1. PURPOSE AND SCOPE
This Policy applies to all confidential information shared with, or generated by, any Group Company in the course of providing Services to a Client or Customer through the Website, including consultancy engagements, property transactions, legal instructions, and private advisory relationships.
2. OUR COMMITMENT TO CONFIDENTIALITY
We treat all Client and Customer information as strictly confidential, and shall not disclose such information to any third party except as expressly permitted under this Policy or required by law.
Confidential information includes, without limitation: personal identification data; financial records and statements; business strategies and plans; property and transaction details; legal instructions, case files, and correspondence; and any other information reasonably understood to be confidential in the context in which it was disclosed.
3. LEGAL PROFESSIONAL PRIVILEGE (WINELVAL & PARTNERS SOLICITORS)
Where a Client engages Winelval & Partners Solicitors, communications between the Client and the Solicitors made for the purpose of obtaining or giving legal advice are additionally protected by legal professional privilege under Nigerian law, which affords a higher standard of protection than general confidentiality and generally cannot be waived without the Client's consent, save in narrowly defined legal exceptions.
4. EXCEPTIONS TO CONFIDENTIALITY
We may disclose confidential information without further consent only where:
- disclosure is required by law, regulation, or a valid court order or subpoena;
- disclosure is required to comply with anti-money laundering and counter-terrorism financing obligations under the Money Laundering (Prevention and Prohibition) Act 2022, including mandatory suspicious transaction reporting to SCUML or the NFIU;
- disclosure is necessary to prevent an imminent risk of serious harm to any person;
- disclosure is made to our professional advisers, auditors, insurers, or regulators, on a strictly need-to-know and confidential basis;
- disclosure is made to a third-party service provider, such as IT hosting or payment processing, under a binding confidentiality and data processing agreement and strictly to the extent necessary to deliver the Service;
- the Client or Customer has given express written consent to the specific disclosure.
5. EMPLOYEE AND STAFF OBLIGATIONS
All employees, partners, contractors, and agents of Winelval Group are bound by confidentiality obligations as a condition of engagement, and receive periodic training on data and confidentiality protection. Access to Client and Customer information is restricted on a need-to-know basis, commensurate with each individual's role.
6. THIRD-PARTY SERVICE PROVIDERS
Where we engage third-party service providers who may have access to confidential information, such as cloud hosting providers, payment processors, and professional correspondents, we require such providers to be bound by written confidentiality and data protection obligations no less protective than those set out in this Policy.
7. SECURITY MEASURES
We maintain appropriate technical, physical, and organisational safeguards to protect confidential information from unauthorised access, disclosure, alteration, or destruction, as further described in our Privacy Policy and Data Protection Policy.
8. DURATION OF CONFIDENTIALITY OBLIGATION
Our confidentiality obligations continue beyond the termination or completion of any engagement with a Client or Customer, and shall survive indefinitely in respect of trade secrets and privileged legal information, and for a minimum of six (6) years in respect of other confidential information, or such longer period as required by professional conduct rules or Applicable Law.
9. REPORTING A CONCERN OR BREACH
If you believe your confidential information has been disclosed or accessed without authorisation, please contact us immediately at [support email] or [phone number]. We shall investigate promptly and, where applicable, notify you and the Nigeria Data Protection Commission in accordance with our data breach notification obligations.
10. CONTACT US
For questions regarding this Policy, please contact us at support@winelvalgroup or +234 8147093769.