Privacy Policy

1. INTRODUCTION

Bono Energy Limited (“Bono Energy”, “we”, “us”, “our”, or “the Company”) is committed to protecting your privacy and safeguarding your personal information. This Privacy Policy explains how we collect, use, share, and protect your personal information when you visit or use our website and all other platform owned and operated by Bono Energy.

This Privacy Policy is fully compliant with the Nigeria Data Protection Act (NDPA) 2023 and the General Application and Implementation Directive (GAID) 2025 issued by the Nigeria Data Protection Commission (NDPC).

2. WHO WE ARE

We are Bono Energy. We are the Data Controller with respect to the personal information processed in accordance with this Privacy Policy (except where this policy explains otherwise).

Bono Energy is engaged in the business of trading crude oil and petroleum products.

Our contact and other details are set out at the end of this policy.

3. THE LEGAL BASES ON WHICH WE PROCESS INFORMATION

Under the NDPA 2023 (Section 25) , we process your personal information only when we have a lawful basis to do so. The lawful bases we rely upon are:

a. Consent

We make deliberate efforts to obtain your explicit consent to process your personal information. For example:

1. By asking you to agree to our use of cookies
2. When you send us a message by email
3. When you submit guest articles
4. When you browse our website
5. When you ask us to provide you with more information about our business, products, or services

You may withdraw your consent at any time (see Section 9 – Individual Rights).

b. Performance of a Contract

When you use our services or otherwise agree to our terms and conditions, a contract is formed between you and us. In order to carry out our obligations under that contract, we must process the information you give us. Some of this information may be personal information.

c. Legal Obligation

Sometimes we must process your information in order to comply with a statutory obligation under Nigerian law.

d. Legitimate Interest

Where permitted by law, we may process your information for our legitimate business interests, provided such interests do not override your fundamental rights and freedoms.

4. THE INFORMATION WE COLLECT

We collect your personal information only to the extent necessary to provide publication and other associated services to you. The categories of personal information we may collect include:

1. Identification information: Name.
2. Contact information: Email address, telephone number and contact address.
3. Professional information: References, professional background (if provided by you).
4. Technical information: IP address, browser type, device information (via cookies).
5. Other information: Any other information you voluntarily provide to us.

Sensitive Personal Data: We do not knowingly collect sensitive personal data (e.g., health data, biometric data, political opinions, religious beliefs) unless you voluntarily provide it and we have obtained your explicit consent in accordance with the NDPA 2023.

5. USE OF INFORMATION COLLECTED THROUGH AUTOMATED SYSTEMS (COOKIES)

A cookie is a small file that is placed on your computer’s hard drive. Its functions include storing your login and session status, recording your user preferences, and analyzing web traffic.

Our website uses cookies. Cookies are placed by:

1. Software that operates on our servers; and
2. Software operated by third parties whose services we use.

You can control cookies through your browser settings. By continuing to use our website without changing your cookie settings, you consent to our use of cookies as described in this policy.

6. WHO WE SHARE YOUR INFORMATION WITH

Towards enhancing our service delivery, we may share your personal information with:

1. Business Counterparties
2. Service providers;
3. Partners and associates; and
4. Subsidiaries within our group

Where applicable, we execute compliant Data Processing Agreements (DPAs) in accordance with Section 32 of the NDPA 2023 to provide an extra layer of protection for personal information shared in the process.

Disclosure Required by Law

We may disclose your personal information when required to do so by Nigerian law, including:

1. By a court order
2. By the Nigeria Data Protection Commission (NDPC)
3. By law enforcement authorities

Unless legally prohibited from doing so, we will notify you of such disclosure.

7. CROSS-BORDER TRANSFER OF PERSONAL INFORMATION

We will not transfer your personal information outside Nigeria unless we are satisfied that the transfer complies with the Nigeria Data Protection Act 2023 and the GAID 2025.

This means we will only transfer your data to a foreign country where that country has adequate data protection laws, or where we have put in place appropriate safeguards such as Standard Contractual Clauses, or where one of the limited exceptions applies (for example, where you have given your explicit consent after being informed of the risks, or where the transfer is necessary for the performance of a contract with you).

