Privacy Policy

Axis Pension Trust Ltd (Axis) is committed to protecting the privacy and personal data of all our stakeholders. For the purposes of this Privacy Policy “the Policy”, our stakeholders include clients, employees, shareholders, directors and/or trustees, beneficiaries, ultimate beneficial owners and third party service providers. The Policy has been approved by the Board and details how we at Axis collect, use, share, protect and delete information of our stakeholders in accordance with Data Protection Act, 2012 (Act 843) and other applicable international data protection laws. The Policy also details the rights of data subjects. If you have any questions, comments or concerns regarding this privacy policy, please contact Axis at privacypolicy@axispension.com

PERSONAL DATA AXIS COLLECTS

Axis collects only personal data necessary for providing its pension services, managing its staff personnel and complying with various regulatory reporting requirements. Some examples of personal data Axis collects includes:

(i) Name, address, contact details, date of birth, ID card details, geographical location;
(ii) Employment history;
(iii) Bank account details, tax identification number, social security number; and
(iv) Beneficiary information and next of Kin information.

WHY AXIS COLLECTS PERSONAL DATA

Axis collects personal data for the purposes of providing pension services, managing its staff personnel as well as complying with various regulatory reporting requirements. Some legal basis for collecting and processing the personal data have been highlighted below:

(i) Setting up and administering pension accounts;
(ii) Payment of retirement benefits;
(iii) Payroll administration;
(iv) Renewal of regulatory licenses;
(v) Reporting to regulatory authorities;
(vi) Customer Due Diligence and Anti-Money Laundering checks;
(vii) Financial inclusion and literacy services.

HOW AXIS USES AND SHARES THE DATA COLLECTED

Axis processes personal data by taking into account the privacy of its data subjects by applying the data protection principles. Axis may share personal information on its data subjects for legitimate purposes. Axis may share such information to trusted third parties such as Regulators, IT support systems, service providers and security agencies. In addition, Axis may disclose personal data to comply with valid legal processes such as a search warrant, subpoena, or court order, if we find that a data subject’s actions violate our policies, or to protect our rights and property, and that of our affiliates or successors to the relevant portions of our business.

All such third parties would be bound by the same terms of data privacy measures and confidentiality. In addition to the purpose for which data subjects originally submitted personal data to Axis, Axis may also share personal data with its affiliates to make you aware of other benefits, products, services or events that may interest you within the context of the financial services sector and also to improve the content and efficiency of Axis’s services. Axis’ mobile application may collect information on data subjects’ geographical location. This information is required to comply with regulatory Customer Due Diligence procedures and also to process any unclaimed benefits in data subjects’ accounts.

The information shall not be sold to any third parties. by law and such information is processed strictly in compliance with the data protection laws. Axis does not share personal data with other aggregated and/or anonymous information that we have collected based on web usage data or statistical information that we have compiled about our users without their consent. Axis does not transfer personal data outside the jurisdiction of Ghana, however should this change, Axis would ensure strict compliance with cross border data protection laws and ensure all contractual agreements are in place to protect the privacy of data subjects.

WEB TOOLS

Axis may use various web tools such as cookies, web beacons or other technologies “Web Tools” on its website, customer portal, mobile app and chat bot. These Web Tools are to enhance the users’ experience and allow Axis to provide personalised content for the users.

RETENTION OF YOUR PERSONAL DATA

In accordance with the Occupational and Personal Pension Schemes (General) Regulations, 2011 (L.I. 1990), accounting records and records of data subjects are kept by Axis for a minimum of seven years following the termination of the business relationship with the data subject. After the seventh year Axis securely archives the information on the data subject following which the data is deleted.

DATA SUBJECTS’ RIGHTS

As a data subject, you have various rights provided under the data protection laws. These rights are:


(i) Rights to access;
(ii) Right to rectification;
(iii) Right to be informed;
(iv) Right to Object to processing of data;
(v) Right to “Opt in” and “Opt out”;
(vi) Freedom from automated decision making;
(vii) Right to porting of data;
(viii) Right to complain;
(ix) Right to compensation; and
(x) Right to deletion.

 

If you would like to exercise any of the above rights, or have any questions, comments or complaints regarding this Policy, please contact Axis at privacypolicy@axispension.com.

YOUR ABILITY TO CHOOSE

Axis communicates with you in providing you our services. Axis may also send you information from the Company and our third-party service providers. You may always choose to not receive our marketing emails by following the instructions at the bottom of each email you receive from us. You may also change your preferences regarding the types of emails you receive from us by emailing us at privacypolicy@axispension.com

SECURITY

Axis stores personal data using secure servers. Axis also uses other measures such as server encryption, varied levels of access for employees, continuous staff and stakeholder sensitization and period audits and vulnerability testing to ensure the data privacy of all its data subjects. Axis will at all times maintain commercially approved safeguards to help prevent unauthorized access and maintain data security. It is also important to note that no transmission of data over the Internet is guaranteed to be completely secure and Axis cannot guarantee the absolute security of any information you provide to us.

YOUR ABILITY TO CHOOSE
We communicate with you to provide you information that you have requested. We may also send you information and offers from the Company and our third-party service providers. You may always choose to not receive our marketing emails by following the instructions at the bottom of each email you receive from us. You may also change your preferences regarding the types of emails you receive from us by emailing us at privacypolicy@axispension.com
LINKS TO OTHER SITES

Our website, apps and portals may contain links to third-party websites that are provided for your convenience.
Axis does not endorse nor is it responsible for the privacy practices or the content or services of such websites. We recommend that you review the privacy policies and terms of use that govern those websites when you visit them.

CHILDREN

Our services are directed towards adults. Axis does not knowingly collect information from children under the age of 15. Children under the age of 15 should not use this website or submit information to us.

REVIEWING YOUR INFORMATION

You may review and update your personal data Axis has collected about you by contacting us at privacypolicy@axispension.com or aptl@axispension.com or on any of the links provided on our website, portals or apps.

To protect your privacy and security, we may take reasonable steps to verify your identity before we make any corrections to such information and also to comply with other laws such as Anti-Money Laundering laws.

POLICY MODIFICATIONS

We reserve the right to change this Policy from time to time to reflect changes in our business practices and to align with local and international laws. Any changes to this Policy, including information collected and the use and disclosure of information, would be updated here. Following any modification, we will revise the “last updated” date at the top of this Policy.

“Personal Data” refers to information that personally identifies you, such as your name, mailing address, telephone number, email address or Internet Protocol (IP) address.

When you visit Axis’ website, portals and apps and click that you agree to our data processing, you affirmatively consent to our use and disclosure of Personal Information as described in this Policy. Please read this Policy carefully.