Introduction

Welcome to Aimvest, your digital wealth advisor! We work hard to protect your personal information and ensure your information is kept private and secure. The following privacy policy outlines the types of personal information that "Aimvest," a product/service of Ashfield Investment Managers Ltd. (‘‘Ashfield’’ or ‘‘AIM’’), collects through Aimvest’s Mobile Applications for iOS and Android devices, as well as via Aimvest’s Web Application. It also explains why we collect your information and how we use it.

Privacy is important to Ashfield. We will never rent or sell your information to anyone. If you have any questions or if you believe that Aimvest has not adhered to this privacy policy, please send us a note at support@aimvest.ai.

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Information We Collect and Why

We collect information primarily to satisfy legal requirements and to enable us to provide the services required under the Agreement between you and Ashfield. In order to provide high-quality service, Aimvest collects various types of information when you visit the website or mobile app, or sign up as a user.

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Visitor Information

We collect various types of anonymous information about visitors to Aimvest and Ashfield’s website, such as device-related information (including browser type and IP address) and server log information (including the date and time of day of your visit, average time spent on the Aimvest application, browsing activity, and any site that referred you to Aimvest). We also collect information that you input into Aimvest and our website, e.g., by beginning the account application process or by commenting on the Aimvest chat window. We use this information to better understand our visitors and our business, facilitate site navigation, provide the services or information you request, and enhance the Aimvest application.

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User Information

When you choose to create an account on Aimvest, we will also collect certain personal information, including your full legal name, email address, permanent address, date of birth, tax identification number, identity card details (specifically, your Ghana Card number, as the Ghana Card is the primary accepted form of identification for financial services in Ghana and passports for foreign nationals not domiciled in Ghana), and information about financial status. We are required by law to collect this information to provide you with financial services. If you do not wish to provide this information, you cannot become an Aimvest User.

As part of our automated identity verification process, we also collect biometric information, including a photograph or short video used for facial matching and liveness detection against your Ghana Card, and we screen your identifying information against government-provided lists of suspected terrorists, money launderers, and politically exposed persons, in each case in accordance with the Anti-Money Laundering Act, 2020 (Act 1044) and the SEC's AML/CFT/CPF Guidelines for capital market operators.

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Other Ways We Collect Information

Apart from through the account opening process and from visitors to our site, we may collect various other types of personal information if you engage with Aimvest. We collect your email address or phone number as part of our user referral service or if you subscribe to the Aimvest blog. We may also collect personal information if you enter into our live chat program or contact us or otherwise give it to us (e.g., in an email, phone call, or live chat with a member of our user support team). Further, we may collect information regarding your browsing activity when you visit Ashfield or Aimvest’s websites and actions you take within your Aimvest account while you are logged on.

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Cookies and Pixels

Cookies are small pieces of data that are stored on your computer, mobile phone, or any other device used to access the internet. Pixels are small code blocks on a website that allow another server to measure viewing of a webpage and often are used in connection with cookies.

We use these technologies to customize Aimvest and improve your experience with the application and our website. Cookies store anonymous information, such as whether you viewed the site from your mobile device. We may store some personal information in a cookie and/or pixel, such as the site that you visited immediately before visiting the Aimvest application or Ashfield’s website, and relevant financial information that allows us to enhance your user experience and for marketing purposes. Additionally, we may use a cookie and/or pixel that only stores anonymous information to track visitors across websites or devices to better customize our marketing and advertising campaigns.

Cookies, pixels, and similar technologies are not required for site functionality. You are not required to accept any cookies or pixels to use our site. However, refusing to accept cookies or pixels will make the use of Aimvest and our website more cumbersome and less accessible.

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Advertising Companies

Aimvest advertises its services on websites not affiliated with Ashfield, and we contract with third-party advertising companies to display these ads. These third-party advertising companies, along with data exchanges and similar providers, may use cookies and similar technologies to collect technical and web navigational information, such as device type, browser type, IP address, and pages visited. We do not provide any information to these advertising companies that could personally identify our users, and they do not collect such information for us.

Aimvest and third-party advertising companies may use the data collected to provide you with ads relevant to you and personalized content while you are on Aimvest or other sites. If you prefer to not receive targeted advertising, you can opt out of some network advertising programs that use your information. Please note that even if you choose to remove your information by opting out, you will still see advertisements while you are browsing online.

