Louer Capital Privacy Policy

The policy applies to: 

• Visitors to our Site who browse our content without engaging our services. 
• Prospective clients submitting information via our contact forms. 
• Clients who provide personal or corporate information as part of contractual engagements. 
• Third parties who interact with Louer Capital in the course of legitimate business dealings. 

1. Definitions 

For the purposes of this Privacy Policy: 

1.1. "Personal Data" refers to any information that identifies, relates to, describes, or is reasonably capable of being associated with a particular individual or legal entity. This may include your name, contact details, identification documents, financial records, or online identifiers.

1.2. "Processing" means any operation or set of operations performed on Personal Data, whether by automated means or otherwise, such as collection, storage, use, disclosure, transmission, or deletion.

1.3. "Cookies"means small text files placed on your device when you visit our Site, which help us recognise you, improve site performance, and deliver a personalised user experience.

1.4. "Third Parties"means persons or entities other than you or Louer Capital, including affiliates, service providers, regulatory bodies, and law enforcement agencies.

1.5. "Applicable Law"means all data protection laws, regulations, directives, and legally binding guidelines relevant to our operations, including NDPR, and other national/international privacy frameworks.These definitions are to be interpreted broadly to ensure maximum protection for individuals’ rights and compliance with all applicable jurisdictions in which Louer Capital operates. 

2. Information We Collect  

Louer Capital collects only the information necessary for legitimate business purposes, legal compliance, and operational efficiency. The categories of Personal Data we collect include:

2.1. Personal Identification Information: Full name, residential address, postal address, date of birth, gender, nationality, identification numbers (passport, national ID, driver’s license), and signature.

2.2. Contact Information: Email address, phone number(s), fax number, and preferred communication channels.

2.3. Financial Information: Bank account details, payment card information, transaction history, and other financial records necessary for billing, payments, or financial due diligence.

2.4. Corporate Information:Company name, registration number, tax identification number, registered address, ownership structure, and corporate governance records.

2.5. Technical Data:Internet Protocol (IP) address, browser type and version, device identifiers, operating system, time zone settings, and geolocation data.

2.6. Usage Data:Pages visited, actions taken on the Site, duration of visits, clickstream patterns, and user interaction data.

2.7. Sensitive Data:Where permitted and required, we may collect sensitive information such as criminal background checks or political exposure status for regulatory compliance purposes (e.g., anti-money laundering).

We do not collect more data than necessary and will not retain your Personal Data beyond the purposes for which it was collected, unless required by law.

3. How We Collect Information  

We obtain Personal Data from various sources:

3.1. Directly from You: Through forms completed on our Site, email communications, business cards, in-person meetings, or phone calls.

3.2. Automatically: Via cookies, server logs, and tracking technologies that collect usage and technical data.

3.3. From Third Parties: Including but not limited to public registries, credit reference agencies, compliance screening providers, regulatory bodies, and industry databases.

3.4. Through Contractual Engagements:Where you engage Louer Capital for services and provide data as part of onboarding, due diligence, or service delivery.

In all cases, we ensure that data is collected lawfully, fairly, and transparently, with clear notification to you at the point of collection where required by law. 

4. How We Use Your Information  

We process your Personal Data for purposes including, but not limited to:

4.1. Service Delivery: Providing the advisory, consulting, or investment banking services you have requested.

4.2. Due Diligence & Compliance: Conducting AML/KYC checks, verifying identities, and ensuring compliance with applicable regulatory requirements.

4.3. Communications: Sending you service updates, transaction notifications, and responses to inquiries.

4.4. Billing & Payments: Processing invoices, handling payment transactions, and maintaining financial records.

4.5. Marketing & Business Development: Sending relevant industry updates, invitations to events, and information about Louer Capital’s offerings, where legally permitted.

4.6. Legal Obligations: Processing invoices, handling payment transactions, and maintaining financial records.

4.7. Site Improvements:Analysing usage data to enhance the functionality, content, and user experience of our Site.

We will not use your Personal Data for purposes incompatible with those for which it was originally collected unless we notify you and obtain any necessary consent.

5. Legal Basis for Processing 

Louer Capital processes Personal Data only where there is a clear, lawful, and justifiable basis for doing so under Applicable Law, including the Nigerian Data Protection Regulation (NDPR), and other relevant international privacy frameworks.

The legal bases on which we rely include:

5.1.1. Where you have explicitly agreed to our processing of your Personal Data for specific purposes.

5.1.2. Consent is obtained in a clear and unambiguous manner, and you have the right to withdraw it at any time, without affecting the lawfulness of processing carried out prior to withdrawal.

Where the processing is necessary to fulfil our obligations under a contract with you or to take steps at your request before entering into such a contract.

Where processing is required for Louer Capital to comply with applicable laws, court orders, regulatory requirements, or statutory obligations (e.g., AML/KYC, tax reporting).

5.4.1. Where the processing is necessary for our legitimate business interests, provided these interests are not overridden by your fundamental rights and freedoms.

