Privacy Policy

Effective Date: 1st July 2026.

1. Introduction

E.V. Atenaga & Associates LLP ("the Firm", "we", "our", or "us") is committed to protecting the privacy, confidentiality, and security of the personal information entrusted to us. As a modern law firm providing legal services to individuals, businesses, entrepreneurs, investors, and international clients, we recognise that privacy and responsible data governance are fundamental to the trust our clients place in us.

This Privacy Policy explains how we collect, use, disclose, store, and otherwise process personal information obtained through our website, www.evallp.com ("Website"), our online consultation services, communications, publications, legal insights, and other digital platforms operated by the Firm.

Our objective is to ensure that personal information is processed lawfully, fairly, transparently, and securely in accordance with applicable data protection laws and recognised international privacy standards.

2. Applicable Legal Framework

This Privacy Policy has been prepared principally in accordance with the:

• Nigeria Data Protection Act, 2023 (NDPA);

• Regulations, directives, and guidance issued by the Nigeria Data Protection Commission (NDPC);

• Other applicable laws governing privacy, confidentiality, and legal professional obligations.

Where we collect or process personal information relating to individuals located within jurisdictions that provide additional statutory privacy protections, including the European Economic Area (EEA) and the United Kingdom, we endeavour, where applicable, to process such information consistently with the principles of the General Data Protection Regulation (GDPR) and other relevant international privacy standards.

Nothing in this Privacy Policy should be interpreted as representing that the GDPR applies in every circumstance. References to international privacy standards are intended to reflect our commitment to recognised principles of responsible data processing where such obligations are applicable.

3. Scope of this Privacy Policy

This Privacy Policy applies to personal information collected through:

• this Website;

• enquiries submitted through our contact forms;

• requests for consultations or legal services;

• appointment booking platforms integrated with our Website;

• electronic communications with the Firm;

• subscriptions to legal publications, newsletters, or updates (where available);

• participation in webinars, educational videos, legal commentary, or other digital content published by the Firm;

• interactions with us through social media platforms linked from this Website;

• Any other personal information voluntarily provided to the Firm through our digital services.

This Privacy Policy does not apply to third-party websites or services that may be accessible through links provided on this Website. Those websites operate under their own privacy policies and terms, for which the Firm accepts no responsibility.

4. Definitions

For this Privacy Policy:

"Personal Information" means any information relating to an identified or identifiable natural person, including any information recognised as personal data under the Nigeria Data Protection Act, 2023 and, where applicable, the General Data Protection Regulation.

"Processing" includes collecting, recording, organising, storing, adapting, retrieving, consulting, using, disclosing, transmitting, combining, restricting, deleting, or otherwise handling personal information.

"Data Subject" means any identified or identifiable individual whose personal information is processed by the Firm.

"Website" means the official website of E.V. Atenaga & Associates LLP located at www.evallp.com, including its associated pages, legal insights, publications, consultation services, and digital content.

"Third-Party Service Provider" means any external organisation or technology provider engaged by the Firm to facilitate the operation of this Website, including website hosting, analytics, appointment scheduling, email communications, embedded media, mapping services, or other technology infrastructure.

5. Information We Collect

The categories of personal information we collect depend on how you interact with our Website and the services you request. We only collect personal information that is reasonably necessary for the purposes described in this Privacy Policy.

A. Information You Voluntarily Provide

When you contact us, request legal information, book a consultation, or otherwise interact with the Firm, we may collect information including:

• Full name;

• Email address;

• Telephone number;

• Company or organisation (where applicable);

• Country and location;

• Subject matter of your enquiry;

• Information contained in messages or correspondence you voluntarily submit;

• Information provided during consultation booking;

• Any documents or supporting materials voluntarily uploaded or transmitted to us in connection with an enquiry or legal service.

You should only provide personal information that is relevant to your enquiry or legal matter. Where your submission contains personal information relating to another individual, you represent that you have the necessary authority or lawful basis to disclose such information.

B. Consultation and Client Information

Where you request legal advice or engage the Firm, we may collect additional information necessary to assess your enquiry, perform conflict checks, comply with applicable legal obligations, and provide legal services.

Depending on the nature of the engagement, this may include:

• Identification information;

• Business or corporate information;

• Transaction details;

• Immigration-related information;

• Intellectual property information;

• Documents supplied for legal review;

• Billing and invoicing information;

• Communications relating to your matter.

