Privacy Policy

Last Updated: [20th October, 2025]

1. Introduction
Glimsource (“the Firm”, “we”, “us”, or “our”) is committed to protecting your privacy and ensuring the lawful processing of your personal data in accordance with the Nigeria Data Protection Act (NDPA) 2023, the Nigeria
Data Protection Commission (NDPC) General Application and Implementation Directive (GAID) 2025, and other applicable data protection regulations.

This Privacy Policy outlines how we collect, use, disclose, and safeguard personal data obtained through our website, digital platforms, and professional services (“Services”).

By accessing our website or using our Services, you acknowledge that you have read and understood this Privacy Policy and agree to the terms contained herein. If you do not agree, please discontinue the use of our website and services.

We may update this Privacy Policy periodically to reflect regulatory changes or operational adjustments. The “Last Updated” date above will indicate the latest revision. Significant changes will be communicated via our website or direct notice before they take effect.

2. Definitions

  • Personal Data: Any information relating to an identified or identifiable natural person.
  • Processing: Any operation performed on personal data, including collection, storage, use, disclosure, or deletion.
  • Data Controller: Any individual or entity that determines the purposes and means of processing personal data.
  • Data Subject: The individual to whom the personal data relates.
  • Cookies: Small text files stored on your device that assist in improving website functionality and user experience.
  • NDPC: The Nigeria Data Protection Commission, the national authority for data protection compliance and enforcement.
  • GAID: The General Application and Implementation Directive issued under the NDPA 2023.

3. Who We Are
Glimsource is a legal and business advisory firm providing corporate, commercial, and compliance-related services across multiple sectors. We act as the Data Controller for the personal data we collect and process in connection with our Services.

If you have any inquiries regarding this Privacy Policy or wish to exercise your data privacy rights, you may contact our Data Protection Officer (DPO) using the details below: Email: dpo@glimsource.com.

4. What Personal Data We Collect
We collect and process personal data necessary for the delivery of our Services or when you interact with us.
This may include:

  • Identity Data: Full name, date of birth, gender, and identification details.
  • Contact Data: Email address, postal address, and other contact information.
  • Technical Data: IP address, browser type, operating system, device identifiers, and access logs.
  • Usage Data: Information on website usage, interactions, and preferences.
  • Professional or Employment Data: Job title, employer, and qualifications (where applicable).
  • Marketing and Communications Data: Your preferences in receiving marketing materials and related communications.
  • Compliance data: KYC/AML information, verification documents, and regulatory filings.
    We may also collect non-identifiable or aggregated data for statistical analysis and service enhancement.

5. How We Collect Your Data
Your personal data may be obtained through the following:
Direct interactions (e.g., inquiries, subscriptions, or service engagements).
Website interactions using cookies and analytics tools.
Participation in events, surveys, or marketing campaigns.
Job applications and professional correspondence.

6. Lawful Basis for Processing
We process personal data under one or more of the following lawful bases:

  • Consent: When you voluntarily provide data or opt-in to marketing communications.
  • Contractual Necessity: To perform obligations under a contract or pre-contractual arrangements.
  • Legal Obligation: To comply with statutory or regulatory requirements.
  • Legitimate Interest: For business operations, service enhancement, or security purposes, provided your rights are not overridden.
  • Vital Interest: Where necessary to protect life or physical safety.
  • Public Interest: Where required for official or public functions.

7. How We Use Your Personal Data
We use your personal data to:
Deliver and improve our Services.
Respond to inquiries, requests, or complaints.
Manage client relationships and billing processes.
Conduct due diligence, conflict checks, and compliance assessments.
Send legal updates, newsletters, or event invitations (where permitted).
Monitor website usage and enhance user experience.
Comply with applicable laws, regulations, and professional standards.

We will not use your personal data for purposes incompatible with those stated unless required by law or with your prior consent.

8. Data Sharing and Disclosure
We may share your personal data with:

  • Service Providers: Trusted third parties providing IT, analytics, hosting, or administrative support under confidentiality agreements.
  • Professional Advisors: Auditors, insurers, or consultants under strict legal and ethical duties.
    Regulatory or Governmental
  • Authorities: Where disclosure is required by law, court order, or regulatory mandate.

