Privacy Policy

Ensuring Your Privacy

Earning your trust is XENO’s top priority. The privacy of your information is essential to earning and keeping that trust. All the decision we make about how we gather, store, and use any information we obtain from you is driven by this principle. Your personal information will never be traded, rented, or sold to anyone.

Introduction

MYXENO Investment Management (“XENO”, “we”, “us” and/or “our”) operates an Automated Investment Management Platform (“Platform”). The Platform is available on our website, mobile application, and USSD. This Privacy Policy details how XENO handles your personal information whenever you use our Platform. Throughout this agreement, a Visitor refers to a person who uses our Platform to assess our Platform, or for purpose of gaining information. On the other hand, a Client is a person who signs our Investment Management Agreement and sets up an investment account with us. This Privacy Policy governs your use of our Platform.

Collection of Information

The kind of information we collect depends on whether you are a Visitor or a Client. We collect Personal Information from you when you voluntarily provide information to us. Examples of instances when we collect Personal Information include when you answer questions on our website to select your goal and determine your risk tolerance and the recommended investment portfolio if you were to become a Client.

The information collected includes some information that you voluntarily provide such as; age. We may also collect your name, email address, and/or telephone number whenever you choose to engage with us through our website, mobile application, USSD, email, text message or telephone. This information is collected whenever you are in the process of registering to open an investment account when you contact us through the landing page or inside your account when you become a Client. At whatever point XENO collects Personal Information, we make sure to link to this Privacy Policy and other relevant policies, like our Terms of Use. Specifically, we collect this information from Visitors and Clients;

• Visitor Information collected.

  To use our Platform, we may collect certain personal information such as name, address, telephone number, and email address. We also collect some information that you voluntarily provide such as age bracket, investable assets, financial goals and objectives, income information, and other critical financial planning information. We may collect your name, e-mail address and/or telephone number whenever you choose to engage with us through our website, mobile application, USSD, email or telephone.

• Client Information collected

  Because investment management is a highly regulated industry, if you choose to become a Client, besides the information we collect from you as a Visitor, we will also collect information that includes, but is not limited to: full legal name, biographical information such as date of birth contact information, identification documents citizenship and/or country of residence, investment objectives, net worth, and other regulatory disclosures that are required under by the regulators and other government agencies.

Partnerships

If we onboard you from any of our partners (or you interact with our Platform using integration provided by any of our partners) who collect your information, you consent to your user details that are relevant for consuming the services offered by XENO to be transferred to us by our Partner.

Use of Information

The information that is taken from both Visitors and Clients by XENO is stored, processed, and maintained securely. It helps us to provide Client support, roll out innovative products or services and operate within the rules and regulations set by the Capital Markets Authority, and other government agencies. Provision of the information is voluntary, however, if you decide not to provide the requisite information, you will most certainly not be able to use the full functionality of the Platform or even become a Client. Occasionally, we may share the information required to become a Client with third parties such as our custodian, trustee, and brokerage partners specifically to allow them to provide services to you. We may periodically use your Personal Information to relay certain critical information to you about our Platform. If you decide at any time that you do not wish to receive certain marketing information, use the “unsubscribe” steps included in every communication to cause this to stop. However, even when you unsubscribe from receiving marketing information, we will still send periodic administrative information such as billing and Platform notifications as well as obligatory regulatory notifications.

Information Sharing and Exceptions

XENO does not sell, rent, or trade your personal information with any third parties other than with your consent or as required by law. However, to efficiently provide our services and for our business operations, we may share your personal information with third parties, including but not limited to: consumer identification verification services, public accounting firms, and certain other service providers (including companies that perform marketing and analytics services).

• For any third parties we may share your information with, we have entered into agreements that require them to keep this information confidential. In addition, we may disclose your information to other third-party financial institutions, e.g., if you ask us to transfer your assets from XENO to such other financial institutions.
• We may also disclose personal information in response to service of legal process, such as court orders, summons, or subpoenas, or as permitted or required by law when we reasonably deem it is necessary or appropriate to investigate, prevent, or take action regarding illegal activities, suspected fraud (including identity theft), front-running or scalping, situations involving potential threats to the physical safety of any person, or suspected violations of our Privacy Policy, Terms of Use or other customer agreements.
• Furthermore, we may disclose personal information in specific other cases with your express consent. In order to provide workplace services to employers or plan sponsors, such as retirement savings plan services and recordkeeping services, we may exchange any information received in connection with such services with the employer or plan sponsor or other authorized service providers. We may also share information, including but not limited to account positions, contributions, and distributions, and with a third-party financial institution that serves as a trustee, or custodian bank.
• You may request deletion of personal information by emailing kenya@myxeno.com. and providing us with enough information to identify your account and prove that you are the owner of the identified account. We will endeavour to make any deletion request effective as soon as reasonably practicable. However, we may retain residual information related to your account, as well as any data related to your trades, in accordance with applicable laws.
• Under no circumstances will we share any personal information data unless lawfully required by courts of law, the regulators or other government agencies. You may decline to provide personal information to XENO. Declining to provide personal information may disqualify you from accessing XENO services and Site features that require certain personal information.

How Your Personal Information is Protected

XENO works diligently to protect your personal information. We deploy several physical and electronic safeguards to keep your information safe and private. We use the strongest available browser encryption, store all of our data on servers in secure facilities, and implement systematic processes and procedures for securing and storing data. For example, we limit access to your personal and financial information to only those employees with authorized access who need to know the information to perform their jobs, and we require third parties who perform services for XENO to agree to keep your information confidential. Moreover, if you decide to close your account or your account is terminated with us, we will continue to adhere to the privacy policies and practices outlined here. Please note that, if you maintain a XENO account that you access through our website, you are responsible for protecting and maintaining the confidentiality of your account and password and restricting access to your computer.

Accessing or Changing Personal Information Collected

Once you have registered with XENO, you can access your profile, review the information that is stored, and revise that information. If you have any problems, please contact us at kenya@myxeno.com. However, due to regulatory requirements, we do not delete residual copies of outdated information and must therefore preserve all customer data for a minimum of seven years.

Other Important Information