The specific information collected will depend on the legal services requested and will be limited to what is reasonably necessary for those purposes.

C. Automatically Collected Technical Information

When you visit our Website, certain technical information may be collected automatically through your browser or device.

This may include:

• IP address;

• Browser type and version;

• Operating system;

• Device type;

• Language preferences;

• Date and time of access;

• Pages visited;

• Time spent on pages;

• Navigation patterns;

• Referral URLs;

• Website performance and diagnostic information.

This information is primarily used to maintain the security, performance, and functionality of the Website and to better understand how visitors use our content.

D. Cookies and Similar Technologies

Our Website uses cookies and similar technologies to improve functionality, enhance user experience, analyse website performance, remember user preferences, and maintain the security of our services.

Cookies may be placed by:

• the Firm;

• our website hosting provider;

• analytics providers;

• embedded content providers; and

• other technology partners supporting the operation of our Website.

Further information regarding our use of cookies is available in our Cookie Policy.

E. Analytics Information

Where analytics tools are implemented, we may collect aggregated information regarding how visitors interact with our Website.

This information may include:

• pages viewed;

• session duration;

• navigation paths;

• approximate geographic location derived from IP addresses;

• traffic sources;

• device characteristics; and

• General usage statistics.

Analytics information is generally processed in aggregated or pseudonymised form and is used solely to improve the functionality, accessibility, security, and effectiveness of our Website and legal publications.

F. Embedded Third-Party Content

Our Website may contain embedded content and services provided by third parties, including:

• YouTube videos;

• Google Maps;

• social media integrations; and

• Other embedded media.

When you interact with such embedded content, the relevant third-party provider may collect information directly from your browser in accordance with its own privacy practices. We encourage users to review the privacy policies of those providers before interacting with embedded services.

G. Information We Do Not Intentionally Collect

The Firm does not intentionally collect:

• personal information from children under the age prescribed by applicable law without appropriate legal authority;

• sensitive personal information unless it is voluntarily provided and reasonably necessary for the provision of legal services; or

• personal information that is irrelevant to the purposes described in this Privacy Policy.

Where sensitive personal information is provided in connection with a legal matter, it will be processed only where authorised by law or with an appropriate legal basis.

6. How We Use Your Personal Information (Purposes of Processing)

We process personal information only for lawful, legitimate, and specific purposes consistent with applicable data protection laws and our professional obligations as a legal practice.

Depending on how you interact with our Website or the Firm, we may use your personal information for one or more of the following purposes:

A. Responding to Enquiries

To respond to enquiries submitted through our contact forms, email communications, telephone calls, or other communication channels.

B. Scheduling Consultations

To arrange, confirm, administer, and manage consultation appointments, including appointments booked through authorised third-party booking platforms used by the Firm.

C. Providing Legal Services

To evaluate legal enquiries, conduct preliminary assessments where appropriate, establish client relationships, provide legal advice, prepare legal documents, represent clients, and otherwise perform legal services requested by clients.

D. Conflict Checks and Client Acceptance

To conduct conflict-of-interest assessments, client identification procedures, and other professional checks required before accepting legal instructions.

E. Communicating with Clients and Prospective Clients

To communicate regarding legal matters, consultations, appointments, requests for information, updates relating to legal services, administrative matters, and other communications reasonably connected with our professional relationship.

F. Publishing and Administering Legal Insights

To publish, manage, and administer legal articles, publications, educational materials, professional commentary, videos, newsletters, and other informational resources available through the Website.

Where users voluntarily subscribe to future publications or updates, we may use their contact information to deliver those communications in accordance with applicable law.

G. Improving the Website

To understand how visitors use our Website, improve user experience, enhance accessibility, monitor performance, identify technical issues, and develop new features and content.

Where analytics technologies are used, information is generally processed in aggregated or pseudonymised form.

H. Maintaining Website Security

To protect the Website, its users, and the Firm against unauthorised access, malicious activity, fraud, cyber threats, abuse of our systems, denial-of-service attacks, and other security incidents.

I. Complying with Legal and Regulatory Obligations

To comply with obligations arising under applicable laws and regulations, including obligations relating to legal practice management, taxation, anti-money laundering requirements where applicable, court orders, regulatory investigations, professional conduct rules, record-keeping requirements, and other lawful governmental requests.

