Legal and Privacy
Our policies on data privacy, cookies, and the terms that govern your use of our website and services.
Privacy Policy
Blue Marina Asset Management Limited and Blue Marina Securities Limited (together referred to as “Blue Marina”, “we”, “us”, or “our”) are committed to protecting your personal information and your right to privacy.
This policy applies to all information collected through www.bluemarina.com.ng, our related platforms and portals, and any services, communications, or events connected to our businesses. If you have questions or concerns about how we handle your personal data, contact us at info@bluemarina.com.ng.
If you do not agree with any part of this policy, please discontinue use of our website and services.
Information We Collect
We collect information that you provide directly to us. This includes information submitted when you:
- Complete an account opening or onboarding form
- Request information about our products or services
- Communicate with us through our website, email, or telephone
- Participate in surveys or feedback requests
- Subscribe to our newsletter or market updates
The information we collect may include your full name, contact details, government-issued identification, Bank Verification Number (BVN), financial information, and any other details provided in the course of engaging with our services.
We may also collect certain information automatically when you visit our website, including your IP address, browser type, device information, and pages visited. This information is collected through cookies and similar technologies. Please refer to our Cookie Policy for further details.
How We Use Your Information
To onboard and serve you as a client. Where you have submitted an application or account opening form, we process your data to enable us to onboard you and deliver the services you have requested.
This processing is carried out on a contractual basis. By submitting an application, you authorise Blue Marina to process your data for the purpose of onboarding you as a client.
To communicate with you. We use your contact details to send information relevant to your account, products, or services, including updates to our terms, conditions, and policies. By engaging with our services, you authorise Blue Marina to communicate with you through electronic channels including email, telephone, SMS, and web-based platforms. Instructions sent through electronic means shall be deemed authentic and binding.
To send you market updates and insights. Where you have opted in, we may use your contact details to send market reports, investment briefs, and updates from Blue Marina. You may opt out at any time by contacting us or using the unsubscribe option in any communication we send.
To comply with legal and regulatory obligations. As regulated entities, we are required to collect, retain, and in certain circumstances disclose client information in compliance with applicable laws and the directives of our regulators, including the Securities and Exchange Commission (SEC) Nigeria, the Nigerian Exchange Limited (NGX), and the Nigeria Data Protection Commission (NDPC).
To monitor platform activity. Your use of our website and digital platforms may be monitored for internal business purposes and in accordance with the rules of applicable regulatory and self-regulatory organisations. By using our platforms, you expressly consent to such monitoring, tracking, and recording.
To improve our services. We may use aggregated, anonymised data to analyse how our website and services are used, identify areas for improvement, and evaluate the effectiveness of our communications.
For other business purposes. With your consent, we may use your information for purposes such as data analysis, identifying usage trends, and evaluating the performance of our products and services.
Data Retention
We retain your personal information for as long as is necessary to fulfil the purposes for which it was collected and to comply with our legal and regulatory obligations. The following retention periods apply:
- Client onboarding and KYC records: Retained for a minimum of 5 years from the end of the client relationship. Basis: SEC Nigeria regulations, Nigeria Data Protection Act (NDPA) 2023.
- Transaction and investment records: Retained for a minimum of 5 years from the date of each transaction. Basis: SEC Nigeria Investment and Securities Act, regulatory best practice.
- Trading and brokerage records: Retained for a minimum of 5 years from the date of each trade or instruction. Basis: NGX Rules, SEC Nigeria regulations.
- Account correspondence and electronic instructions: Retained for a minimum of 5 years from the date of the communication. Basis: Regulatory best practice, contractual obligation.
- Complaint and dispute records: Retained for a minimum of 5 years from the date of resolution. Basis: SEC Nigeria consumer protection guidelines.
- Website enquiry and contact form submissions: Retained for 12 months from the date of submission, unless the enquiry results in a client relationship, in which case the client onboarding retention period applies. Basis: Legitimate interest.
- Newsletter and marketing preferences: Retained until you opt out or for a maximum of 2 years of inactivity, whichever comes first. Basis: Consent.
Where your information is no longer required, we will securely delete or anonymise it in accordance with our internal data disposal procedures.
Your Rights
You have the following rights in relation to your personal data under the Nigeria Data Protection Act (NDPA) 2023 and the Nigeria Data Protection Regulation (NDPR):
- Right of access. You may request a copy of the personal information we hold about you.
