1. Introduction

Panovest Capital Limited (“Panovest”, “we”, “our” or “us”) is committed to providing quality services to you in respect of how we manage your Personal Information.

We are committed to protecting personal data in accordance with the Nigeria Data Protection Act, 2023 (the “NDPA”). This Privacy Policy sets out the principles and procedures governing the collection, processing, storage, use, disclosure, and protection of personal data obtained through our website and other communication channels.

2. Scope of Application

This Policy applies to all personal data processed by Panovest in the course of its operations, including data collected via our website (https://panovest.com), electronic communications, and offline interactions. It applies to all data subjects whose personal data is in our custody or control, whether residing within or outside Nigeria.

3. Definitions

Unless otherwise stated, terms used in this Policy shall have the meanings ascribed to them under the NDPA. Personal Information is information that identifies an individual. Examples of Personal Information we collect include names, addresses, email addresses, and phone numbers.

This Personal Information is obtained in many ways, including correspondence, by telephone, by email, from media and publications, from other publicly available sources, from cookies, and from third parties. We don’t guarantee the website links or the policies of authorised third parties.

4. Categories of Personal Data

We may collect and process various categories of personal data during our operations. Such data may include identification information, such as an individual’s full name; contact details, including email address, telephone number, and residential address; employment-related information, such as curricula vitae, resumes, academic and professional qualifications, and records of prior professional experience; and technical data, including but not limited to Internet Protocol (IP) addresses, browser types, and device identifiers. In addition, we may process any other information voluntarily disclosed or otherwise provided by the data subject. All such data shall be collected and processed in accordance with applicable data protection laws and solely for purposes consistent with our business activities and requirements.

5. Principles of Data Processing

Panovest shall process personal data in accordance with the principles set out in the NDPA, namely: lawfulness, fairness, and transparency; purpose limitation; data minimization; accuracy; storage limitation; integrity and confidentiality; and accountability.

6. Purpose of Processing

Personal data may be processed for any of the following purposes: Responding to inquiries and providing requested services, Recruitment and human resource management, Compliance with legal and regulatory obligations, Business administration and internal record-keeping, Marketing and communication and any other reason which is commercially expedient or necessary by us.  The basis for data processing by us depends on the peculiarities of situations. This may include consent, legal obligations, vital interests, public interest/official authority, legitimate Interest, Vital Interest, Public Interest, and legitimate interests.

7. Lawful Basis for Processing

Our processing activities are conducted based on one or more lawful grounds as provided under the NDPA. These grounds include the consent of the data subject, the necessity of processing for the performance of a contract, compliance with legal obligations, the protection of vital interests, the performance of a task carried out in the public interest, and the pursuit of legitimate interests by Panovest or by a third party.

8. Amendments

Panovest reserves the right to amend this Privacy Policy at any time. Updated versions shall be published on our website and shall take effect upon publication.

9. Governing Law and Jurisdiction

This Privacy Policy shall be governed by and construed in accordance with the laws of the Federal Republic of Nigeria. Any disputes arising hereunder shall be subject to the exclusive jurisdiction of the Nigerian courts. 

10. Data Retention

We retain Personal Data for as long as necessary to fulfil the purposes for which it was collected, including to satisfy any legal, regulatory, tax, accounting, or reporting requirements. Where applicable, we may retain Personal Data for longer periods in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the data, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process the data, and whether those purposes can be achieved through other means, as well as applicable legal requirements.

Upon expiration of the applicable retention period, we will securely delete or anonymize your Personal Data, unless we are required by law to retain it for a longer period.

11. Data Sharing and Disclosure to Third Parties

We may disclose Personal Data to third parties where necessary for the purposes outlined in this Privacy Policy, including but not limited to service provision, legal compliance, and business operations. Such disclosures shall be made in accordance with applicable data protection laws and subject to appropriate safeguards.

Third-party recipients may include service providers and vendors who perform functions on our behalf, such as hosting, analytics, customer support, marketing, and payment processing. We may also share Personal Data with affiliates, subsidiaries, and business partners in connection with joint ventures, collaborations, or corporate transactions.

In certain circumstances, we may be required to disclose Personal Data to legal and regulatory authorities, law enforcement agencies, courts, or other governmental bodies where mandated by law, subpoena, or other legal process. Additionally, in the event of a merger, acquisition, reorganization, or sale of assets, Personal Data may be transferred to successors or assigns.

We do not sell, rent, or lease your Personal Data to third parties for their own marketing purposes without your explicit consent. Where we engage third parties to process Personal Data on our behalf, such parties are contractually obligated to maintain the confidentiality and security of the data and to process it only in accordance with our instructions and applicable law.

12. Complaints

Any complaints, inquiries, or communications relating to matters of data protection or privacy arising under or in connection with this Agreement shall be directed in writing to Panovest at the following designated email address: compliance@panovest.com. The Parties acknowledge and agree that such email address shall serve as the official channel for receipt of data privacy–related correspondence, and that Panovest shall not be deemed to have received any such complaint or inquiry unless and until it has been duly transmitted to the aforementioned address.

Last updated: January 2026