Leadway Pensure PFA is strongly committed to protecting your privacy while interacting with our content, products and
services. We want to provide a safe and secure environment for you. The purpose of this Privacy Policy is to tell you what
kind of information we may gather about you when you visit our site, how we may use that information, whether we disclose
it to anyone, and the choices you have regarding our use of, and your ability to correct this information. Our policy allows
you to choose, subject, of course, to the requirements of the Pension Reform Act 2004, what kind and how much information you
provide to us and to control how we use whatever information you give us. Our goal is to provide you with a satisfying experience
while allowing you to control your privacy and to give you a means to voice any questions or concerns you may have.
This policy applies only to Pensure and not to other companies’ or organisations’ websites to which Pensure is linked.
Collection of Informtaion
Information is collected from you primarily to make it easier and more rewarding for you to use our services. Depending on
the service you are accessing, you could be asked to provide information such as your name, email address or information about
a few other things. It is entirely your choice whether to respond to these questions or not. Leadway Pensure PFA collects two
types of information. The first type is anonymous information. For instance, we may collect information to tell us that five
thousand people visit this Privacy Policy today, but we do not know their names, where they live or their date of birth – they
are ‘anonymous’ to us. Another example of Pensure collecting anonymous information is when Pensure audiences are invited to respond
to surveys on Pensure website. The surveys may ask you for demographic information such as your age, gender and postcode. This
information is collected for research purposes, is used in the aggregate (where possible), and remains anonymous. Many of the
individuals who access our services are anonymous to us. The second type of information that Pensure collects is personal
information. Pensure will collect personal information that lets us know the specifics of who you are such as your name, email
address, or postal address. With this information, Pensure can provide a variety of personalised and enhanced services that are
not available to anonymous users. We hope that you will find it beneficial to provide individually identifiable information about
yourself to us because it will make our services more valuable to you. Sometimes, we may specifically ask for personal information
about you when you sign up to use a service. Certain information may be required, such as your name, age, internet address in order
to provide that service or product to you. This information may also be used to inform you of additional products and services
which may interest you. You can choose not to receive such information when you are undertaking product or service registration on
our website. We may also ask about your interests, but it is your choice whether or not to respond. How much of your personal
information that you choose to disclose to Leadway Pensure PFA is completely up to you. The only way we know something about you
personally is if you provide it to us.
Use of anonymous information
Leadway Pensure PFA may automatically gather anonymous information to monitor the use of the site like the numbers and
frequency of visitors to the site. We only use such data in the aggregate. This collective data helps us determine how much
our audiences use parts of the site, so we can improve and make the site as appealing as we can make it for as many users as
possible. Pensure may publish or provide this aggregate data to other people.
Use of personal information
Leadway Pensure PFA will only use the personal information you have chosen to provide us for the purpose for
which you provided it. Leadway Pensure PFA will not use it for any other purpose without your consent.
Disclosure
There will be occasions when it might be necessary for Leadway Pensure PFA to disclose your personal information
to third parties such as its funds Custodians (PFCs) or the industry Regulator, National Pension Commission (PenCom).
Leadway Pensure PFA may be required by law to disclose the information, or Leadway Pensure PFA may be required to
disclose your personal information to third parties to provide the service you have requested. However, the disclosure
will only be made where it is necessary to fulfil the purpose for which you disclosed your personal information. Otherwise
than stated above, we do not disclose personal information that you may give us, such as your name, address, email address
or telephone number, to any organization or person outside Pensure unless you have authorised us to do so.
No sale of personal information
Under no circumstances will Pensure sell or receive payment for disclosing your personal information. Ultimately, you
are solely responsible for maintaining the secrecy of your passwords and/or any personal information. Be responsible whenever
you are online.
Access and correction: personal data
If Leadway Pensure PFA holds your personal information, we will, where possible provide you with access to the
information. Leadway Pensure PFA will take reasonable steps to correct the information so that it is accurate, complete
and up to date.
Security
Leadway Pensure PFA operates secure data networks that are designed to protect your privacy and security.
Changes to Leadway Pensure PFA privacy policy
If we decide to change the Leadway Pensure PFA Privacy Policy, we will post those changes here.