Additionally, many network advertising programs allow you to view and manage the interest categories they have compiled from your online browsing activities. These interest categories help determine the types of targeted advertisements you may receive.

Because mobile devices may vary in how they operate and may not use cookies, the choice management options listed above may not work for all mobile devices and mobile applications.

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Analytics Services

We use third-party analytics tools, including “Google Analytics” (such tools collectively referred to as “Analytics Services"), to collect information about the usage of this site. The Analytics Services collect information about how often users visit this site, what pages they visit when they do so, and what other sites they used prior to coming to this site, among other information. We use the information we get from these Analytics Services to improve this site and our mobile applications.

These analytics services collect the IP address assigned to you on the date you visit this site, along with other anonymized information (e.g., browser type and type of device used to visit the site), but not your name or other personally identifiable information. The Analytics Services’ ability to use and share information about your visits to this site is restricted by their terms of use and privacy policies. We do not combine the information collected through the use of Google Analytics with personally identifiable information.

You can prevent Google Analytics from recognizing you on return visits to this site by disabling cookies on your browser. You can opt-out of Google Analytics by installing the Google Analytics Opt-out Browser Add-on.

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How We Use Your Personal Information

Aimvest or Ashfield uses your personal information to enhance your user experience, provide user support, operate and maintain your account in accordance with Ghanaian law, investigate and understand how Aimvest is used, monitor and protect the security and integrity of Aimvest, and better market and advertise the Aimvest service. You understand and agree that Aimvest will compare your identifying information with government-provided lists of suspected terrorists and money launderers.

Additionally, we may use your personal information to contact you regarding our own services, resources, or Ashfield job openings that we think may be of interest to you. If you no longer wish to receive such marketing communications from Aimvest, please click the “unsubscribe” link that can be found at the bottom of each such email message.

 

Please note that if you hold an account with Aimvest, you cannot opt out of certain communications related to the administration of your account, including communications related to billing, statements, and trade confirmation delivery or certain regulatory matters.

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How We Share Your Information

We do not sell, rent, or trade your personal information with any third parties other than with your consent or as required by law.

In order to provide financial services and in connection with our everyday business purposes and activities, we may share your personal information with third parties who perform services on our behalf. Examples of these third parties and services include consumer identification verification services, payment service providers, public accounting firms, regulatory bodies and other professional firms, and certain other vendors and service providers who perform marketing, advertising, research, and analytics services on our behalf. We have entered into agreements that require that these third parties keep this information confidential. We may also disclose your information to other third-party financial institutions, e.g., if you ask to transfer assets from Aimvest to such financial institutions.

We may also disclose personal information in response to service of legal process, such as a court order, summons, or subpoena, or as permitted or required by law when we reasonably believe 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 Terms of Service or Client Agreements.

Furthermore, we may disclose personal information in specific other cases with your consent.

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How Your Personal Information Is Protected

Ashfield works diligently to protect your personal information. We employ several physical and electronic safeguards to keep your information safe. 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. We limit access to your personal and financial information to only those employees with authorized access who need to know the information in order to perform their jobs, and we require third parties who perform services for Aimvest or Ashfield to agree to keep your information confidential. Furthermore, if you choose to close your account or your account is terminated with us, we will continue to adhere to the privacy policies and practices outlined here. If you maintain an Aimvest account that you access through our website or mobile applications, you are responsible for protecting and maintaining the confidentiality of your account and password and restricting access to your computer or mobile device.

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How You Can Access or Change Your Personal Information That We Have Collected

Once you have registered with Ashfield to open an Aimvest account, you can access your profile, review the information that is stored, and revise that information. If you have any problems, you may also contact us at support@aimvest.ai. Due to Ghanaian regulatory requirements (including the record-keeping obligations under the SEC's Securities Industry (Conduct of Business) Guidelines 2020, which require market operators to preserve client records for seven years after the end of the client relationship, and the customer due diligence record-keeping duty under the Anti-Money Laundering Act, 2020 (Act 1044)), we do not delete

residual copies of outdated information and must preserve all User data for a minimum of seven (7) years.

Under the Data Protection Act, 2012 (Act 843), you have the right to: request access to the personal information we hold about you, which we will provide within twenty-one (21) days of a written request; request correction of inaccurate or incomplete information; request deletion of personal information we are not legally required to retain; object to certain processing of your personal information; and withdraw any consent you have given to processing, without affecting the lawfulness of processing carried out before you withdrew consent. You also have the right to lodge a complaint directly with the Data Protection Commission of Ghana if you believe your personal information has been processed unlawfully.

