Privacy Policy

This Privacy Policy explains how Investment Nerds ("we", "us", "our") collects, uses, stores, shares and protects personal information when you use our website, application, community spaces, learning features and related services (the "Platform").

Investment Nerds seeks to process personal information lawfully, fairly and transparently and in accordance with applicable data-protection requirements, including the Data Protection Act, 2012 (Act 843) of Ghana where applicable.

For personal information for which Investment Nerds determines the purposes and means of processing, Investment Nerds acts as the data controller.

This Policy should be read with our Terms of Service, Community Guidelines, Investment Education Disclaimer, Expert & Creator Policy and Security & Responsible Disclosure Policy.

This Policy applies to visitors, members, learners, community participants and other users of the Platform in Ghana and abroad.

It covers personal information processed through Investment Nerds-operated or controlled services. Third-party services have their own privacy practices.

Depending on the features you use, we may collect:

Account and profile information

• name;
• username;
• email address;
• phone number;
• country or general location;
• profile information you choose to provide;
• account authentication and security information; and
• account preferences.

Passwords should be stored using appropriate security protections rather than as readable credentials.

Community content

Posts, comments, questions, replies, reports, moderation-related information and other content you submit.

Learning information

Course progress, quiz responses, learning activity, certification information and other inputs associated with educational features.

Portfolio and financial information you choose to provide

Information you enter into portfolio-tracking, planning or educational tools, such as holdings, quantities, values, goals or other financial information.

Investment Nerds does not require you to provide brokerage passwords, banking PINs, mobile-money PINs, one-time authentication codes or similar financial-account credentials, and you should never provide them.

Contributor or session information

Information reasonably necessary to arrange or administer educational sessions or interactions with Contributors where such features are offered.

Payment and billing information

Where paid Platform services are introduced, third-party payment processors may process card, mobile-money or other payment information. Investment Nerds may receive transaction confirmations and limited billing records.

Investment Nerds does not treat payments for Platform services as investment funds and does not receive money for investment on a member's behalf.

Communications

Support requests, feedback, complaints, privacy requests, security reports and other communications sent to us.

Technical and usage information

Depending on the service and settings used:

• IP address;
• device and browser information;
• operating system and app version;
• login and security events;
• pages or features used;
• timestamps and interaction data; and
• cookies or similar technologies.

Information from service providers

Service providers supporting authentication, hosting, communications, analytics, security, payments or other Platform operations may provide information necessary to operate those services.

Portfolio and financial information can be particularly sensitive in context.

We seek to limit its use to legitimate purposes connected with providing, securing, improving and administering the features you use, complying with legal obligations, preventing fraud and protecting members.

We do not require access to your brokerage, bank or mobile-money credentials to provide Investment Nerds' educational and portfolio-tracking functions.

Do not post sensitive financial or identification information publicly in community spaces.

We may process personal information to:

• create and administer accounts;
• provide learning, community, portfolio and other Platform features;
• track educational progress and issue permitted certifications;
• personalise and improve the user experience;
• communicate service information;
• respond to support, complaints and rights requests;
• process payments for legitimate Platform services where introduced;
• moderate content and enforce our Terms and Community Guidelines;
• detect, investigate and prevent fraud, scams, impersonation and abuse;
• secure accounts, systems and infrastructure;
• investigate cybersecurity incidents;
• preserve evidence where reasonably necessary;
• comply with applicable legal or regulatory obligations;
• respond to lawful requests;
• establish, exercise or defend legal rights; and
• analyse and improve the Platform, including through aggregated or de-identified information where appropriate.

The lawful ground for processing depends on the context and applicable law and may include:

• processing necessary to perform our agreement with you or take requested steps;
• compliance with a legal obligation;
• legitimate interests in operating, securing, improving and protecting the Platform and community, where those interests are not overridden by applicable rights;
• consent where consent is required or appropriate; and
• other lawful grounds recognised by applicable law.

Where we rely on consent, you may withdraw it subject to applicable law. Withdrawal does not make earlier lawful processing unlawful.

We seek to collect personal information that is adequate, relevant and reasonably necessary for legitimate Platform purposes.

We do not intend to use personal information for materially incompatible purposes without an appropriate lawful basis and, where required, notice or consent.

Investment Nerds does not sell or rent members' personal information as a data product.

We do not provide personal information to investment-product sellers for the purpose of allowing them to target or solicit members through Investment Nerds.

This does not prevent disclosures that are reasonably necessary to operate the Platform, comply with law, protect users, complete a user-requested service, or carry out a lawful business transfer as described below.

We may share personal information in the following circumstances:

Service providers

With providers supporting hosting, infrastructure, authentication, communications, analytics, security, support, payments or similar Platform operations, subject to appropriate contractual and data-protection requirements where applicable.

Contributors you choose to interact with

Where a Platform feature requires information to arrange or administer an educational session, we may provide the Contributor with information reasonably necessary for that purpose.

Contributors may not use access obtained through Investment Nerds as a concealed means of soliciting investment business or reusing member information for unauthorised purposes.

Legal, regulatory, safety and security purposes

We may preserve, restrict or disclose information where required or permitted by applicable law, including to:

• respond to a lawful request;
• investigate suspected fraud or unlawful activity;
• investigate cybersecurity incidents;
• protect members or the public;
• protect the integrity or security of the Platform;
• enforce our Terms or Community Guidelines; or
• establish, exercise or defend legal rights.