- Right of rectification. You may ask us to correct any information that is inaccurate or incomplete.
- Right to erasure. In certain circumstances, you may request that we delete the personal data we hold about you, subject to our legal and regulatory retention obligations.
- Right to restriction of processing. Where certain conditions apply, you may request that we limit how we use your data.
- Right to data portability. You may request that we transfer your data to another organisation in a structured, commonly used format.
- Right to object. You may object to certain types of processing, including direct marketing communications.
- Right to withdraw consent. Where processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of processing carried out before the withdrawal.
- Right to lodge a complaint. You have the right to lodge a complaint with the Nigeria Data Protection Commission (NDPC) if you believe your data rights have been violated.
To exercise any of these rights, contact our Data Protection Officer:
Email: info@bluemarina.com.ng
Address: 10, Keffi Street, SW Ikoyi, Lagos, Nigeria
Business Hours: Monday to Friday, 8:00am – 5:00pm
Security
We implement appropriate technical and organisational measures to protect your personal information against unauthorised access, loss, destruction, or alteration. However, no method of transmission over the internet or electronic storage is entirely secure. While we take reasonable steps to protect your data, we cannot guarantee absolute security and shall not be liable for any loss or damage resulting from unauthorised access by third parties.
Changes to This Policy
We may update this Privacy Policy from time to time. Where we make material changes, we will notify you by posting a prominent notice on our website or by contacting you directly. The date at the top of this tab reflects when the policy was last updated. We encourage you to review this page periodically.
Cookie Policy
What Are Cookies
Cookies are small text files placed on your device when you visit a website. They allow the website to recognise your device, remember your preferences, and collect information about how you navigate and use the site. We use cookies and similar technologies, including web beacons and pixels, on www.bluemarina.com.ng.
Types of Cookies We Use
Essential cookies. These are necessary for the website to function correctly. They enable core features such as page navigation, secure access to client portals, and form submissions. The website cannot function properly without these cookies and they cannot be switched off. No consent is required for essential cookies as they are strictly necessary for the delivery of our services.
Analytics cookies. These help us understand how visitors interact with our website, which pages are visited most, where visitors come from, and how they move through the site. Information collected is aggregated and anonymised and is used solely to improve website performance and user experience. Examples include Google Analytics or similar tools.
Functional cookies. These allow the website to remember choices you have made, such as your login preferences or settings, and provide a more consistent experience across your visits. Disabling these cookies may affect certain features of the website.
Marketing cookies. Where you have given consent, these cookies track your browsing activity to help us deliver relevant communications and measure the effectiveness of our campaigns. They may also be set by third-party advertising or analytics partners in accordance with their own policies.
Cookie Retention Periods
- Essential cookies: Session-based. Deleted when you close your browser, or retained for up to 12 months where necessary for security and authentication purposes.
- Analytics cookies: Retained for up to 26 months from the date of your last visit, in line with standard analytics provider settings.
- Functional cookies: Retained for up to 12 months from the date they are set.
- Marketing cookies: Retained for up to 12 months from the date of consent, or until you withdraw consent, whichever comes first.
Managing Your Cookie Preferences
When you first visit www.bluemarina.com.ng, you will be presented with a cookie notice giving you the option to accept all cookies or manage your preferences by category. You can update your preferences at any time by clicking “Manage Cookie Preferences” in the footer of any page on our website.
You may also control or delete cookies through your browser settings. Guidance for the most commonly used browsers is available at www.allaboutcookies.org. Please note that disabling certain cookies may affect the functionality of our website.
Third-Party Cookies
Some cookies on our website are set by third-party services, such as analytics providers or embedded content platforms. These cookies are subject to the respective third parties’ own privacy and cookie policies. We do not control how these third parties collect or use data through their cookies and we are not responsible for their practices.
Changes to This Policy
We may update this Cookie Policy from time to time in line with changes to our use of cookies or applicable regulations. We will notify you of any material changes by updating the date at the top of this tab.
Terms Of Use
By accessing www.bluemarina.com.ng, our trading portal, or any of our digital platforms, you agree to be bound by these Terms of Use. Please read them carefully before using our website or services.