In all cases, we will ensure that your personal information remains protected in line with Nigerian data protection standards.

8. SECURITY OF YOUR PERSONAL INFORMATION

Bono Energy ensures that personal information processed is stored securely using appropriate technical and organizational measures in accordance with Section 43 of the NDPA 2023 and the GAID 2025.

However, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website, and any transmission is at your own risk. Once we have received your information, we will use appropriate procedures and security features to try to prevent unauthorized access.

9. YOUR INDIVIDUAL RIGHTS (DATA SUBJECT RIGHTS)

Under Part VI (Sections 34–38) of the NDPA 2023, you have the following rights over your personal information:

1. Right to be informed | You have the right to be informed of the processing of your information, typically through this Privacy Policy.
2. Right to access | | You have the right to obtain confirmation as to whether we process your personal information and to receive a copy of that information.
3. Right to rectification | You have the right to have your personal information corrected if it is inaccurate, out of date, incomplete, or misleading.
4. Right to erasure (right to be forgotten) | You have the right to request the deletion or removal of your personal information where there is no compelling legal or regulatory requirement for its continued processing.
5. Right to restriction of processing| You have the right to ‘block’ or restrict our processing of your information in certain circumstances.
6. Right to withdrawal of consent| You have the right to withdraw your consent to our processing of your information at any time (where processing is based on consent).
7. Right to object to processing | You have the right to object to our processing of your information in some circumstances, including for direct marketing purposes.
8. Right not to be subject to automated decision-making |You have the right not to be subject to a decision based solely on automated processing (including profiling) that produces legal or similar significant effects concerning you.
9. Right to data portability You have the right to receive your personal information in a structured, commonly used, and machine-readable format and to transmit it to another data controller.

How to Exercise Your Rights

To exercise any of these rights, please contact us using the details in Section 13 below. We will respond to your request without undue delay and within one (1) month of receipt, as required by the NDPA 2023.

Unsubscribing from Marketing Communications

To unsubscribe from any electronic newsletters or other marketing communications, you can click on the “unsubscribe” link in the relevant communication.

10. RETENTION PERIOD

We will retain your personal information only for as long as is necessary for the purposes for which it was collected, or as required by Nigerian law.

• As a general rule, we will not retain your personal information for longer than seven (7) years after our last interaction with you, unless a longer retention period is required or permitted by law (e.g., under the Companies Income Tax Act, Police Act, or other applicable legislation).

If you object to our processing, we will only retain your personal information if we are permitted or required to do so in terms of Applicable Laws.

At the end of the retention period, your personal information will be securely deleted or anonymized.

11. AVAILABLE REMEDIES (RIGHT TO LODGE A COMPLAINT)

If you have a complaint about any processing of your personal information being conducted by us, you can:

1. Contact Us First

   We encourage you to contact us directly to resolve any concern.

   Email: compliance@bono-energy.com

   Address: 19 Amodu Tijani Street, Victoria Island, Lagos State.

2. Lodge a Formal Complaint with the NDPC

   If you are not satisfied with our response, you have the right to lodge a formal complaint with the:

   Nigeria Data Protection Commission (NDPC)

   Website: www.ndpc.gov.ng

   Email: info@ndpc.gov.ng

12. COMPLIANCE WITH NIGERIAN LAW

This Privacy Policy has been compiled so as to comply with the Nigeria Data Protection Act (NDPA) 2023 and the GAID 2025.

We have not evaluated or accounted for the laws of any legal jurisdiction outside Nigeria. If you are accessing our website from outside Nigeria, you are responsible for ensuring compliance with your local laws.

13. CONTACT US

For inquiries regarding this Policy or to exercise your information or this Privacy Policy, please contact:

The Data Protection Officer
Bono Energy Limited
19 Amodu Tijani Street
Victoria Island, Lagos State
Phone number: +234 201 630 9566
Email address: compliance@bono-energy.com

14. REVIEW AND UPDATES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time as necessary to reflect changes in:

1. Our business practices;
2. Applicable laws (including the NDPA 2023 and GAID 2025);
3. Technology or industry standards.

The terms that apply to you are those posted here on our website on the day you use our website. We will notify you of material changes by posting a notice on our website or by contacting you directly where required by law.