Custodian Investment Plc (the Group) is an investment company with significant holdings in:

• Custodian and Allied Insurance Limited
• Custodian Life Assurance Limited
• Custodian Trustees Limited
• Crusader Sterling Pensions Limited
• Adapt

Data Collection We collect data through:

• Forms related to our products/services.
• Customer surveys and feedback.
• Website usage via cookies.
• Mobile apps, USSD, chatbots, and contact center services.
• Third-party integrations such as NIBSS APIs and NIID APIs.

Data Usage

• Processing service requests efficiently.
• Sending marketing and informational messages.
• Personalizing digital experiences.
• Sharing data with partners for bundled services (e.g., fitness, travel, car tracking).
• Fraud detection and prevention.

Data Storage & Security

• Data is stored securely in on-premise and cloud databases protected by firewalls and intrusion detection.
• Retention: 15 years for inactive accounts before deletion.

Marketing Preferences Users can opt out of marketing communications by contacting dataprotection@custodianplc.com.ng.

User Rights Users have the right to:

• Access, correct, or delete their data.
• Restrict or object to data processing.
• Request data portability.

For requests, email dataprotection@custodianplc.com.ng or call (+234)12774000-9.