Privacy Policy

Effective Date: 22 September 2026

Trinity Securities Limited (“Trinity Securities“, “we“, “us“, or “our“) respects your privacy and is committed to protecting the personal information entrusted to us.

This Privacy Policy explains how Trinity Securities Limited collects, uses, stores, protects, and otherwise processes personal data when you visit our website, use our online platforms, mobile applications, trading services, or otherwise interact with us.

By using our website, platforms, products, or services, you acknowledge that you have read and understood this Privacy Policy.

1. About Trinity Securities Limited

Trinity Securities Limited is a Nigerian securities and investment services company providing services through its physical and digital channels.

For the purposes of applicable data protection laws, Trinity Securities Limited may act as a Data Controller in respect of personal data that we determine the purpose and means of processing.

2. Personal Information We Collect

Depending on the services you use and your relationship with us, we may collect the following categories of personal information:

A. Identification Information

• Full name
• Date of birth
• Gender
• Nationality
• Passport or other identification details
• National Identification Number (NIN), where applicable
• Bank Verification Number (BVN), where applicable
• Signature
• Passport photograph or other identification photographs

B. Contact Information

• Residential or business address
• Email address
• Telephone/mobile number
• Emergency or next-of-kin information where required

C. Financial and Investment Information

• Bank account details
• Investment account information
• Securities holdings and transaction information
• Source of funds and source of wealth information where required
• Payment and settlement information
• Transaction history
• Tax-related information where applicable

D. Account and Platform Information

When you use our website, trading platform, mobile application or other digital services, we may collect:

• Customer/account identification numbers
• Login information
• Device information
• IP address
• Browser and operating-system information
• Authentication and security information
• Platform activity and transaction logs

E. Communications

We may retain information you provide when you contact us through:

• Email
• Telephone
• Contact forms
• Social media
• Customer-support channels
• Other communication platforms

3. How We Collect Personal Data

We may collect personal information directly from you when you:

• Open or maintain an account with us;
• Apply for our products or services;
• Register on our website or digital platforms;
• Execute securities transactions;
• Complete KYC or other regulatory requirements;
• Contact our customer-service or support teams;
• Subscribe to communications or updates;
• Participate in promotions, events or surveys; or
• Use our websites, applications and digital platforms.

We may also receive information from authorised third parties, including financial institutions, payment providers, regulators, exchanges, government agencies, identity-verification providers, technology providers, and other service providers where permitted by law.

4. How We Use Your Personal Data

We may process your personal information for purposes including:

1. Opening, maintaining and administering your account;
2. Providing securities, investment and related services;
3. Processing and executing transactions;
4. Performing customer identification and verification;
5. Meeting Know Your Customer (KYC) and Anti-Money Laundering (AML) requirements;
6. Preventing fraud, financial crime, unauthorised transactions and other security threats;
7. Processing payments, settlements and related financial transactions;
8. Communicating with you regarding your account and transactions;
9. Providing customer support;
10. Improving our products, platforms and services;
11. Maintaining the security and integrity of our systems;
12. Sending service-related communications;
13. Sending marketing communications where permitted by law and, where required, with your consent;
14. Meeting legal, regulatory, tax, audit and reporting obligations;
15. Responding to lawful requests from regulators, courts, law-enforcement agencies and other competent authorities; and
16. Establishing, exercising or defending legal claims.

5. Legal Basis for Processing

We process personal data only where there is a lawful basis for doing so under applicable data-protection laws.

Depending on the circumstances, our legal basis may include:

• Performance of a contract – where processing is necessary to provide services you have requested;
• Legal or regulatory obligation – where processing is required by applicable laws or regulatory requirements;
• Consent – where you have provided consent for a specific processing activity;
• Legitimate interests – where processing is necessary for legitimate business, security, fraud-prevention or service-improvement purposes and your rights do not override those interests; and
• Protection of vital interests or other lawful grounds recognised under applicable law.

Where we rely on consent, you may withdraw that consent at any time, subject to applicable legal or contractual restrictions.

6. KYC, AML and Regulatory Processing

As a securities company, Trinity Securities may be required to collect and process personal and financial information to comply with applicable laws, regulations, regulatory directives and requirements relating to:

• Customer identification;
• KYC;
• Anti-Money Laundering and Counter-Terrorist Financing;
• Fraud prevention;
• Securities transactions;
• Market and transaction reporting;
• Tax compliance;
• Investor protection; and
• Other regulatory obligations.

Where processing is required by law or regulation, withdrawal of consent may not prevent us from continuing to process the information where another lawful basis applies.

7. Sharing of Personal Data

We do not sell your personal information.