5.4.2 Examples include improving service delivery, preventing fraud, and safeguarding network security.

Where processing is necessary to protect your life or the life of another person, which is rare but may occur in specific emergency circumstances.

We will always ensure that at least one of the above legal bases applies to every instance of Personal Data processing.

6. Sharing and Disclosure of Information 

We treat your Personal Data with the highest degree of confidentiality. However, we may share it with third parties in the following limited and controlled circumstances:

6.1. With Affiliates and Subsidiaries: Louer Capital may share data within its corporate group where necessary for operational, compliance, or administrative purposes.

6.2. With Service Providers: We may engage trusted third-party vendors to perform services on our behalf, such as IT hosting, payment processing, compliance screening, data analytics, and marketing support. These service providers are bound by strict contractual obligations to protect your data and process it only as instructed.

6.3. With Regulatory and Law Enforcement:Authorities Where required by Applicable Law, we may disclose Personal Data to governmental bodies, regulators, or law enforcement agencies, including but not limited to anti-money laundering authorities, financial regulators, and courts of law.

6.4. In Connection with Business Transactions:If Louer Capital undergoes a merger, acquisition, restructuring, or sale of assets, Personal Data may be transferred as part of that transaction, subject to safeguards and applicable legal requirements.

6.5. With Professional Advisors:We may share Personal Data with lawyers, auditors, bankers, and insurers where necessary for legitimate business purposes.

6.6. With Your Consent:In all other cases, we will only share your data with third parties when you have provided explicit consent.

We never sell, rent, or trade your Personal Data to third parties for marketing purposes.

7. International Data Transfers 

Given the nature of our operations, your Personal Data may be transferred to, stored in, or processed in jurisdictions outside your country of residence, including but not limited to North America, the European Union, and other regions where Louer Capital operates or engages third-party service providers.

Whenever we transfer Personal Data internationally, we ensure that:

7.1. The destination country provides an adequate level of data protection, as recognised by relevant authorities; or

7.2. We implement robust contractual protections, such as standard contractual clauses approved by regulators, or

7.3.We rely on other legally recognised transfer mechanisms under Applicable Law.

We take reasonable steps to ensure that any overseas recipient of your Personal Data implements appropriate safeguards to protect your privacy and comply with this Privacy Policy.

8. Data Retention 

We retain your Personal Data only for as long as necessary to fulfil the purposes for which it was collected, including to satisfy any legal, regulatory, accounting, or reporting requirements.

Retention periods may vary depending on:

8.1. The nature of the data.

8.2. The purpose for which it is processed.

8.3.Applicable statutory limitations.

When Personal Data is no longer required:

8.4.It will be securely deleted, anonymised, or destroyed in accordance with recognised industry practices.

8.5.Where deletion is not immediately possible (e.g., backup systems), we will isolate the data and prevent further processing until it can be safely erased.

9. Data Security 

We employ a layered security approach to protect your Personal Data from unauthorised access, alteration, disclosure, or destruction. These measures include:

9.1. Technical Safeguards: Encryption, firewalls, intrusion detection systems, multi-factor authentication, and regular vulnerability testing.

9.2. Administrative Safeguards: Access controls, staff training, background checks, and strict internal data handling policies.

9.3. Physical Safeguards:Secured offices, locked storage, and controlled facility access. Despite these measures, no transmission over the internet or electronic storage system is completely secure. You acknowledge that we cannot guarantee absolute security, and you provide your data at your own risk.

10. Your Rights

Subject to Applicable Law, you have the following rights regarding your Personal Data:

10.1. Right to Access: You may request a copy of the Personal Data we hold about you.

10.2. Right to Rectification: You may request correction of inaccurate or incomplete data.

10.3. Right to Erasure:You may request that we delete your data when it is no longer necessary, except where retention is required by law.

10.4. Right to Restrict Processing:You may request that we limit how we use your data in certain circumstances.

10.5. Right to Data PortabilityYou may request that your data be provided in a structured, commonly used format and transferred to another controller.

10.6. Right to Object: You may object to our processing of your data based on legitimate interests or for direct marketing purposes.

10.7. Right to Withdraw Consent: Where processing is based on consent, you may withdraw it at any time without affecting prior lawful processing.

To exercise these rights, contact us using the ‘Contact Us’ form provided.

11. Cookies and Tracking Technologies

We use cookies and similar technologies to:

11.1. Enhance your browsing experience.

11.2. Analyse traffic and usage patterns.

11.3. Deliver personalised content and advertisements (where permitted by law).

You can manage or disable cookies through your browser settings; however, some site features may not function properly without them. 

12. Third-Party Links

Our Site may contain links to websites operated by third parties. We are not responsible for the privacy practices, content, or security of such websites. We encourage you to review the privacy policies of any third-party sites you visit. 

13. Children’s Privacy

Our Site and services are not directed at individuals under the age of 18. We do not knowingly collect Personal Data from minors. If we discover that a minor has provided us with data, we will delete it immediately.

14. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or operational needs. Updates will be posted on this page, and where appropriate, notified to you via email or site banner.

The “Last Updated” date at the bottom of this Policy indicates when changes were last made.