J. Exercising and Protecting Legal Rights

Where necessary, we may process personal information to establish, exercise, defend, or enforce the legal rights and interests of the Firm, our clients, or other persons.

K. Internal Administration

To administer the Firm's business operations, maintain records, improve operational efficiency, manage information systems, perform internal audits, and support lawful business activities.

L. Preventing Fraud and Abuse

To detect, investigate, prevent, and respond to fraudulent activities, misleading enquiries, misuse of our Website, attempted cyber intrusions, and other unlawful conduct.

M. Cross-Border Legal Services

As the Firm advises clients involved in international transactions and cross-border legal matters, personal information may be processed where reasonably necessary to provide legal services involving multiple jurisdictions, subject to appropriate safeguards and applicable legal requirements.

We will not use your personal information for purposes that are incompatible with those described in this Privacy Policy unless required or authorised by law, or with your consent where consent is required.

7. Legal Basis for Processing Personal Information

The Firm processes personal information only where there is a lawful basis for doing so under applicable data protection laws, including the Nigeria Data Protection Act, 2023 (NDPA) and, where applicable, the General Data Protection Regulation (GDPR).

Depending on the nature of the interaction and the services requested, the Firm may rely on one or more of the following legal bases.

A. Consent

We process personal information where you have freely provided your consent for a specific purpose.

Examples include:

• submitting enquiries through our Website;

• requesting information from the Firm;

• subscribing to newsletters, publications, or legal updates (where available);

• Consenting to the use of non-essential cookies where applicable.

Where processing is based on consent, you may withdraw your consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

B. Performance of a Contract

We process personal information where it is necessary to take steps prior to entering into a contract or to perform our contractual obligations.

This includes processing necessary for:

• arranging consultations;

• evaluating legal instructions;

• providing legal advice;

• preparing legal documents;

• delivering legal services;

• administering client engagements;

• Managing billing and related administrative matters.

C. Compliance with Legal Obligations

The Firm may process personal information where processing is necessary to comply with applicable legal, regulatory, judicial, or professional obligations.

This may include compliance with:

• applicable legislation;

• regulatory requirements;

• lawful requests from competent authorities;

• court orders;

• record-keeping obligations;

• Professional conduct rules governing legal practitioners.

D. Legitimate Interests

The Firm may process personal information where such processing is reasonably necessary for our legitimate interests or the legitimate interests of our clients, provided that those interests do not override the rights and freedoms of the relevant data subject.

Legitimate interests may include:

• protecting the security of our Website;

• preventing fraud, abuse, and cyber threats;

• maintaining and improving our digital services;

• administering the Firm's operations;

• protecting our legal rights;

• responding to legal claims;

• improving client experience;

• publishing professional legal content and educational resources;

• maintaining the integrity of our information systems.

E. Legal Claims and Professional Obligations

Where necessary, the Firm may process personal information for the establishment, exercise, or defence of legal claims, the protection of legal rights, or the discharge of professional responsibilities arising from the provision of legal services.

Such processing may occur before, during, or after the conclusion of a legal engagement.

F. Special Categories of Personal Information

In the course of providing legal services, the Firm may receive personal information that is regarded as sensitive or subject to additional legal protection.

Such information will only be processed where:

• authorised or required by applicable law;

• necessary for the establishment, exercise, or defence of legal claims;

• necessary for the provision of legal services requested by the client;

• processed with the appropriate legal basis under applicable data protection legislation.

The Firm will implement appropriate safeguards to protect such information against unauthorised access, disclosure, alteration, or misuse.

The Firm will not process personal information in a manner that is incompatible with the purposes for which it was collected unless such processing is authorised by law or supported by an appropriate legal basis.

8. Confidentiality and Solicitor–Client Relationship

The Firm recognises the importance of confidentiality and takes appropriate steps to protect information submitted through this Website. Personal information received through our contact forms, consultation requests, email communications, and other authorised communication channels is handled with appropriate care and in accordance with our professional and legal obligations.

However, users should note that visiting this Website, reading articles, watching videos, downloading publications, submitting enquiries, or communicating with the Firm through this Website does not, by itself, create a solicitor–client relationship between the user and E.V. Atenaga & Associates LLP.