All third parties are required to handle your personal data in compliance with the NDPA and process it only for authorised purposes.

9. Data Security
We employ industry-standard technical and organizational measures to protect your data against unauthorized access, alteration, loss, or misuse.
These include encryption, access control, secure storage, and regular system reviews.

Although we take appropriate steps to secure your information, no electronic transmission is entirely risk-free. You acknowledge this inherent limitation when using our website or digital platforms.

10. Data Retention
We retain personal data only for as long as necessary to fulfill the purposes for which it was collected, including compliance with legal, accounting, or reporting obligations. Upon expiration of the retention period, we securely delete or anonymize the data in accordance with NDPA and best practice standards.

11. Your Data Privacy Rights
Under the NDPA and GAID, you have the following rights:

  • Access: Request a copy of your personal data.
  • Rectification: Request correction of inaccurate or incomplete data.
  • Erasure: Request deletion of your personal data under lawful circumstances.
  • Restriction: Request suspension of data processing in specific scenarios.
  • Objection: Object to data processing, particularly for direct marketing.
  • Portability: Request transfer of your data to you or a third party.
  • Withdraw Consent: Revoke consent at any time where processing is based on consent.

Lodge a Complaint: With the Nigeria Data Protection Commission (NDPC).
To exercise any of these rights, please contact our DPO via dpo@glimsource.com.

12. Data Transfer Outside Nigeria
Where it becomes necessary to transfer personal data outside Nigeria, Glimsource ensures such transfers comply with NDPC-approved adequacy standards, binding corporate rules, or standard contractual clauses to guarantee equivalent protection.

13. Automated Decision-Making and AI Use
Glimsource does not engage in automated decision-making that significantly affects individuals. Where artificial intelligence (AI) tools are used to enhance efficiency or service delivery, such use is governed by strict ethical, data protection, and professional oversight to ensure transparency, accountability, and human review of all outcomes.

14. Cookies
Our website uses cookies to improve functionality, enhance security, and analyse traffic. You can manage or disable cookies through your browser settings; however, certain website features may not function optimally if cookies are disabled. For more details, please refer to our Cookie Policy.

15. Data Breach Management
In the event of a data breach, Glimsource shall promptly investigate, mitigate, and notify the NDPC and affected data subjects, where required, in accordance with the NDPA and applicable regulations.

16. Links to Third-Party Websites
Our website may contain links to third-party websites. Glimsource is not responsible for the privacy practices, accuracy, or content of external sites.

We recommend that you review the privacy policies of any third-party website before providing personal data.

17. Governing Law
This Privacy Policy is governed by the laws of the Federal Republic of Nigeria, and any dispute arising from it shall be subject to the exclusive jurisdiction of Nigerian courts.

18. Contact Us
For questions, requests, or concerns regarding this Privacy Policy, please contact: Email: dpo@glimsource.com.

DISCLAIMER
The information contained on this website is provided by GLIMSOURCE for general informational and educational purposes only. Although every effort has been made to ensure that the content is accurate, comprehensive, and current, it does not, under any circumstances, constitute legal advice, opinion, or professional counsel.

Accessing or using this website, or communicating with GLIMSOURCE through it, does not create and is not intended to create an attorney–client or solicitor–client relationship. Users are strongly advised not to act, or refrain from acting, based on any information contained herein without obtaining specific legal advice from qualified counsel familiar with their particular facts and circumstances.

GLIMSOURCE expressly disclaims any liability for loss, damage, or inconvenience arising directly or indirectly from the use of, reliance upon, or interpretation of any material presented on this website or through any linked resources.
Links to third-party websites, if provided, are for convenience and reference purposes only. GLIMSOURCE neither endorses nor accepts responsibility for the content, accuracy, or security of any external website accessed through such links. By continuing to browse or use this website, you acknowledge and agree that the materials provided are for informational purposes only and that GLIMSOURCE shall not be held liable for any action taken or not taken based on the content herein. For legal guidance tailored to your specific situation, please contact a qualified professional at GLIMSOURCE.