Privacy Policy

We reserve the right to change this policy at any given time of which you will be promptly updated.

  1. What user data we collect:

    2. When you visit our site we may collect the following data:

    • Your IP address
    • Your contact information and email address
    • Other information such as interests and preferences.
    • Data profile regarding your online behaviour on our site.
  2. How We Use Your Information

    3. Specifically, we may use information collected about you via the Application to:

    1. Create and manage your account
    2. Compile anonymous statistical data and analysis for use internally.
    3. Email you regarding your account.
    4. Enable user-to-user communications.
    5. Increase the efficiency and operation of the Application.
    6. Request feedback and contact you about your use of the Application.
    7. Resolve disputes and troubleshoot problems.
    8. Send you a newsletter.
    9. Solicit support for the Application.
  3. Why We Collect Your Data
    1. We are collecting your data for several reasons:
      • To better understand your needs.
      • To improve our services and products.
      • To send you promotional emails containing the information we think you will find interesting.
      • To contact you to fill out surveys and participate in other types of market research.
      • To customize our blog according to your online behavior and personal preferences.
    2. Personal information collected automatically:

      3. We Collect certain personal information automatically when you visit our online services including:

      Location Data

      To help us protect you against fraud, provide our services to you and improve our services, we collect location data including current and historical information concerning users geographic locations and IP address that we use in conjunction with our service.

    3. Disclosure of your Information

      4. We may share information we have collected about you in certain situations. Your information may be disclosed as follows:

      By Law or to Protect Rights, if we believe the release of information about you is necessary to respond to legal process, to investigate or remedy potential violations of our policies, or to protect the rights, property, and safety of others, we may share your information as permitted or required by any applicable law, rule, or regulation. This includes exchanging information with other entities for fraud protection and credit risk reduction.

    4. Mobile Device Access

      5. We may request access or permission to certain features from your mobile device, including your mobile device's storage. If you wish to change our access or permissions, you may do soin your device's settings.

    5. Safeguarding and Securing the Data:

      6. EMA is committed to securing your data and keeping it confidential. EMA has done all in its power to prevent data theft, unauthorized access, and disclosure by implementing the latest technologies and software, which help us safeguard all the information we collect online.

    6. Our Cookie Policy

      7. Once you agree to allow EMA to use cookies, you also agree to use the data it collects regarding your online behaviour (analyse web traffic, web pages you visit and spend the most time on). The data we collect by using cookies is used to customize our app to your needs. After we use the data for statistical analysis, the data is completely removed from our systems. Please note that cookies don't allow us to gain control of your computer in any way. They are strictly used to monitor which pages you find useful and which you do not so that we can provide a better experience for you. If you want to disable cookies, you can do it by accessing the settings of your internet browser. You can visit https://www.internetcookies.com, which contains comprehensive information on how to do this on a wide variety of browsers and devices.

    7. Links to Other Websites:

      8. Our Website/EMA contains links that lead to other sites If you click on these links EMA is not held responsible for your data and privacy protection. Visiting those websites is not governed by this privacy policy agreement. Make sure to read the privacy policy documentation of the website you go to from our website.

    8. Restricting the Collection of your Personal Data:

      9. At some point, you might wish to restrict the use and collection of your personal data. You can achieve this by doing the following when you are filling the forms on the EMA, make sure to check if there is a box which you can leave unchecked, if you don't want to disclose your personal information. If you have already agreed to share your information with us, feel free to contact us via email and we will be more than happy to change this for you. Website/EMA will not lease, sell or distribute your personal information to any third parties, unless we have your permission. We might do so if the law forces us. Your personal information will be used when we need to send you promotional materials if you agree to this privacy policy.

    9. Our Security Measures:

      10. The security of your information is important to us. We use appropriate personal and organisational safeguards to protect your information from unauthorised use, disclosure and loss. We encourage you to take reasonable measures to protect your password and your computer to prevent unauthorised access to your account.

    10. Changes to this policy:

      11. We may change this privacy policy from time to time to reflect the new ways that we process your information. When we post modifications to this Privacy Policy, we would revise the “last updated” date at the top of this page. The modified Privacy Policy will be effective immediately upon posting the service. If we make significant changes that affect your information, we would provide you with notice of changes through the app, by email or some other means of contact.

