Privacy Notice

01Information We Collect

When you visit our website, contact us or use our services, we may collect information such as:

• Your name, email address and telephone number.
• Identification, CDS account, financial and transaction information needed to provide our services.
• Information you provide when opening or managing an account.
• Information about how you use our website and services.
• Technical information such as your device, browser and IP address.
• Communications you have with FourFront.

We only collect information reasonably necessary to provide our services, meet our legal and regulatory obligations and operate our business.

02How We Use Your Information

We may use your information to:

• Respond to your enquiries.
• Open and manage your account.
• Provide FourFront services and communicate with you about them.
• Verify your identity and meet regulatory requirements.
• Process and maintain records of transactions.
• Personalise how our advisory information is presented and explained to make it easier to understand.
• Improve our website, services and customer experience.
• Send service updates and, where permitted, marketing communications.
• Prevent fraud and protect our systems.
• Meet our legal and regulatory obligations.

We process personal information only where we have a lawful basis to do so, including where necessary to provide our services, meet legal or regulatory obligations, pursue legitimate business interests or where you have given consent.

03AI and Technology

FourFront uses technology, including algorithms and artificial intelligence, to analyse market information and identify potential investment opportunities.

We may also use your personal information to personalise how investment information, analysis and risks are presented and explained to you, making our advisory easier to understand.

Where personal information is used in automated processing, FourFront will process it in accordance with applicable data protection law and provide the safeguards required by law.

04Who We Share Information With

We may share your information where necessary with Standard Investment Bank, regulators, market infrastructure providers, custodians, technology providers and other service providers that help us provide our services.

We may also disclose information where required by law or by a competent regulatory or government authority.

We do not sell your personal information.

Where third parties process personal information on our behalf, we require appropriate measures to protect that information.

05How We Protect Your Information

We use appropriate technical and organisational measures to protect personal information against unauthorised access, loss, misuse, alteration or disclosure.

Access to personal information is limited to people and service providers who need it for legitimate business purposes.

06How Long We Keep Your Information

We keep personal information only for as long as necessary for the purpose for which it was collected and to meet applicable legal, regulatory and record-keeping requirements.

When information is no longer required, we take appropriate steps to securely delete or anonymise it.

07Your Rights

Under Kenya's Data Protection Act, you have rights regarding your personal information, including the right to:

• Be informed about how your information is used.
• Access personal information held about you.
• Object to certain processing of your information.
• Ask us to correct false or misleading information.
• Request deletion of false or misleading information.

08Information Outside Kenya

Some technology or service providers may process or store information outside Kenya.

Where personal information is transferred outside Kenya, we take appropriate steps to ensure that the transfer complies with applicable data protection law and appropriate safeguards are in place.

09Marketing Communications

Where permitted, we may contact you about FourFront products, services and opportunities that may be relevant to you.

You can ask us to stop sending marketing communications at any time by using the unsubscribe option provided or contacting us.

10Contact Us

If you have questions about this Privacy Notice, wish to exercise your rights or have concerns about how we handle your personal information, please contact:

11Changes to This Notice

We may update this Privacy Notice from time to time to reflect changes in our services, technology or legal requirements.