Introduction
Nina Jojer Limited (“we,” “our,” or “us”) is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website at https://ninajojer.com/.
Nina Jojer Limited is a premier Pan-African public policy, strategy, and business advisory firm headquartered in Abuja, Nigeria, serving clients across Sub-Saharan Africa. We leverage deep expertise in communications, public policy, corporate strategy, advocacy, and technology solutions to deliver transformative results for businesses and organizations operating across the continent.
We are firmly committed to safeguarding the privacy rights of our users (“Data Subjects”). This Privacy Policy outlines our practices regarding the processing of personal data collected through our website, ensuring compliance with Section 37 of the Constitution of the Federal Republic of Nigeria (CFRN) 1999 (as amended), the Nigeria Data Protection Act (NDP Act) 2023, and its subsequent General Application and Implementation Directive (GAID) 2025.
This Privacy Policy applies solely to our online infrastructure and operations via our website. It does not apply to third-party services, applications, or platforms that we do not own or control.
We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of this policy. If we make material changes, we will provide you with additional notice (such as by adding a statement to our homepage or sending you an email notification). We encourage you to review this Privacy Policy regularly to stay informed about our information practices and the choices available to you.
Our Guiding Principles on Data Processing
In processing your personal data, we adhere strictly to the principles set out under Section 24 of the NDP Act. Our obligations include ensuring that personal data is:
- Processed in a fair, lawful, and transparent manner;
- Collected for specified, explicit, and legitimate purposes, and not further processed in a way incompatible with these purposes;
- Adequate, relevant, and limited to the minimum necessary for the purposes for which it was collected;
- Retained for no longer than necessary to achieve the lawful bases for which it was collected;
- Accurate, complete, not misleading, and, where necessary, kept up to date; and
- Processed in a manner that ensures appropriate security, including protection against unauthorized or unlawful processing, access, loss, destruction, damage, or any form of data breach.
Scope of Data Processing
Depending on your interaction with our website and the choices you make, we may collect and process various types of personal data for different purposes and lawful bases, including:
| Purpose | Type of Data | Lawful Basis |
|---|---|---|
| Business Inquiries & Advisory Requests | Name, company, job title, email address, phone number, and any details shared via our contact/lead generation forms. | Contractual Necessity / Legitimate Interest: To evaluate, respond to, and fulfill requests for policy and strategic advisory services. |
| Talent Acquisition & Recruitment | Name, email address, CV/Resume, academic qualifications, employment history, and professional references. | Contractual Necessity: To evaluate prospective candidates for open employment opportunities within the firm. |
| Communications & Insights | Name, email address, and communication preferences. | Legitimate Interest: To distribute thought leadership articles, policy briefs, newsletters, and regulatory update alerts. |
| Website Optimization & Security | IP address, browser type, device information, and usage tracking logs via cookies. | Legitimate Interest: To monitor website security, prevent fraud, and optimize our digital presence and user experience. |
Rights of Data Subjects
We uphold your privacy rights under the NDP Act, which include but are not limited to:
- Right to be Informed
- Right to Access Information
- Right to Rectification
- Right to Object to Processing
- Right to Restriction of Processing
- Right to Data Portability
- Right to be Forgotten (Deletion)
- Right to Object to Automated Decision Making
You also have the right to lodge a complaint with the Nigeria Data Protection Commission (NDPC) as outlined in Part VI of the NDP Act.
Data Subject’s Standard Notice to Address Grievance (SNAG)
We encourage you to use the Standard Notice to Address Grievance (SNAG) if you believe your data privacy rights have been violated. The SNAG is a standardized template that allows you to formally request an internal resolution from us. You can submit a SNAG directly or through someone acting on your behalf. We will track these notices, and if unresolved, the NDPC may initiate an investigation.
To submit a SNAG, please fill out the form available in Schedule 9 of GAID on the NDPC’s website or send an email to [email protected]with ‘SNAG’ in the subject line, outlining the details of your grievance. You can also serve a SNAG via our physical address listed in the contact section below.
To exercise any of your rights as a data subject, please contact our administrative and compliance desk at [email protected].
Transfer of Data to Third Parties and Countries
To provide our advisory services and maintain our online platform effectively, we may engage third-party service providers in the following areas:
- Cloud hosting and data storage services;
- Website hosting, maintenance, and technical support;
- Event management, webinar hosting, and virtual meeting platforms;
- Other service providers engaged to support the delivery, administration, security, and improvement of our services.
In transferring your data to these third parties, or across borders within Sub-Saharan Africa and globally, we strictly comply with the cross-border transfer requirements of the NDP Act 2023, ensuring that appropriate safeguards and data sharing agreements are in place to protect your data.
Disclosure of Information
We disclose the categories of information described above as follows:
- Vendors & Consultants — We disclose information to trusted vendors, service providers, contractors, and consultants who assist us with web hosting, business intelligence, and talent acquisition operations.
- Regulatory Authorities — We may disclose information to public authorities or regulatory bodies for compliance purposes where required by applicable law, legal processes, or statutory obligations.
- Consent — We may disclose information when we have your explicit consent to do so.
Data Security, Integrity, and Retention
We employ industry-standard technical and organizational measures to safeguard your personal data from loss, misuse, and unauthorized access, disclosure, alteration, or destruction.
In the event of a significant data breach that impacts your rights and freedoms, Nina Jojer Limited will notify the Nigeria Data Protection Commission within 72 hours of discovery, as well as affected individuals without undue delay.
We retain your personal data only for as long as necessary to fulfill the operational purposes for which it was collected, to resolve disputes, or to comply with statutory retention requirements under Nigerian law.
Children
Our website and advisory services are strictly tailored to corporate entities, professionals, and adults. We do not knowingly target or collect personal data from children under the age of 18. If you have reason to believe that a minor has provided us with personal data, please contact us immediately, and we will take appropriate steps to purge the information from our systems.
Contact Information
For any questions, concerns, or inquiries regarding this Privacy Policy or our data processing practices, please contact us at:
Nina Jojer Limited
21 Lobito Crescent, Wuse, Abuja, Nigeria.
Email: [email protected]
Effective Date: June 11, 2026