    11. Options Regarding Your Information

      12. You may at any time review or change the information in your account or terminate your account by:

      • Logging into your account settings and updating your account
      • Contacting us using the contact information provided below
      • Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with legal requirements.

      Emails and Communications If you no longer wish to receive correspondence, emails, or other communications from us, you may opt-out by:

      • Noting your preferences at the time you register your account with the Application
      • Logging into your account settings and updating your preferences.
      • Contacting us using the contact information provided below if you no longer wish to receive correspondence, emails, or other communications from third parties, you are responsible for contacting the third party.
    12. Contact Us:

      13. Event Peak LCC welcomes comments, questions and concerns. Please contact us by visiting https://event-money.com for more information about us.

EVENT PEAK LIMITED Anti-Money Laundering (AML) Policy and KYC Policy

Dated 21st January 2025

AML stands for Anti-Money Laundering, which refers to a set of procedures, laws, and regulations designed to prevent, detect, and report money laundering activities.

Money laundering is the process of disguising the origins of illegally obtained money, typically by means of transfers involving financial institutions, to make the funds appear legitimate.

Money Laundering can also be defined as the process of converting funds obtained illegally (fraud, corruption and terrorism) via the means of transfers or transactions that make the money appear legitimate.

Criminals engage in money laundering to hide the true source of their illicit funds, often stemming from activities like drug trafficking, fraud, corruption, or terrorism.

  1. EVENT PEAK LIMITED is committed to ensuring that its services, systems, and resources are not used to facilitate money laundering, terrorist financing, or other illicit activities. This Anti-Money Laundering (AML) Policy establishes procedures, controls, and guidelines to detect, deter, and report suspicious activities in compliance with Nigerian laws and regulations.
  2. This policy applies to all employees, contractors, partners, and third-party service providers of [Event Peak Limited]. It covers all business activities, including software development, IT services, cloud storage, and financial transactions processed through the company's systems.
  3. The Legal and Regulatory Compliance

    4. EVENT PEAK LIMITED adheres to the provisions of all applicable anti-money laundering laws in Nigeria, including but not limited to:

    • The Money Laundering (Prevention and Prohibition) Act, 2022
    • The Central Bank of Nigeria (CBN) AML/CFT Regulations
    • The Economic and Financial Crimes Commission (EFCC) Act
    • The Nigerian Financial Intelligence Unit (NFIU) Guidelines
    • Nigerian Data Protection Act

    GENERAL PROVISIONS

    This is a policy of EVENT PEAK LTD a company registered under the laws of the Federal Republic of Nigeria on the 19th of June 2024 with its registered office at 14, CHURCH CLOSE, BAKARE ESTATE, ISHERI/IGANDO/LASU ROAD, LAGOS STATE, NIGERIA. herein referred to as the Company on combating money laundery. Event Peak Limited is a company engaged in Information Technology,and other contracts.

  4. Definitions
    • Money Laundering: The process by which criminals disguise the proceeds of illegal activities as legitimate funds.
    • Terrorist Financing: Providing funds or financial services with the intention of supporting terrorist activities.
    • Customer Due Diligence (CDD): Processes used to verify the identity and assess the risk level of customers.
    • KYC is Know of the customer.
  5. Know Your Customer (KYC):
    • CUSTOMER DUE DILIGENCE

      • Event Peak Limited shall establish the following measures for potential customers and existing customers in line with the law: —

      • ensure identification and verification of identity of beneficial owners via Bank Verification Number.
      • Implement enhanced due diligence for high-risk customers, including politically exposed persons (PEPs) via our current verification procedure.
    • Event Peak Limited shall take measures to identify their customer (whether permanent or occasional, and whether natural or legal persons or legal arrangements) and obtain the following information —

