Privacy Policy.

ClimeNergies is an advisory firm based in Lagos, Nigeria, working across Africa's energy, climate, critical minerals and industrial sectors. For the purposes of the NDPA, we are the data controller of the personal data described in this policy. This means we decide how and why that data is processed.

You can contact us about anything in this policy by email at info@climenergiesconsulting.com, by phone on +234 (0) 808 585 5527, or by post at the address in the Contact Us and Complaints section below.

This policy applies to personal data we collect when you:

• visit our website;
• contact us through our website, by email, by phone or through social media;
• subscribe to The ClimeNergies Digest;
• deal with us as a client, prospective client, partner, supplier or other business contact; or
• attend a meeting or event that we organise or take part in.

It does not cover personal data we process on behalf of a client as part of an advisory engagement. That processing is governed by our engagement terms with the client and by the client's own privacy notices. It also does not cover other websites we link to, such as LinkedIn.

Information you give us

• Contact form: your first name, surname, email address, company (if you provide it) and the content of your message. Your enquiry is sent to our team by email through our email provider, Resend.
• Newsletter sign-up: your email address.
• Business dealings: your name, job title, organisation, business contact details, our correspondence with you, and the information we need to set up and manage an engagement, such as billing details.
• Meetings and events: your name, organisation and role, and any other details you choose to share with us.

Information collected automatically

When you visit our website, our hosting provider, Vercel, automatically records technical information that your browser sends. This includes your IP address, browser and device type, the pages you request, the page that referred you, and the date and time of your visit. We use this information to deliver the website, keep it secure and diagnose problems.

We also collect anonymous statistics about how our website is used, as explained in the Analytics and Cookies section.

Information from other sources

We may receive information about you from people who introduce or refer you to us, from our clients and partners in the course of an engagement, and from publicly available professional sources such as company websites, official registers and professional networking sites.

Sensitive personal data

We do not ask for sensitive personal data through our website, such as information about your health, ethnic origin, religious or political beliefs, or biometric data. Please do not include it in messages you send us. If an engagement requires sensitive personal data, we will only process it where the NDPA allows, for example with your explicit consent.

We only use personal data where we have a lawful basis to do so under the NDPA. The main purposes, and the lawful basis for each, are:

• Responding to enquiries. To read and reply to messages you send through our contact form, by email or by phone, and to follow up on them. Lawful basis: our legitimate interest in responding to people who contact us, or taking steps at your request before entering into a contract.
• Sending The ClimeNergies Digest. To email you our monthly news roundup and related updates from ClimeNergies, if you have subscribed. Lawful basis: your consent, which you can withdraw at any time.
• Providing our services. To scope, deliver, invoice and manage advisory engagements, and to keep records of our work. Lawful basis: performance of a contract with you or your organisation, and our legitimate interest in managing our business relationships.
• Managing business relationships. To stay in touch with clients, prospective clients, partners and other business contacts, including sharing insights we believe are relevant to them. Lawful basis: our legitimate interest in developing our business. Where the law requires consent for marketing, we will ask for it.
• Operating, securing and improving our website. To deliver the website, protect it against spam, abuse and attacks, fix problems, and understand which content is most useful to visitors. Lawful basis: our legitimate interest in running a secure, reliable and useful website.
• Meeting legal and regulatory obligations. For example, keeping financial records, carrying out conflict and due diligence checks before taking on an engagement, and responding to lawful requests from authorities. Lawful basis: compliance with a legal obligation, and our legitimate interest in managing risk.
• Protecting our rights. To establish, exercise or defend legal claims. Lawful basis: our legitimate interest in protecting our business, or compliance with a legal obligation.

Where we rely on legitimate interests, we have balanced those interests against your rights and reasonable expectations. You can ask us for more information about this assessment.

We do not make decisions about you based solely on automated processing, including profiling, that have legal or similarly significant effects on you.

If you subscribe to The ClimeNergies Digest, we add your email address to our mailing list, which is kept by our email provider, Resend, and use it to send you each issue. Every email includes a link to unsubscribe, and you can also unsubscribe at any time by emailing us at info@climenergiesconsulting.com. After you unsubscribe, we keep your email address on a suppression list only to make sure we do not email you again.

We use Vercel Web Analytics to understand how visitors use our website, such as which pages are viewed most and how people find us. It does not use cookies. Each page view is recorded anonymously, together with the time of the visit, the page visited, the website that referred you, your approximate location (country, region and city), and your device type, operating system and browser.

To count unique visitors, Vercel Web Analytics creates a temporary identifier from your browser's request, which is automatically discarded after 24 hours. We only see aggregated statistics, and we cannot use them to identify you or to follow you across other websites.

Cookies are small text files that a website stores on your device. Our website does not set cookies for analytics, advertising or tracking, and we do not allow advertising networks to track you on our website. If we introduce cookies that are not strictly necessary, we will update this policy and ask for your consent before setting them, as the NDPA and the GAID require. Websites we link to, such as LinkedIn, set their own cookies under their own policies.