Business transfers

If Investment Nerds undergoes a merger, acquisition, restructuring, financing, sale of assets or similar transaction, personal information may be transferred as permitted by applicable law and subject to appropriate protections.

With your direction or consent

We may share information where you direct us to do so or give valid consent.

Aggregated or de-identified information

We may use or share information that has been aggregated or de-identified so that it does not reasonably identify an individual, subject to applicable law.

Information you intentionally post in public or member-visible community areas may be visible to other users and, depending on the Platform's configuration, may be publicly accessible or indexed.

Do not post:

• bank or mobile-money account details;
• passwords, PINs or authentication codes;
• brokerage credentials;
• national identification details;
• financial-account numbers;
• private addresses;
• confidential employment information;
• another person's personal information without lawful authority; or
• other information you do not want exposed to the relevant audience.

Deleting a post from Investment Nerds does not necessarily remove copies independently saved, quoted or shared by others outside our control.

To protect the community, Investment Nerds may process content, account information, reports, moderation history, security information and related records to investigate suspected violations.

Reports may be treated as confidentially as reasonably practicable.

Where technically available, Investment Nerds may allow a report to be submitted without displaying the reporter's identity to the reported user or community. We do not guarantee absolute anonymity where identifying information is technically transmitted, necessary for an investigation, or disclosure is legally required.

We may preserve relevant information where reasonably necessary for fraud prevention, security, dispute resolution, legal compliance or enforcement, even where related content is otherwise removed from public view.

Investment Nerds seeks to apply appropriate technical and organisational safeguards designed to protect personal information against unauthorised access, alteration, disclosure, loss or misuse.

Measures may include access controls, encryption in transit, secure hosting, authentication protections, monitoring and other safeguards appropriate to the service.

No system can guarantee absolute security.

You are responsible for protecting your credentials and should promptly report suspected unauthorised account access or security incidents to support@investmentnerds.org.

Investment Nerds serves users in Ghana and abroad. Service providers may process or store information in other countries.

Where applicable law imposes requirements on international transfers of personal information, Investment Nerds will seek to implement the required safeguards, contractual measures, notices, consents or other compliance steps.

We retain personal information for as long as reasonably necessary for the purposes for which it was collected and for legitimate legal, security, fraud-prevention, accounting, dispute-resolution and enforcement purposes.

Retention periods may vary by category of information.

When information is no longer reasonably required, we seek to delete, anonymise or otherwise dispose of it appropriately, subject to legal and technical requirements.

Account deletion does not necessarily require immediate deletion of every record where retention is permitted or required for legal compliance, security, fraud prevention, backups, disputes or enforcement.

We seek to keep personal information reasonably accurate and up to date for the purposes for which it is used.

Users should keep account information current and may request correction of inaccurate information as provided by applicable law.

Depending on applicable law and subject to applicable conditions, exemptions and identity verification, you may have rights to:

• request access to personal information held about you;
• request correction of inaccurate or incomplete information;
• request deletion in circumstances recognised by law;
• object to or request restriction of certain processing;
• withdraw consent where processing relies on consent;
• object to direct marketing; and
• complain to the appropriate data-protection authority.

Requests may be sent to info@investmentnerds.org or support@investmentnerds.org.

Investment Nerds may request reasonable information to verify identity and protect personal information from unauthorised disclosure.

Where the Data Protection Act, 2012 (Act 843) applies, users may also have the right to complain to the Data Protection Commission of Ghana.

Where Investment Nerds sends marketing communications, it will do so in accordance with applicable law.

You may opt out of marketing communications using the provided unsubscribe mechanism or applicable account settings.

Opting out of marketing does not prevent necessary service, security, legal or transactional communications.

Investment Nerds may use cookies and similar technologies for authentication, security, preferences, functionality, analytics and other legitimate Platform purposes.

Where applicable law requires consent for a particular cookie or technology, Investment Nerds will seek that consent.

Additional details may be provided in a Cookie Policy or cookie-management interface.

Public educational material may be accessible to younger visitors.

Account creation and features involving stored personal financial information, community participation, consultations or paid services are intended for users aged at least 18, or the age of majority in the user's jurisdiction if higher.

Investment Nerds does not intend to knowingly collect account-level personal information from children who are not eligible to create an account. Where such information is identified, appropriate steps may be taken in accordance with applicable law.

Third-party websites, brokers, financial institutions, payment processors, sign-in providers and other services may have their own privacy practices.

A link, integration or reference by Investment Nerds does not make Investment Nerds responsible for a third party's independent processing.

Where applicable law requires registration, notification, consent, contractual safeguards, security measures, records or other data-protection compliance steps, Investment Nerds will implement the requirements applicable to its processing.

Nothing in this Policy limits privacy rights that applicable law does not permit to be waived or excluded.

Investment Nerds may update this Policy to reflect changes in the Platform, law, regulation, technology, security risks or data-processing practices.

Material changes will be communicated through appropriate channels where required. The revised Policy will state its effective or updated date.

For privacy questions or rights requests:

Investment Nerds — Privacy Team. Accra, Ghana. Email: info@investmentnerds.org or support@investmentnerds.org · Web: investmentnerds.org