These Terms of Use apply to both Blue Marina Asset Management Limited (RC 7865545) and Blue Marina Securities Limited (RC 746044), together referred to as “Blue Marina”, “we”, “us”, or “our”. References to “you” and “your” refer to the person accessing this website and using our services. References to “Party” or “Parties” refer to both you and Blue Marina, or either of us individually.
Any person who accesses or relies on this website or the information contained herein does so at their own risk. If you do not agree with any part of these terms, please discontinue use of our website and services immediately.
These Terms of Use take effect when you first access this website and remain in effect for all subsequent visits. You are responsible for familiarising yourself with the current version of these terms on each visit, as they may be updated periodically.
General Disclaimer
Your use of any services provided by Blue Marina is subject to these Terms of Use, applicable product-specific documentation, and the rules and regulations of the Securities and Exchange Commission (SEC) Nigeria and the Nigerian Exchange Limited (NGX) where applicable.
The information on this website is provided for general informational purposes only. It does not constitute investment, legal, accounting, or tax advice, nor does it represent that any investment or financial service is suitable or appropriate for your individual circumstances. Content on this website should not be construed as a recommendation, offer, or solicitation to buy, sell, or participate in any particular investment or trading strategy.
Investment Risk
All investments in financial instruments involve risk. Investment values may fluctuate and past performance is not indicative of future results. There can be no assurance that investment objectives will be achieved. The value of securities and investments may go down as well as up, and investors may not recover the amount originally invested.
The information on this website does not take into account the specific investment objectives, financial situation, tax circumstances, or individual needs of any particular investor. It should not be relied upon as a personal recommendation. You are encouraged to seek independent financial advice before making any investment decision. Certain transactions carry significant risk and may not be suitable for all investors.
Accuracy of Information
While Blue Marina takes reasonable steps to ensure the accuracy of information on this website, we make no representation or warranty, express or implied as to its accuracy, completeness, timeliness, or fitness for any particular purpose. The website and all services are provided on an “as is” basis at your sole risk.
Blue Marina is not responsible for maintaining the currency of information on this website and has no obligation to supply updates, corrections, or releases unless required by law or regulation. Blue Marina reserves the right to add, modify, or remove any information on this website at any time without prior notice to you.
Know Your Customer and Source of Funds
You warrant that all information provided to us is true, accurate, and current. All subscription, investment, and trading payments must be made from a bank account held in your name. We do not accept third-party payments under any circumstances.
You confirm that all funds used for investments or trading are from lawful sources and are not derived, directly or indirectly, from any criminal, fraudulent, or unlawful activity. Blue Marina reserves the right to refuse, suspend, or terminate any transaction or account where it has reasonable grounds to suspect a breach of this clause.
Client Obligations and Communication
You agree to promptly notify us, within 7 calendar days, of any changes to the information you have provided, including your contact details, bank account information, and identification documents.
You authorise Blue Marina to communicate with you through electronic channels including email, telephone, SMS, and web-based platforms. Instructions sent through electronic means shall be deemed authentic and binding on you unless you notify us promptly of any unauthorised communication.
Electronic Instructions and Indemnity
You acknowledge and accept the risks associated with electronic communications, including interception, loss, delay, or corruption of data. You agree that Blue Marina shall not be liable for any losses arising from acting in good faith on instructions received electronically from you or your authorised representatives.
You agree to indemnify and hold Blue Marina harmless from any claim, loss, damage, or liability arising from such electronic communications, including any loss resulting from unauthorised access to your electronic credentials.
Monitoring
Your use of this website and our digital platforms may be monitored by Blue Marina for internal business purposes and in accordance with the rules of applicable regulatory and self-regulatory organisations. By using this website, you expressly consent to such monitoring, tracking, and recording.
Confidentiality
All information you provide to us will be treated as confidential and will not be used or disclosed in any manner incompatible with the purposes for which it was collected. Notwithstanding this, you acknowledge that Blue Marina may disclose and transfer your information to its affiliates, agents, or information providers, or where we have a legal right, duty, or obligation to do so. You consent to the processing and transfer of such information as necessary for the delivery of our services and in compliance with applicable law.
Website Content and Permitted Use
You are permitted to access, display, and print information from this website for your own personal, non-commercial use only. You are not permitted to publish, transmit, reproduce, or redistribute any content from this website in whole or in part, in any format, to any third party without the prior written consent of Blue Marina.