A solicitor–client relationship is established only after:

• the Firm has completed any necessary conflict-of-interest assessments;

• the Firm has agreed to accept instructions;

• any required engagement procedures have been completed; and

• where applicable, an engagement letter or other appropriate retainer arrangement has been executed.

Until such time, information submitted through the Website should not be regarded as protected by legal professional privilege solely by reason of its submission through the Website.

Users are encouraged not to transmit highly confidential, privileged, commercially sensitive, or legally protected information through the Website unless specifically requested by the Firm or through secure communication channels authorised by the Firm.

Where a solicitor–client relationship has been established, the Firm will handle client information in accordance with applicable laws, professional rules governing legal practitioners, and the terms of the relevant engagement.

The legal articles, educational videos, professional commentary, publications, and other materials made available through the Website are provided for general informational and educational purposes only. They do not constitute legal advice, should not be relied upon as a substitute for obtaining legal advice tailored to specific circumstances, and should not be interpreted as creating any solicitor–client relationship.

Individuals and organisations requiring legal advice should contact the Firm to obtain advice based on the specific facts and circumstances of their matter.

9. Disclosure of Personal Information and Third-Party Service Providers

The Firm does not sell, rent, trade, or otherwise disclose personal information to third parties for marketing purposes.

However, in the course of operating our Website and providing legal services, we may disclose or make personal information available to carefully selected third-party service providers where such disclosure is reasonably necessary to support our operations, comply with legal obligations, or provide requested services.

Where appropriate, we take reasonable steps to ensure that third-party service providers process personal information in a secure manner and in accordance with applicable data protection requirements.

Personal information may be disclosed in the following circumstances:

A. Website Hosting and Technology Infrastructure

Our Website is hosted and supported through third-party technology providers responsible for website hosting, security, performance, content delivery, and related technical services.

These providers may process limited technical information necessary to maintain the availability, security, and functionality of the Website.

B. Consultation and Appointment Platforms

Where users schedule consultations through appointment booking or payment platforms authorised by the Firm, personal information necessary to facilitate those services may be processed by the relevant service providers.

Such processing is governed by the privacy practices of those providers in addition to this Privacy Policy.

C. Payment Processing

Where payments for consultations or legal services are made through authorised third-party payment providers, payment information is processed directly by those providers.

The Firm does not store complete payment card information on its Website.

Users are encouraged to review the privacy policies and terms of any payment service provider used in connection with transactions conducted through or linked from our Website.

D. Communication and Email Services

We may use third-party communication and email service providers to facilitate correspondence, appointment confirmations, client communications, and administrative notifications.

Such providers process only the information reasonably necessary to deliver those communications.

E. Analytics and Website Performance

Where implemented, analytics providers may process technical information regarding Website usage to assist us in understanding visitor interactions, improving performance, enhancing accessibility, and maintaining the security of our digital services.

Analytics information is generally processed in aggregated or pseudonymised form and is not intended to identify individual users.

F. Embedded Third-Party Services

Our Website may incorporate third-party services such as:

• embedded videos;

• interactive maps;

• social media integrations; and

• other embedded digital content.

When users interact with such services, the relevant third-party provider may collect information directly from their browser or device in accordance with its own privacy practices.

The Firm does not control the data processing activities of such independent third-party providers.

G. Legal and Regulatory Requirements

The Firm may disclose personal information where disclosure is:

• required by law;

• required by a court of competent jurisdiction;

• required by a lawful request from a regulatory authority;

• necessary to comply with applicable legal or professional obligations;

• necessary to establish, exercise, or defend legal claims; or

• necessary to protect the rights, property, safety, or legitimate interests of the Firm, its clients, or other persons.

H. Business and Professional Advisers

Where reasonably necessary, personal information may be disclosed to professional advisers engaged by the Firm, including external legal advisers, auditors, insurers, information technology consultants, cybersecurity specialists, or other advisers who require access for legitimate professional purposes.

Such disclosures will be limited to what is reasonably necessary and subject to appropriate obligations of confidentiality.

The Firm will not disclose personal information beyond the circumstances described in this Privacy Policy unless required or authorised by law or with the consent of the relevant individual where such consent is required.

10. International Data Transfers

As a modern law firm serving clients and Website users within and outside Nigeria, the Firm may process or transfer personal information across national borders where reasonably necessary to provide legal services, operate the Website, or engage trusted technology service providers.

