Privacy Policy

1. Introduction

Grand Towers Limited ("Grand Towers", "we", "our", or "us") is committed to protecting your privacy and safeguarding your personal information.

This Privacy Policy explains how we collect, use, disclose, retain and protect your information when you interact with our website, services, investment opportunities, communications, forms and digital platforms.

2. Information We Collect

2.1 Personal Information

• Full name
• Email address
• Phone number
• Residential or business address
• Identification documents
• Payment or financial information
• Employment, application or professional information submitted through our platforms

2.2 Method of Collection of Personal Information

We use different methods to collect data from and about you. Personal information may be collected through various means, including but not limited to:

• Online enquiry or contact forms
• Online applications
• Newsletter subscriptions
• Direct correspondence with our team
• Administrative, recruitment, investor or business engagement processes
• Any other method through which you voluntarily provide information to us

As you interact with our website, we may automatically collect technical data about your device, browsing actions and usage patterns through cookies and similar technologies.

2.3 Non-Personal and Technical Information

• Browser type
• Device information
• IP address
• Website usage analytics
• Cookies and tracking data

3. Use of Information and Lawful Basis

We collect and process personal data for legitimate and lawful purposes connected with our website, communications, business operations, investments, recruitment, compliance and stakeholder engagement.

Personal data may be processed on one or more lawful bases, including:

• Where you have provided consent
• Where processing is necessary to protect your vital interests or the vital interests of another person
• Where processing is necessary for the performance of a contract or to take steps prior to entering into a contract
• Where processing is necessary for compliance with a legal obligation
• Where processing is necessary for the legitimate interests pursued by Grand Towers Limited or a third party
• Where processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority
• Any other applicable lawful basis relevant to the use of our website, services or business operations

We may use personal information to respond to enquiries, process applications, manage communications, send updates, improve website performance, administer subscriptions, support business relationships and comply with applicable regulatory obligations.

4. Change of Purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another purpose that is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis permitting such processing. Where required or permitted by law, we may process your personal data without your knowledge or consent.

5. Cookies & Tracking Technologies

Our website may use cookies to enhance functionality, analyze usage patterns, and improve security.

You may disable cookies through browser settings, though certain website features may be affected.

6. Information Sharing

• Regulatory authorities when required by law
• Financial institutions for transaction processing
• Professional advisors
• Trusted operational service providers

7. Data Security

We have implemented appropriate technical and organisational measures to safeguard your personal data against accidental loss, unauthorised access, alteration, disclosure or misuse. Access to personal data is restricted to employees, agents, contractors and authorised third parties who require such information for legitimate business purposes and who are subject to confidentiality obligations.

8. Data Retention

We will retain your personal data only for as long as is reasonably necessary to fulfil the purposes for which it was collected, including compliance with applicable legal, regulatory, accounting or reporting obligations.

9. Data Subject Rights

Subject to applicable law, you may exercise the following rights in relation to your personal data:

• Request access to personal data
• Request correction of inaccurate or incomplete personal data
• Request deletion of personal data where applicable
• Withdraw consent where applicable
• Object to the processing of personal data
• Request restriction of the processing of personal data

10. International Data Transfers

You have the right to be informed where your personal data is intended to be transferred outside Nigeria or to an international organisation, including whether the Nigeria Data Protection Commission (NDPC) has issued an adequacy decision in respect of the receiving country. Where personal data is transferred internationally, we will implement appropriate safeguards to ensure that your personal data receives a level of protection consistent with the requirements of the Nigeria Data Protection Act, 2023 and other applicable laws.

11. Third-Party Links

Our website may contain links to third-party platforms. We are not responsible for their privacy practices.

12. Policy Updates

We may update this policy periodically. Updates will be posted here with a revised effective date.

It is important that the personal data we hold about you is accurate and up to date. Please keep us informed if your personal data changes during your relationship with us.