Privacy Policy
Version 2.0 — Updated in alignment with NDPA 2023 & GAID 2025
1. Overview and Scope
GlobalWire NG Limited ("GlobalWire", "we", "us", or "our") is committed to safeguarding the privacy, integrity, and confidentiality of personal data. This Privacy Policy outlines our data processing practices in strict compliance with the Nigeria Data Protection Act (NDPA) 2023 and the General Application and Implementation Directive (GAID) 2025. This policy governs all public interactions on our informational platform (globalwireng.com) and applies to all data subjects whose information we handle as a Data Controller.
2. Lawful Bases for Processing Personal Data
In accordance with statutory mandates, GlobalWire ensures that every data processing operation relies on a legitimate and documented lawful basis:
- Consent: We obtain explicit and voluntary consent as the mandatory lawful ground for direct marketing communications and non-necessary online tracking or cookies.
- Performance of a Contract: This basis applies to data processing essential for managing staff, payroll systems, and vendor or supplier relationships.
- Legal Obligation: This basis is relied upon to fulfill mandatory statutory requirements and regulatory compliance reporting.
- Legitimate Interest: Used for core operations, website analytics, and security surveillance, provided these business interests do not override your fundamental rights, freedoms, or human dignity. We conduct mandatory formal Legitimate Interest Assessments (LIAs) to justify and document this balance.
3. Personal Data Inventory and Processing Framework
Adhering to the principles of "Privacy by Design and by Default," we process only the minimum necessary data for specified purposes. Our inventory of data assets is structured as follows:
| Processing Activity | Categories of Personal Data | Purpose of Processing | Primary Lawful Basis | Processor Involved | Retention | Storage & Security |
|---|---|---|---|---|---|---|
| Customer Acquisitions & Leads | Identification, Biographic, Financial | Regulatory reporting and lead management | Legitimate Interest / Contract | Yes | 5 Years | Cloud / Technical Measures |
| Employee Management & Payroll | Identification, Biographic, Employment | Payroll processing and due diligence | Contract and Legal Obligation | Yes | 5 Years | Cloud (App Level) / Admin & Tech |
| Vendor & Supplier Management | Financial, Identification, Biographic | Vendor assessment and payment of fees | Performance of a Contract | No | 5 Years | Cloud (App Level) / Administrative |
| Website & Online Analytics | Digital Identification (None active/0 users) | Platform traffic metrics & optimization | Explicit Consent / Legitimate Interest | N/A | 5 Years | Cloud / Technical Controls |
| CCTV Monitoring & Surveillance | Physical Imagery / Surveillance Markers | Premise security and physical protection | Legitimate Interest (Formal LIA applied) | No | Statutory Limit | Hybrid (App Level) / Physical |
4. Cookie Notice and Digital Transparency
To guarantee comprehensive front-facing transparency:
- Conspicuous Interface: Our website cookie banner is engineered to be highly conspicuous and obvious to visiting users, rather than being obscured exclusively at the bottom of the homepage.
- User Control: Visitors are provided with clear, explicit "Accept" and "Decline" choices for all cookies that are not strictly necessary for core platform features, preventing unauthorized behavioral profiling.
5. Cross-Border Data Transfers
GlobalWire operates as an International Money Transfer Operator facilitating cross-border data routing:
- Destination & Type: We transfer non-sensitive personal data collected within Nigeria to the United Kingdom.
- Legal Grounding: These transfers rely strictly on the adequacy decisions recognized by the Nigeria Data Protection Commission (NDPC) regarding the United Kingdom.
- Safeguards and Redress: These cross-border data flows are validated via active Data Privacy Impact Assessments (DPIAs) to ensure continuous protection, and data subjects maintain clear rights to seek legal redress within these respective jurisdictions.
6. Disclosure to Third Parties and Processors
We explicitly disclose the categories of third-party vendors (such as cloud hosting hosts, IT support providers, payment gateways, marketing partners, and KYC verification networks) that may handle personal data on our behalf:
- Data Processing Agreements (DPAs): For every engaged data processor, GlobalWire executes a standard written DPA reflecting all terms mandated by Article 34 of the GAID, explicitly laying out the scope, technical security parameters, and regional locations of data processing.
- Due Diligence: We perform strict regulatory vetting to verify that all relevant partners are duly registered with the NDPC.
7. Your Statutory Data Subject Rights
The NDPA guarantees you direct, enforceable control over your personal data. You can contact us at any time to exercise the following rights:
- Right to Rectification: Seamlessly correct or update inaccurate or fragmented personal records.
- Right to Data Portability: Request an export of your personal data in a structured, commonly used, and machine-readable layout.
- Right to Erasure ("Right to be Forgotten"): Demand the total deletion of your personal data when there is no overriding statutory retention obligation.
- Right to Withdraw Consent: Opt-out of direct marketing or behavioral profiling through a simple, friction-free mechanism that is as easy to execute as providing consent.
8. Grievance Redress and Regulatory Recourse
If you suspect your data privacy rights have been infringed or if you wish to file an inquiry regarding our data handling routines, you have access to clear remediation channels:
Internal Remediation (SNAG Process)
You may formally demand internal remediation through our internal grievance resolution pathway. To do so, you can submit a Standard Notice to Address Grievance (SNAG) request directly to our Data Protection Officer for accelerated evaluation and corrective action.
External Regulatory Recourse
You maintain an absolute, unalienable right to escalate complaints or lodge a formal report directly with the federal data protection authority:
Nigeria Data Protection Commission (NDPC)
Address: 12 Dr. Clement Isong Street, Asokoro, Street 900103, FCT, Abuja, Nigeria
Website: www.ndpc.gov.ng
9. Contact Our Data Protection Officer (DPO)
For questions regarding this policy, to exercise your data rights, or to file a formal SNAG request, please reach out to our certified Data Protection Officer:
- Designated DPO: Abdulrasaq Folorunsho
- Email Address: [email protected]
- Registered Address: GLOBALWIRE NG LIMITED, The Post Square, Adeola Odeku, Victoria Island, Lagos State, Nigeria
By using our Services, you confirm that you have read, understood, and agreed to this Privacy Policy.