      • (a) for Individuals —

      • legal name and any other names used (such as maiden name),
      • Telephone number and email address;
      • Bank Verification Number (BVN),
    • Event Peak Limited shall take measures to verify the identity of customers via their Bank Verification number.
    • Event Peak Limited shall verify —
      • that any person purporting to act on behalf of a customer is so authorized ; and
      • the identity of the person purporting to act on behalf of a customer.
    • Event Peak Limited Shall take measures for high risks customers as appropriate.
    • Event peak Limited shall ensure that documents, data or information collected under then customer due diligence process is kept up-to-date and relevant by undertaking reviews of existing records, particularly for higher risk categories of customers or business relationships.
    • These verification shall however be subject to the laid down rules on data collection and data processing under the Nigerian Data Protection Act 2023.
  6. Risk-Based Approach:
    • Event Peak Limited shall where higher risks are identified, apply enhanced measures to manage and mitigate the risk;
    • where lower risks are identified, Event Peak shall take simplified measures to manage and mitigate the risks, provided that simplified customer due diligent measures are not permitted whenever there is suspicion of money laundering or terrorist financing; and
    • Categorize customers, transactions, and activities into low, medium, and high-risk tiers.
    • Apply stricter monitoring and controls to high-risk transactions or customers.
  7. Transaction Monitoring:
    • Continuously monitor transactions for unusual patterns or activities.
    • Flag and investigate transactions above established thresholds or those involving high-risk regions.
  8. Record Keeping:

    9. The Company will principally retain the following records from an AML perspective:

    • Maintain detailed records of customer identification, due diligence, and transaction data for at least five years, in compliance with Nigerian laws;
    • Copies of, or references to, the evidence obtained of a customer’s identity for five years after the end of the customer relationship;
    • Details of customer transactions for five years from the date of the relevant transaction;
    • Records of all AML training delivered;
    • Details of actions taken in respect of internal and external suspicion reports;
    • Details of information in respect of an internal report where no external report is made.
    • all records of account files and business correspondence, and results of any analysis undertaken,for at least five years following the termination of the business relationship or after the date of the occasional transaction.

      • The records referred to above shall be—

    • sufficient to permit individual transactions to be readily reconstructed at any time by the competent authorities ; and
    • made swiftly available to the competent authorities.
  9. Reporting:

      10. Event Peak Limited shall appoint a Anti Money Laundery Reporting Officer;

    • Where an employee or member of management suspects that money laundering is occurring or has occurred, they should be concerned that their involvement in the matter could potentially facilitate the acquisition, concealment, conversion, possession, or retention of criminal property (which constitutes a prohibited act). In such cases, they must report their concerns to the Money Laundering Reporting Officer (MLRO) as soon as possible. This disclosure should be made either before or at the time the activity takes place. If the report is made afterward, a valid and justifiable reason must be provided.

      • Review of the Disclosure by the Money Laundering Reporting Officer (MLRO)

      • Upon receiving a disclosure report, the MLRO will record the date of receipt and confirm acknowledgement of the report. They will also inform you of the expected timeline for a response.
      • The MLRO will review the report along with any other relevant internal information and conduct any necessary inquiries to determine if a report to the Special Control Unit Against Money Laundering (SUCML) is required. Additionally, the MLRO may need to consult with you regarding the details of the report.
      • The MLRO must submit a report to the Special Control Unit Against Money Laundering (SCUML)as soon as practicable. However, the report may be delayed if there is a legitimate reason for not doing so immediately.
      • If consent from the SCUML is required for a transaction to proceed, the transaction(s) must not be carried out or completed until explicit consent is granted by the SCUML, or until deemed consent is given through the expiration of the relevant time limits without objection from the SCUML.
      • If the MLRO determines there are no reasonable grounds to suspect money laundering, the record should be marked accordingly, and consent will be given for any ongoing or imminent transaction(s) to proceed.
      • All disclosure reports referred to the MLRO, as well as reports submitted by the MLRO to the SCUML, must be securely retained by the MLRO for a minimum of five years.
  10. Ensure employees know how to escalate concerns internally.
  11. Responsibilities

    12. Compliance

    Event Peak Limited will establish a body responsible for the implementation of this policy.

    Event Peak Limited will carry out the procedure to identify any irregularity on behalf of any stakeholder under this policy. The company shall:

    • Identify all the financer of the company and verify their identity
    • Take special care where stakeholders want anonymity
    • Maintain proper records of the stakeholders

    If anyone in Event Peak Limited knows or suspects that a person is involved in money laundering or terror financing, it is their responsibility to report such person to the MLRO established by Event Peak Limited. In such a case, Event Peak Limited must:

    • Take the details of the people involved
    • Verify the type of transactions
    • Reason for suspicion
    • The amount involved

    Event Peak Limited must consult with the legal department before embarking on business with a third party and carefully screen such interactions.

