Privacy Policy

AFEX COMMODITIES EXCHANGE LIMITED ("us", "we", or "our") operates the Workbench Platform (the "Platform").

{% translate "This page informs you of the policies regarding the collection, use and disclosure of Personal Information when you use the Platform." %}

{% translate "We will not use or share your information with anyone except as described in this Privacy Policy." %}

{% translate "We use your Personal Information for providing and improving the Platform. By using the Platform, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms and Conditions." %}

Information Collection and Use
{% translate "While using our Platform, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you. Personally identifiable information may include, but is not limited to, your email address, name, phone number, postal address ("Personal Information")." %}

Log Data

{% translate "When you access the Platform by or through a mobile device, we may collect certain information automatically, including, but not limited to, the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use and other statistics ("Log Data").

In addition, we may use third party Platforms such as Google Analytics that collect, monitor and analyze this type of information in order to increase our Platform's functionality. These third party Platform providers have their own privacy policies addressing how they use such information." %}

Location information
{% translate " We may use and store information about your location, if you give us permission to do so. We use this information to provide features of our Platform, to improve and customize our Platform. You can enable or disable location Platforms when you use our Platform at anytime, through your mobile device settings." %}

{% translate "Cookies are files with small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a web site and stored on your computer's hard drive." %}

{% translate "Cookies are small files saved on your browser by a web page server. Cookies contain information that can later be read by a web server in the domain that issued the cookie to you. Some of the cookies will only be used if you use certain features or select certain preferences, and some cookies will always be used." %}

We use cookies for the following purposes:
  • To enhance your user experience on our platforms.
  • To improve our platform and to better understand your visits on our platforms.
  • To serve you with interest-based or personalized recommendations.
  • {% translate "To observe your behaviours and browsing activities over time across multiple Platforms or other platforms." %}
  • To better understand the interests of our customers and visitors to our platforms.

{% translate "Some Cookies are necessary for certain uses of the platform, and without such Cookies, we may not be able to provide many services that you need to properly use the platform. These cookies, for example, allow us to operate our platform so you may access them as you have requested and let us recognize that you have created an account and have logged into that account to access content on our platform. They also include Cookies that enable us to remember your previous actions within the same browsing session and secure our platforms." %}

The Purpose for Which We Will Use Your Data
The information that we collect from you -{% translate " We may use information held about you in the following ways" %}:
  • {% translate "to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and Platforms that you request from us;" %}
  • {% translate "to provide you with information about other goods and Platforms we offer that are similar to those that you have already purchased or enquired about;" %}
  • {% translate "to provide you, or permit selected third parties to provide you, with information about goods or Platforms we feel may interest you. If you are an existing customer, we will only contact you by electronic means (e-mail, SMS or WhatsApp) with information about goods and Platforms similar to those which were the subject of a previous sale or negotiations of a sale to you. If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this. If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please tick the relevant box situated on the form on which we collect your data;" %}
  • {% translate "to ensure that content from our site is presented in the most effective manner for you and to notify you about changes to our Platform;" %}
  • {% translate "to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;" %}
  • {% translate "to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you; and to make suggestions and recommendations to you and other users of our site about goods or Platforms that may interest you or them, identify your preferences, and personalize your experience with the Platform." %}

Information we receive from other sources - {% translate "We will combine this information with information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive)." %}

Disclosure of Your Personal Information
You agree that we have the right to share your personal information:
  • with any of our affiliated companies and Platform providers;
  • {% translate "with financial Platform providers, including the financial institutions identified in your cardholder bank agreement that provide banking Platforms in connection with your account;" %}
  • {% translate "with non-financial companies, such as email Platform providers that perform marketing Platforms on our behalf, and fraud prevention Platform providers that use the information to provide Platforms to us;" %}
  • {% translate "with a non-affiliated third-party to access and transmit your personal and financial information from a relevant financial institution. You grant the third-party the right, power, and authority to access and transmit this information according to terms of their privacy policy;" %} 
  • {% translate "with selected third parties including business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you;" %}
  • {% translate "with third parties to whom we may choose to sell, transfer or merge parts of our business or our assets or alternatively, acquire all or parts of their businesses;" %}
  • {% translate "in response to a request for information, if we are required by, or we believe disclosure is in accordance with, any applicable law, regulation or legal process; and" %}
  • {% translate "with relevant law enforcement officials or other third parties, such as investigators or auditors, if we believe it is appropriate to investigate fraud." %}

Changes to Personal Information
{% translate "It is imperative that your data with us is current and accurate. You may request for the rectification of any personal data that we hold about you so as to enable you to correct any incomplete or inaccurate data we hold about you. Such requests may be sent to" %} {% translate "We may, however, need to verify the accuracy of the new data you provide to us." %}

Platform Providers
{% translate "We may employ third party companies and individuals to facilitate our Platform, to provide the Platform on our behalf, to perform Platform-related Platforms or to assist us in analyzing how our Platform is used." %}

{% translate "These third parties have access to your Personal Information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose." %}

{% translate " We may use your Personal Information to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send." %}

Compliance With Laws
{% translate "We will disclose your Personal Information where required to do so by law or subpoena or if we believe that such action is necessary to comply with the law and the reasonable requests of law enforcement or to protect the security or integrity of our Platform." %}

Business Transaction
If AFEX Commodities Exchange Limited {% translate "is involved in a merger, acquisition or asset sale, your Personal Information may be transferred. We will provide notice before your Personal Information is transferred and becomes subject to a different Privacy Policy." %}

Security and Retention
{% translate "The security of your Personal Information is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security." %}

{% translate "We will retain your data for as long as necessary for the said purpose of the processing, and after that, we will keep your data as long as the law requires." %}

{% translate "International Transfer Your information, including Personal Information, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction." %}

{% translate "If you are located outside Nigeria and choose to provide information to us, please note that we transfer the information, including Personal Information, to Nigeria and process it there." %}

{% translate "Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer." %}

Links To Other Sites
{% translate "Our Platform may contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit." %}

{% translate "We have no control over, and assume no responsibility for the content, privacy policies or practices of any third party sites or Platforms." %}

Children's Privacy
Our Platform does not address anyone under the age of 18 ("Children").

{% translate "We do not knowingly collect personally identifiable information from children under 18. If you are a parent or guardian and you are aware that your Children has provided us with Personal Information, please contact us. If we become aware that we have collected Personal Information from a children under age 18 without verification of parental consent, we take steps to remove that information from our servers." %}

Your Legal Rights
You have the right to:
  • {% translate " Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it." %}
  • {% translate "Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us." %}
  • {% translate "Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request." %}
  • {% translate "Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms." %}
  • {% translate "Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:" %}
    • If you want us to establish the data’s accuracy.
    • Where our use of the data is unlawful but you do not want us to erase it.
    • {% translate "Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims." %}
    • {% translate "You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it." %}
  • {% translate "Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you." %}
  • {% translate "Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or Platforms to you. We will advise you if this is the case at the time you withdraw your consent." %}

Changes to This Privacy Policy
{% translate "We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page." %}

{% translate "You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page." %}

Contact Us
If you have any questions about this Privacy Policy, please send us an email at {% translate "Or contact our Data Protection Officer, Peace Adeoye at" %}