We do not sell your personal data. We share it only as described below, and only as far as necessary:

• Service providers who host our website and provide our analytics (Vercel), send email from our website and keep our mailing list (Resend), and provide our business email, IT and administrative support. They act only on our instructions and are bound by contracts that require them to keep your data secure and confidential.
• Professional advisers such as lawyers, auditors, accountants and insurers, where they need it to advise us.
• Partners and associates we work with on a particular engagement or event, where this is relevant to your enquiry or engagement and you would reasonably expect it.
• Authorities, regulators and courts, where the law requires us to, or where we need to establish, exercise or defend legal claims.
• A successor business, if we are involved in a merger, acquisition, restructuring or sale of all or part of our business, subject to confidentiality obligations.
• Anyone else with your consent or at your direction.

Some of our service providers store or process data outside Nigeria. Vercel (website hosting and analytics) and Resend (email delivery and our mailing list) are based in the United States and may process data there and in other countries. When we transfer personal data outside Nigeria, we make sure the transfer is permitted under the NDPA. This means the destination country provides an adequate level of protection, appropriate safeguards recognised under the NDPA are in place, or another lawful basis applies, such as your informed consent or the transfer being necessary to perform a contract with you.

You can contact us for more information about the safeguards we use.

We keep personal data only for as long as we need it for the purposes in this policy, including to meet legal, accounting and reporting requirements. In general:

• Enquiries are kept for as long as we need to respond and follow up, and then for a limited period in case you contact us again about the same matter.
• Newsletter subscriptions are kept until you unsubscribe, after which we keep only a suppression record of your email address.
• Client and engagement records are kept for the duration of the engagement and afterwards for as long as required by law, tax and accounting rules, our professional obligations and the limitation periods for legal claims.
• Website server logs are kept for a short period, unless we need them to investigate a security incident. Analytics identifiers are discarded after 24 hours, and we keep only aggregated statistics after that.

When we no longer need personal data, we securely delete or anonymise it.

We use appropriate technical and organisational measures to protect personal data against unauthorised access, loss, misuse and alteration. These include encrypted connections to our website, access controls that limit who can see personal data, and requiring our service providers to meet appropriate security standards.

No method of sending or storing data is completely secure, so we cannot guarantee absolute security. If a personal data breach is likely to put your rights and freedoms at risk, we will notify the Nigeria Data Protection Commission within 72 hours of becoming aware of it. If the breach is likely to pose a high risk to you, we will also tell you immediately, in clear language, along with the steps you can take to protect yourself.

Under the NDPA, you have the right to:

• be informed about how we process your personal data, which is the purpose of this policy;
• access your personal data and receive a copy of it;
• rectify personal data that is inaccurate, out of date or incomplete;
• erase your personal data where we no longer have a lawful reason to keep it;
• restrict how we process your personal data in certain circumstances, for example while we check its accuracy;
• object to processing based on our legitimate interests, and object at any time to direct marketing;
• withdraw your consent at any time where we rely on it, such as for The ClimeNergies Digest. This does not affect processing that took place before you withdrew it;
• data portability, meaning you can receive the personal data you gave us in a structured, commonly used and machine-readable format, and ask us to send it to another organisation where technically feasible;
• not be subject to decisions based solely on automated processing that have legal or similarly significant effects on you. We do not make such decisions; and
• complain to the Nigeria Data Protection Commission, as explained in the Contact Us and Complaints section.

To exercise any of these rights, email us at info@climenergiesconsulting.com with “Data Protection Request” in the subject line. We may need to verify your identity before acting on your request. We will not charge a fee unless your request is clearly unfounded or excessive, and we will respond within the time the law requires. Some rights have legal limits. If we cannot fully meet your request, we will explain why.

Our website and services are intended for businesses, governments and professionals. They are not directed at children, and we do not knowingly collect personal data from anyone under 18. If you believe a child has given us personal data, please contact us and we will delete it.

Our website links to other websites and platforms, such as LinkedIn. We are not responsible for the privacy practices of those websites, and we encourage you to read their privacy policies.

We may update this policy from time to time to reflect changes in our practices, our services or the law. We will post the updated version on this page and change the “Last updated” date at the top. If the changes are significant, we will take reasonable steps to let you know, such as by email if you subscribe to The ClimeNergies Digest.

If you have questions about this policy or how we handle your personal data, or if you want to make a complaint, please contact us first so we can try to resolve it:

Email

info@climenergiesconsulting.com

Phone

+234 (0) 808 585 5527

Address

2nd Floor, Alternative Bank building21, Admiralty WayLekki Phase 1, Lagos, Nigeria.

If you are not satisfied with our response, you have the right to lodge a complaint with the Nigeria Data Protection Commission (opens in a new tab). If you live outside Nigeria, you may also be able to complain to the data protection authority in your country.