    The Event Peak Limited, with the support of the Board, is responsible for ensuring that it meets AML compliance requirements in accordance with applicable laws in Nigeria. Event Peak Limited will oversee the AML systems and controls and ensure they are fit for purpose.

  12. Compliance Officer:
    • Oversee the implementation of the AML policy.
    • Serve as the point of contact with Nigerian regulatory authorities.
    • Conduct periodic reviews and audits of the AML program.

    Event Peak Limited shall establish an internal audit unit to ensure compliance with and effectiveness of the measures taken to enforce AML.

  13. Employees:
    • Adhere to AML training and internal reporting procedures.
    • Be vigilant and report any suspicious activities.
  14. Third-Party Providers:
    • Ensure third-party vendors comply with [Company Name]'s AML standards.
    • Incorporate AML requirements into contracts with partners.
  15. AML Risk Assessment
    • Event Peak Limited will adopt a risk-based approach to managing the risks presented by the business, taking into account legislation and industry guidance as applicable.
    • Event Peak Limited is responsible for ensuring an AML risk assessment is completed and regularly reviewed. The risks assessed should help determine the strength of Event Peak Limited’s policies and procedures and control systems in place to help prevent and detect such money laundering or terrorist financing activity.
    • The risk-based approach takes the most cost effective and proportionate way to manage and mitigate money laundering and terrorist financing risks. Event Peak Limited will assess the money laundering and terrorist risks presented by:
    • Customer risk - specific categories of customers and the resulting business relationships
    • Payment risk - payment methods offered and the degree to which their specific characteristics are vulnerable to AML threats
    • Geographical risk - the risks posed by geographical factors
    • Technological Risk - risks with technology used by the company / how susceptible is it to money laundering or terrorist financing?
    • Employee Risk - the risks posed by employees of the company
    • Regulatory Risk - the risks of non-compliance with license and regulatory frameworks and the risk of penalties to the company and individuals.
    • Data Risk- the risk of processing personal data of customers.

      • Event Peak Limited shall also :

    • Design and implement controls to manage and mitigate those risks;
    • Monitor and seek to improve the operation of these controls; and
    • Record what has been done for audit and evidence purposes.
    • Event Peak Limited recognises that risks change over time and will continually and regularly update its risk management procedures as part of its overall risk management framework.
  16. TRAINING AND AWARENESS

    17. Event Peak Limited will provide mandatory AML training to all relevant employee annually, covering:

    • Recognition of money laundering and terrorist financing activities.
    • Internal procedures for reporting suspicious activities.
    • Updates on Nigerian regulatory changes.
    • All employees will be made aware, through the annual compulsory training programme, of:
    • Event peak Limited shall lay down the procedures on how to recognise and deal with potential money laundering or terrorist financing suspicious transactions or activity.
    • Staff training on anti-money laundering and counter terrorist financing will be carried out at least annually for all staff, and details will be recorded.
    • Ensure all staff are informed about the responsibilities and obligations imposed by anti-money laundering legislation.
    • Provide targeted training for staff most likely to encounter money laundering situations.
    • Develop guidance notes to support staff in implementing this policy.
    • Make the policy, guidance documents, and reporting forms accessible to officers and members via the intranet.
    • Send regular reminders to staff regarding the requirements of the Council's Anti-Money Laundering Policy.
  17. ACCOUNTABILITY

    18. Anti-Money Laundering Policy shall be communicated internally and externally as applicable. The management of the Event Peak Limited has overall responsibility for the Policy implementation.

    Event Peak Limited will track the performance and review the effectiveness of the Anti-Money Laundering Policy and procedures, supporting the implementation of the Policy, and make necessary updates to the procedures at least annually or where there is a significant change of circumstances to ensure its continuous improvement

  18. Non-Compliance

    19. Failure to comply with this policy may result in disciplinary action, up to and including termination of employment or business relationships. Legal penalties may also apply where applicable.

  19. Review and Updates

    20. This AML Policy will be reviewed and updated annually or as required by changes in Nigerian legislation or business operations.

  20. Approval and Endorsement

    21. This policy has been approved by [Babatunde Joshua /Director ] and is effective as of January 28 2025.

Contact Information

For questions or concerns about this policy, please contact Modupe Oluwadare at modupeolawadare22@gmail.com or +234 817 718 3517.

These Terms of Use are effective as of January 30, 2025.