Limited for brokerage services or other
trusted businesses or persons for processing personal information on our behalf. We require that
these parties agree to process such information based on our instructions and in compliance with
• We have a good faith belief that access, use, preservation or disclosure of such information is
reasonably necessary to:
o Satisfy any applicable law, regulation, legal process or enforceable governmental request,
o Enforce applicable Terms of Service, including investigation of potential violations thereof,
o Detect, prevent, or otherwise address fraud, security or technical issues, or
o Protect against imminent harm to the rights, property or safety of our website, its users or
the public as required or permitted by law.
• We may share with third parties certain pieces of aggregated, non-personal information, such as the
number of users who searched for a particular product. Such information does not identify you
We take appropriate security measures to protect against unauthorised access to or unauthorised alteration,
disclosure or destruction of data. These include internal reviews of our data collection, storage and
processing practices and security measures, as well as physical security measures to guard against
unauthorised access to systems where we store personal data. The security of your account also depends on
keeping your account password confidential. We restrict access to personal information by our employees
and the investment management, advisory and brokerage companies who need to know that information to
operate, develop or improve our services. These individuals are bound by confidentiality obligations.
We process personal information only for the purposes for which it was collected and in accordance with this
processing practices to ensure that we only collect, store and process the personal information needed to
provide or improve our services. We take reasonable steps to ensure that the personal information we
process is accurate, complete, and current, but we depend on our users to update or correct their personal
information whenever necessary.
We provide services through IC Asset Managers (Ghana) Limited and IC Securities (Ghana) Limited which are
registered with the Data Protection Commission (“The Commission”) with registration numbers
DC17060000801I and DC161100006281 respectively. The Commission is an independent statutory body
established under the Data Protection Act, 2012 (Act 843) to protect the privacy and personal data of the customer by regulating the processing of personal information. The Commission provides for the process to obtain, hold, use or disclose personal information and for other issues related to
the protection of personal data.
Accessing and updating personal information
When you use our website, we provide you access to your personal information either to correct this data if
it is inaccurate or to delete such data at your request if it is not otherwise required to be retained by law or
for legitimate business purposes. We ask individual users to identify themselves and the information
requested to be accessed, corrected or removed before processing such requests, and we may decline to
process requests that are unreasonably repetitive or systematic, require disproportionate technical effort,
jeopardise the privacy of others, or would be extremely impractical, or for which access is not otherwise
website or by emailing firstname.lastname@example.org.
website or by emailing email@example.com.
We are committed to ensuring that your privacy is protected. We aim to be as open and transparent as
possible around the information we collect when you visit our website. To make full use of the features and
services we offer on this website, your computer, tablet or mobile phone will need to accept cookies, as we
can only provide you with certain features of this website by using them. This policy explains what cookies
are and how we use them. It also explains the different types of cookies we use, and how you can change or
delete them. We hope that this policy helps you understand, and feel more confident about our use of
What are cookies?
Cookies are small text files that are stored by your browser onto your computer or other internet enabled
devices, such as a smartphone or tablet when you visit a website. They are widely used to make websites
work in a better and more efficient way. They can do this because websites can read and write these files,
enabling them to recognize you and remember important information that you will make use of, thus making
a website more convenient (e.g. by remembering your user preferences) and provide you with a more secure
online experience. Cookies generally do not hold any information to identify an individual person, but are instead used to identify a browser on an individual machine. Cookies can be referred to as session cookies or persistent cookies, depending on how long they are used:
• Session cookies only last for your online session and disappear from your computer or device when
you close your browser.
• Persistent cookies stay on your computer or device after the browser has been closed and last for
the period specified in the cookie. These persistent cookies may be checked each time you visit the
site where the cookie was generated or, in the case of third-party cookies, from another site that
also uses the same service.
Types of cookies
Cookies also have, broadly speaking, four different functions and can be categorised as follows: ‘necessary’
cookies, ‘performance’ cookies, ‘functionality’ cookies and ‘targeting’ or ‘advertising’ cookies.
Necessary cookies – These cookies are essential to enable a user navigate around a website and use its
features. Without them, you would not be able to use basic services like registration or getting investment
management, advisory or brokerage services. Necessary cookies allow you to sign in to the website as a
registered user. These cookies do not gather information about you that could be used for marketing or
remembering where you’ve been on the internet.
Performance cookies – These cookies help us understand how visitors interact with our websites by providing
information about the sections visited, the time spent on the website, and any issues encountered, such as
error messages. Performance cookies collect anonymous data for statistical purposes on how visitors use a
website. They don’t contain personal information, and are used to improve your user experience of a
Functionality cookies – Functionality cookies allow a website to remember the choices you make (such as
your user name, language or the region you are in) and to provide enhanced and more personal features.
They also remember changes you have made, such as customising a certain webpage, and for other services
you request such as watching a video or commenting on a blog. Functionality cookies will not
Targeting cookies – These cookies are used to deliver content that is more relevant to you and your interests.
They may be used to deliver targeted advertising or to limit the number of times you see an advertisement.
They also help us measure the effectiveness of advertising campaigns on our website. We may use these
cookies to remember websites you have visited and we may share this information with other parties,
including advertisers and our agencies.
Third Party cookies
In some cases, we may use third parties to manage our cookies but we do not allow any third party to use
these cookies other than for the purposes listed in this policy. Third party advertisers and other organisations
may also use their own cookies or other technologies to collect information about the content of our website
and/or the advertisements you have clicked on. This information may be used by them to serve
advertisements which they believe are most likely to be of interest to you based on content you have viewed.
Third party advertisers may also use this information to measure the effectiveness of their advertisements.
We do not have access or control over the cookies placed on our website by third parties and use of their cookies is subject to their own privacy policies. We recommend that you review the privacy policies of each of our third parties.
Most internet browsers are initially set up to automatically accept cookies. You can change the settings to
block cookies or to alert you when cookies are being sent to your device. Please note, if you choose to block
all cookies, our site will not function as intended and you will not be able to use or access many of the
services we provide. Generally, you have the option to see what cookies you’ve got and delete them
individually, block third-party cookies or cookies from particular sites. Visit the ‘options’ or ‘preferences’
menu on your browser to change settings.
By continuing to use our site, you agree to the placement of cookies on your device. If you choose not to
receive our cookies, we cannot guarantee that your experience will be as fulfilling as it would otherwise be.