Such transfers may occur where:

• a client is located outside Nigeria;

• legal services involve cross-border transactions or international matters;

• cloud-based technology infrastructure is used to support the Firm's operations;

• third-party service providers process information on our behalf; or

• international communications are necessary in connection with legal services or client enquiries.

Where personal information is transferred outside Nigeria, the Firm will take reasonable steps to ensure that appropriate safeguards are implemented in accordance with applicable law, including the Nigeria Data Protection Act, 2023 (NDPA) and, where applicable, relevant international data protection standards.

Such safeguards may include:

• contractual protections with service providers;

• transfers to jurisdictions recognised as providing an adequate level of data protection where applicable;

• implementation of appropriate technical and organisational security measures;

• confidentiality obligations imposed upon third-party processors; and

• other lawful safeguards recognised under applicable data protection legislation.

Where the Firm processes personal information relating to individuals located within jurisdictions that provide additional statutory privacy protections, including the European Economic Area or the United Kingdom, we will take reasonable measures to process and transfer such information consistently with applicable legal requirements.

The Firm seeks to ensure that international transfers of personal information are carried out responsibly, securely, and only where reasonably necessary for the purposes described in this Privacy Policy.

11. Data Retention

The Firm retains personal information only for as long as is reasonably necessary to fulfil the purposes for which it was collected, including the provision of legal services, compliance with applicable legal and regulatory obligations, resolution of disputes, enforcement of legal rights, and maintenance of appropriate business records.

The period for which personal information is retained depends on the nature of the information, the purpose for which it was collected, and any applicable legal or professional obligations.

Accordingly:

• General enquiries submitted through the Website may be retained for a reasonable period to enable the Firm to respond, maintain correspondence, and manage future communications where appropriate.

• Consultation requests and appointment information may be retained for administrative purposes, record management, and compliance with professional obligations.

• Client files and legal records may be retained for longer periods where required by applicable law, professional rules governing legal practitioners, contractual obligations, regulatory requirements, or the legitimate interests of the Firm in protecting legal rights and maintaining professional records.

• Technical information, cookies, and analytics data may be retained for periods reasonably necessary to maintain Website security, monitor performance, analyse usage trends, and improve the functionality of our digital services, subject to applicable legal requirements.

Where personal information is no longer required for the purposes for which it was collected, and the Firm is not otherwise required or permitted by law to retain it, we will take reasonable steps to securely delete, anonymise, or otherwise dispose of such information in accordance with our internal record management practices and applicable legal requirements.

In certain circumstances, the Firm may retain personal information for longer periods where retention is necessary to:

• comply with applicable legal or regulatory obligations;

• establish, exercise, or defend legal claims;

• protect the rights, property, or legitimate interests of the Firm or its clients;

• comply with court orders or lawful governmental requests; or

• satisfy professional record-keeping obligations applicable to legal practitioners.

The Firm periodically reviews retained personal information to ensure that it is not kept longer than is reasonably necessary, having regard to the purposes for which it was collected and the applicable legal framework.

12. Your Privacy Rights

The Firm respects the privacy rights of individuals whose personal information we process. Subject to applicable law and any lawful limitations, you may exercise certain rights in relation to your personal information.

Where applicable under the Nigeria Data Protection Act, 2023 (NDPA) and, where relevant, the General Data Protection Regulation (GDPR) or other applicable privacy legislation, you may have the following rights:

A. Right to be Informed

You have the right to receive clear and transparent information regarding how the Firm collects, uses, stores, shares, and otherwise processes your personal information.

B. Right of Access

You may request confirmation as to whether the Firm processes your personal information and, where applicable, request access to the personal information we hold about you, together with certain information regarding how it is processed.

C. Right to Rectification

Where your personal information is inaccurate, incomplete, or outdated, you may request that the Firm correct or update such information.

D. Right to Erasure

Subject to applicable legal and professional obligations, you may request that the Firm delete or erase your personal information where there is no lawful basis requiring its continued retention.

This right is not absolute and may be limited where the Firm is legally required or professionally entitled to retain certain information.

E. Right to Restrict Processing

In certain circumstances, you may request that the Firm temporarily restrict the processing of your personal information while a request for correction, objection, or verification is being considered.

F. Right to Object

Where permitted by applicable law, you may object to certain processing activities carried out by the Firm, particularly where processing is based on legitimate interests.