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Deleting Your Account

The Aimvest mobile and web applications include a “Delete Account” feature within your account settings that lets you request the permanent closure of your Aimvest account. You do not need the app installed to make this request — you may also ask us to delete your account at any time by emailing support@aimvest.ai. Before we can act on a deletion request, you must first withdraw all funds and reduce your account balance to zero, as described in the Client Agreement. Once your account balance is confirmed at zero and any outstanding obligations to Ashfield have been settled, we will close your account and deactivate your login credentials, generally within thirty (30) business days. Deleting your account closes your access to Aimvest, but it does not erase all of your personal information. As explained above, Ghanaian regulatory requirements oblige us to retain certain account, transaction, and identification records — including KYC and anti-money-laundering information for a minimum of seven (7) years from the date your account is closed, regardless of your deletion request. Any information we are not legally required to keep will be deleted or anonymized within a reasonable time after your account is closed.

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Data Protection Commission Registration

Ashfield Investment Managers Ltd is registered as a data controller with the Data Protection Commission of Ghana under the Data Protection Act, 2012 (Act 843), registration number 0006487, renewed every two years as required by the Act.

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Other Important Information

Former Users

If you are a former user, these policies also apply to you; we treat your information with the same care as we do information about current users.

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How We Respond to Do Not Track Signals

Online tracking is the collection of data about an individual’s Internet activity used to deliver targeted advertisements and for other purposes. Users using certain modern browsers have the ability to activate a “Do Not Track” signal. Aimvest does not currently respond to the “Do Not Track” signal.

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How You Accept This Policy

By using and continuing to use the Aimvest websites, mobile applications, and/or services, or otherwise providing us with personal information (such as an email address or phone number), you agree to the terms and conditions of this privacy policy and any updates thereto. This policy may change from time to time. This is our entire and exclusive privacy policy, and it supersedes any earlier version. In the event of any conflict between this Privacy Policy, the Ashfield Terms and Conditions, and a Client Agreement: (i) the Client Agreement governs all matters concerning the advisory relationship, the Account, and the provision of investment advisory and fund management services; (ii) this Privacy Policy governs all matters concerning the collection, use, and protection of personal information; and (iii) the Terms and Conditions govern all other matters relating to access to and use of the Platform not addressed by (i) or (ii).

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Changes to The Policy

We may modify this privacy policy over time without prior notice by posting a new version of this privacy policy, which is your responsibility to review. Any changes to the privacy policy will be reflected on this page and will become effective immediately upon posting. We encourage you to periodically review this privacy policy to stay informed about how we are protecting the personally identifiable information we collect. If changes to the privacy policy are material, we will do our best to notify you via email or through a notification on the site or application or via an SMS. Please check the effective date below to determine if there have been any changes since you have last reviewed the Aimvest Privacy Policy.

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Children

Our service is not directed towards anyone under the age of 18. If a parent or guardian becomes aware that his or her child under the age of 18 has created an account on our Aimvest Mobile application and/or provided us with personally identifiable information, please contact us at support@aimvest.ai. Additionally, if we become aware at any point that a child under the age of 18 is using our service, we will terminate his or her account immediately.

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International Visitors

This Service is hosted in Ghana. If you are an international visitor, you should note that by providing your personal information, you are: (i) permitting the transfer of your personal information to Ghana which may not have the same data protection laws as the country in which you reside; and (ii) permitting the use of your personal information in accordance with this privacy policy.

Where Ashfield itself transfers your personal information outside Ghana (for example, to a service provider, cloud hosting provider, or analytics provider located abroad), Ashfield will do so only where the Data Protection Act, 2012 (Act 843) permits, including where the recipient jurisdiction has an adequate level of data protection, where appropriate contractual safeguards requiring the recipient to protect your information to a standard consistent with Ghanaian law are in place, or where you have consented to the transfer.

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Questions

If you have any questions on the privacy policy, please contact us at:

Ashfield Investment Managers Ltd

The Investment House

18 Noi Fetreke Street

Airport West, Accra support@aimvest.ai

+233-540 127 125

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Last Amended Date: 1st September 2026