These Terms of Use do not transfer or grant any rights in or to the information on this website beyond those expressly described herein. All rights not expressly granted are reserved by Blue Marina.
You are strictly prohibited from:
- Unauthorised access to or misuse of our systems or website
- Misuse of passwords, login credentials, or account access
- Unauthorised entry into our systems or platforms
- Using this website for any unlawful purpose or in any manner that could damage, disable, overload, or impair our systems or services
No Warranty on Security
Blue Marina makes no warranty regarding the security of this website, including with respect to the ability of unauthorised persons to intercept or access information transmitted through it. We also make no warranty that files or information available on this website are free of viruses, malicious code, destructive materials, or other harmful components that could affect your device, network, or software. You are responsible for implementing appropriate security measures on your own devices and systems.
Service Availability
Access to this website may be unavailable, delayed, or limited from time to time due to hardware or software failures, system maintenance, network overloads, or other disruptions beyond our reasonable control. Blue Marina shall not be liable for any loss, damage, or inconvenience resulting from any such interruption or unavailability.
Limitation of Liability
Blue Marina shall not be liable for any indirect, incidental, special, or consequential loss or damage arising from your use of this website or our services, including loss of profit, loss of opportunity, or loss of data, even where Blue Marina has been advised of the possibility of such damages.
Blue Marina shall not be liable for the actions of third parties, including custodians, correspondent brokers, banks, or other service providers, or for losses arising from force majeure events, market disruptions, regulatory actions, or other circumstances beyond our reasonable control.
Death or Incapacity
In the event of your death, incapacity, bankruptcy, or insolvency, Blue Marina shall continue to act on your account in accordance with existing instructions until formally notified in writing by your lawful representatives, executors, or administrators, supported by appropriate legal documentation.
Intellectual Property
All content on this website, including text, graphics, logos, software, and other materials, is the property of Blue Marina or its licensors and is protected by applicable intellectual property laws. Users do not acquire any rights to any content on this website by accessing, downloading, or printing it. Copyright notices and trademarks may not be altered, removed, or obscured.
Users are not permitted to create hyperlinks or online links from any third-party website to this website without the prior written consent of Blue Marina.
Third-Party Links
This website may contain links to third-party websites for your convenience. Blue Marina does not endorse, control, or take responsibility for the content, accuracy, privacy practices, or security of any third-party site. The inclusion of any link does not imply endorsement, sponsorship, or affiliation. We have not tested the information, software, or products found on any linked site and make no representations with respect to them.
Data Privacy
Blue Marina will collect, process, and disclose your personal and financial information only in accordance with our Privacy Policy and applicable data protection laws, including the Nigeria Data Protection Act (NDPA) 2023. Please refer to the Privacy Policy tab on this page for full details.
Complaints and Dispute Resolution
We are committed to resolving client concerns promptly and fairly. If you have a complaint, please contact us at:
Email: info@bluemarina.com.ng
Address: 10, Keffi Street (2nd Floor), SW Ikoyi, Lagos, Nigeria
We will acknowledge your complaint and aim to resolve it within a reasonable timeframe. Where a complaint remains unresolved to your satisfaction, it may be escalated to the Securities and Exchange Commission (SEC) Nigeria or resolved through mediation or arbitration in accordance with applicable Nigerian law.
No Waiver
The failure of Blue Marina to exercise or enforce any right or provision of these Terms of Use does not constitute a waiver of that right or provision. Any waiver of a right or provision must be made in writing and signed by an authorised representative of Blue Marina to be effective.
Amendments
Blue Marina reserves the right to update or modify these Terms of Use at any time. The updated version will be effective as soon as it is published on this website. The date at the top of this tab reflects the most recent revision. Continued use of our website or services following any update constitutes your acceptance of the revised terms. We encourage you to review this page periodically.
Termination
Blue Marina reserves the right to suspend or terminate your access to this website or any of our digital platforms at any time without prior notice or liability to you. You agree that Blue Marina shall not be liable to you for any such suspension or termination.
Governing Law
These Terms of Use are governed by and construed in accordance with the laws of the Federal Republic of Nigeria. You agree to submit to the exclusive jurisdiction of Nigerian courts in the event of any dispute arising from your use of this website or our services.