The Firm will carefully consider such objections and determine whether overriding lawful grounds require continued processing.

G. Right to Data Portability

Where processing is based on consent or contractual necessity and carried out by automated means, you may request that personal information provided to the Firm be made available in a structured, commonly used, and machine-readable format, where applicable.

H. Right to Withdraw Consent

Where processing is based upon your consent, you may withdraw that consent at any time.

Withdrawal of consent will not affect the lawfulness of processing carried out before the withdrawal.

I. Right to Lodge a Complaint

If you believe that the Firm has processed your personal information in a manner inconsistent with applicable data protection laws, you may contact the Firm in the first instance so that we may seek to resolve your concerns.

Where applicable, you may also have the right to lodge a complaint with the Nigeria Data Protection Commission (NDPC) or any other competent supervisory authority having jurisdiction over your complaint.

Exercising Your Rights

Requests relating to your personal information should be submitted using the contact details provided in this Privacy Policy.

To protect the privacy and security of individuals, the Firm may request reasonable information to verify the identity of the person making the request before responding.

The Firm will consider and respond to requests within the timeframes required by applicable law, subject to any lawful exemptions, professional obligations, or other legal limitations.

13. Security of Personal Information

The Firm is committed to protecting the confidentiality, integrity, and availability of the personal information entrusted to us.

We maintain appropriate administrative, technical, organisational, and physical safeguards designed to protect personal information against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, misuse, or access.

These safeguards may include, where appropriate:

• secure website hosting and infrastructure;

• encrypted communication technologies where available;

• access controls and authentication measures;

• regular monitoring of our digital systems;

• information security practices designed to reduce cybersecurity risks;

• confidentiality obligations applicable to our personnel and authorised service providers; and

• reasonable organisational measures to ensure that personal information is processed only by authorised individuals for legitimate purposes.

While the Firm takes reasonable steps to safeguard personal information, no method of electronic transmission over the Internet or electronic storage can be guaranteed to be completely secure.

Accordingly, although we strive to implement appropriate security measures consistent with recognised industry standards and applicable legal requirements, we cannot guarantee the absolute security of information transmitted to or from the Website.

Users are encouraged to take appropriate precautions when communicating electronically with the Firm, including avoiding the transmission of highly confidential, privileged, financial, or otherwise sensitive information through unsecured communication channels unless specifically requested by the Firm or transmitted using an authorised secure method.

In the event of a personal data breach requiring notification under applicable law, the Firm will take appropriate steps to investigate the incident, mitigate potential risks, and comply with any applicable legal or regulatory notification obligations.

14. Children's Privacy

This Website is intended for individuals who are at least the age of majority under applicable law and is not directed to children.

The Firm does not knowingly collect personal information from children without appropriate legal authority or the consent of a parent or legal guardian where required by law. If we become aware that personal information relating to a child has been collected inadvertently, we will take reasonable steps to delete or otherwise manage such information in accordance with applicable legal requirements.

If you believe that a child has provided personal information through this Website without appropriate authorisation, please contact the Firm promptly.

15. Changes to this Privacy Policy

The Firm reserves the right to amend or update this Privacy Policy at any time to reflect changes in applicable laws, regulatory requirements, professional obligations, technological developments, or our business operations.

Where material changes are made, the updated Privacy Policy will be published on this Website together with a revised Effective Date.

Your continued use of the Website following the publication of any revised Privacy Policy constitutes your acknowledgement of the updated Policy.

16. Contact Us

If you have any questions regarding this Privacy Policy, wish to exercise your privacy rights, or would like further information regarding the Firm's processing of personal information, you may contact us using the details below:

E.V. Atenaga & Associates LLP

Email: info@evallp.com

Telephone: +234 708 562 8297

Office Address: E.V Atenaga & Associates LLP, Benin Sapele Rd, Ikpoba-Okha, Benin City 300105, Edo State Nigeria.

Where appropriate, privacy-related complaints may also be submitted to the Nigeria Data Protection Commission (NDPC) or any other competent supervisory authority having jurisdiction over the processing of your personal information.

17. Governing Law

This Privacy Policy shall be governed by and construed in accordance with the laws of the Federal Republic of Nigeria, including the Nigeria Data Protection Act, 2023, without prejudice to any mandatory rights available to individuals under applicable foreign data protection laws where such laws apply.