We may disclose or transfer personal information to trusted third parties where necessary for legitimate business, contractual, regulatory or legal purposes.

These parties may include:

• Regulators and government authorities;
• Nigerian Exchange and relevant market institutions;
• Banks and financial institutions;
• Payment and settlement service providers;
• Identity-verification and KYC providers;
• Technology and cloud-service providers;
• Cybersecurity and fraud-prevention providers;
• Professional advisers, auditors and consultants;
• Legal advisers;
• Service providers acting on our behalf; and
• Courts, law-enforcement agencies or other competent authorities where legally required.

Where third parties process personal information on our behalf, we take reasonable steps to ensure that appropriate confidentiality, security and data-protection obligations are maintained.

8. International Transfers

Some of our technology, cloud, communication, payment or service providers may process personal information outside Nigeria.

Where personal data is transferred outside Nigeria, Trinity Securities will take appropriate steps to ensure that the transfer is conducted in accordance with applicable data-protection requirements and that appropriate safeguards are implemented.

9. Data Security

We use reasonable technical and organisational measures designed to protect personal information against:

• Unauthorised access;
• Unauthorised disclosure;
• Loss;
• Destruction;
• Alteration;
• Fraud;
• Misuse; and
• Other unlawful or unauthorised processing.

Security measures may include access controls, authentication mechanisms, encryption where appropriate, monitoring, backups, employee controls and other administrative, technical and physical safeguards.

However, no electronic transmission or storage system can be guaranteed to be completely secure.

10. Data Retention

We retain personal information only for as long as reasonably necessary for the purposes for which it was collected, including to:

• Provide our services;
• Maintain business and transaction records;
• Meet legal and regulatory requirements;
• Resolve disputes;
• Prevent fraud and financial crime;
• Enforce agreements; and
• Comply with applicable record-retention obligations.

When personal information is no longer required, we will take reasonable steps to securely delete, anonymise or otherwise dispose of it in accordance with applicable requirements.

11. Your Data Protection Rights

Subject to applicable law and any lawful limitations, you may have the right to:

• Request access to personal information we hold about you;
• Request correction of inaccurate or incomplete information;
• Request deletion of personal information in appropriate circumstances;
• Request restriction of certain processing activities;
• Object to certain processing activities;
• Request portability of your personal data where applicable;
• Withdraw consent where processing is based on consent; and
• Lodge a complaint concerning our processing of your personal data.

Some requests may be subject to legal, regulatory, contractual or other legitimate restrictions.

12. Marketing Communications

Where permitted by applicable law, we may send you information about our products, services, investment opportunities, events or other relevant communications.

You may opt out of marketing communications by using the unsubscribe mechanism included in the communication or by contacting us.

Please note that opting out of marketing communications will not prevent us from sending essential service, transaction, security or regulatory communications.

13. Cookies and Similar Technologies

Our website and digital platforms may use cookies and similar technologies to:

• Enable essential website functionality;
• Remember preferences;
• Improve website performance;
• Understand how users interact with our platforms;
• Improve security; and
• Support analytics and relevant communications.

Where required, we will request your consent before placing non-essential cookies on your device.

You may also manage or disable cookies through your browser settings. Disabling certain cookies may affect the functionality of some parts of our website.

14. Third-Party Websites

Our website or digital platforms may contain links to websites or services operated by third parties.

This Privacy Policy does not apply to third-party websites or services. We encourage you to review the privacy policies of those third parties before providing them with personal information.

15. Children’s Privacy

Our services are not intentionally directed at children where such services are not legally available to minors.

We do not knowingly collect personal information from children except where permitted or required by applicable law and where appropriate safeguards are in place.

16. Accuracy of Personal Information

You are responsible for providing accurate and up-to-date information to us and for notifying us when your information changes.

You may contact us to request correction or updating of your personal information.

17. Data Breaches and Security Incidents

Where a personal-data breach occurs, Trinity Securities will assess and respond to the incident in accordance with applicable laws and regulatory requirements.

Where notification is legally required, we will notify the relevant regulatory authority and/or affected individuals within the applicable timeframe.

18. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our services, technology, legal requirements or regulatory obligations.

The updated version will be published on our website with the revised effective date.

We encourage you to periodically review this Privacy Policy.

19. Contact Us

20. Complaints to the Regulatory Authority

If you believe that your personal data has been processed unlawfully or that your privacy rights have not been adequately addressed, you may contact the Nigeria Data Protection Commission (NDPC) through its official channels.

Trinity Securities will endeavour to resolve privacy concerns promptly and transparently.

---

Trinity Securities Limited
Privacy Policy
Effective Date: 22 September 2026