privacy policy
effective date:
october 1, 2026
1. Introduction
1.1. Elin Group Limited (“the Group”, “the Company”, “We”, “Us”, or “Our”) is a diversified conglomerate operating through various subsidiaries in sectors including but not limited to mining, aviation, construction, and power. Our privacy policy is designed to give you a better understanding of how we use your Personal Data that you share with us through our website, business operations, contractual relations and/or recruitment processes; what safeguards we have in place, and how you can exercise your rights.
1.2. For purposes of this Privacy Policy, the term Personal Data shall mean any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person; It can be anything from a name, address, a photo, an email address, bank details, posts on social networking websites, medical information n, and other unique identifier such as but not limited to MAC address, IP address, IMEI number, IMSI number, SIM and others
1.3. This Privacy Policy explains that the Group may collect, use, share, safeguard and/or otherwise process information (including Personal Data) collected during any of the process/interaction highlighted in 1.1 above.
1.4. As from the effective date of this Privacy Policy, any existing Personal Data already held by us shall be deemed to have been legally collected and processed unless you, as the data subject, requests for the correction or deletion of any part of your information held.
2. Collection of Information
2.1. We may collect Personal Data directly from you in the course of your interactions (whether digitally, written or physically) with us, except for instances where the law permits us to collect your Personal Data from other sources.
2.2. We may also collect Personal Data directly from you through your subscriptions to any service provided by the firm.
2.3. We may also collect other Personal Data in the course of providing services to you.
2.4. Some of the Personal Data that may be collected from your interactions with us include your name, business contact details, job title or position and your expertise and interests.
2.5. If necessary, we may collect other Personal Data – for example, your financial information.
2.6. We collect Personal Data when we (or propose to) deal with, or provide or market our services to you as a client. In accordance with our legal obligations, we inform you of the following:
a. the fact that we are collecting your Personal Data from you;
b. the purpose for which we intend to collect your Personal Data including why we are collecting your Personal Data and how we plan to use it (see section 3 below);
c. the third parties to whom your personal data will be shared or transferred, including details of safeguards adopted (see sections 4 and 5 below);
d. a description of the technical and organizational security measures taken to ensure the integrity and confidentiality of the data (see section 5 below);
e. your rights as the subject of the Personal Data which we collect from you (see section 6 below);
f. the contacts of the data controller or data processor who will handle your Personal Data (see section 7 below);
g. whether the data is being collected pursuant to any law and whether such collection is voluntary or mandatory (see paragraph (k) below); and
h. the consequences where the data subject fails to provide all or any part of the requested data (see paragraph (n) below).
2.7. If you apply for a job with us we may collect certain Personal Data from you, such as your name and contact details and information about your working history. We may also collect your Personal Data from relevant records checks, from any recruitment consultant and from your previous employers, universities and others who may be able to provide information to us to assist us in our decision on whether or not to make you an offer of employment. As part of the job application process and in every other instance where we intend to collect your Personal Data from other sources besides you, we will, in so far as practicable, notify you of the fact that we intend to collect such Personal Data. In instances where you apply for any employment position with us, you agree that by so doing, you are validly consenting to our collection of your relevant Personal Data from other sources for purposes of evaluating your application.
2.8. Should we ever collect your Personal Data from sources other than you, in any other context besides where you have applied for employment with us, we will, in so far as it is practicable, notify you before we collect such Personal Data from such other sources.
2.9. We generally only collect Personal Data when it is provided voluntarily by you.
2.10. If the Personal Data is intended to be collected pursuant to any law or where the collection of such Personal Data is mandatorily required, we will notify you of this directly prior to collecting such data.
2.11. We use cookies on our website and as such, we also obtain Personal Data from your IP address, operating system and web browser that you use to access our website.
2.12. When you visit our website, our server will record your IP address together with the date, time and duration of your visit. An IP address is an assigned number, similar to a telephone number, which allows your computer to communicate over the Internet. It enables us to identify which organizations have visited this website. We use this information to compile statistical data on the use of our website to track how users navigate through our site to enable us to evaluate and improve our site.
2.13. Please note that the provision of your Personal Data to us may be necessary for enabling the use or functioning of certain features of our website or the provision of certain services through our website. To that extent, any such features or services may not be functional or available for use or capable of being used in the absence of the provision of your Personal Data.
3. Purpose of Collection and Use of Personal Data
We may use your Personal Data in a variety of ways once collected including, but not limited to:
a. providing and managing services and business operations;
b. recruitment and employment administration;
c. managing contractual relationships with clients, vendors, and partners;
d. responding to your emails or online requests for products, services or information;
e. providing you with service communications such as bill reminders, order confirmations, programme registrations and client service messages;
f. fulfilling and/or delivering our products and services;
g. delivering and processing surveys;
h. improving the Group’s operations, systems, and services;
i. personalizing and improving the usability of our website;
j. tailoring content, advertising and marketing to you; and
k. sharing your Personal Data with certain third parties so as to fulfil any express service requests which you make to us. We may also share such information with service providers that perform business functions for us.
4. Sharing your information
4.1. By providing your Personal Data to the Group, you acknowledge and consent that such information may be shared within the Group, including with its subsidiaries, affiliates, and related entities, where necessary for legitimate business, administrative, or operational purposes.
4.2. The Group may also disclose Personal Data to third-party service providers who perform services on its behalf, provided that such parties are required to maintain appropriate confidentiality and data protection safeguards.
Personal Data may further be disclosed where required or permitted by applicable law, regulation, or legal process, or where necessary for the establishment, exercise, or defence of legal claims.
4.3. Where the Group intends to transfer Personal Data outside the jurisdiction in which it was collected, such transfer will only occur in compliance with applicable data protection laws, and where required, the prior consent of the Data Subject will be obtained.
In addition to this, we will take reasonable steps to ensure that your Personal Data is treated securely and that the means of transfer provides adequate safeguards.
5. Information Security
5.1. We use up-to-date data storage and security systems to hold your Personal Data securely in electronic and physical form to protect your personal information from unauthorized access, improper use or disclosure, unauthorized modification or unlawful destruction or accidental loss. Our IT usage and security policy is supported by various security standards, processes and procedures.
5.2. We implement commercially reasonable security measures to help protect against unauthorized access to or unauthorized alteration, disclosure, or destruction of data. Unfortunately, no data transmission over the Internet can be guaranteed to be one hundred (100) percent secure. Accordingly, and despite our efforts, we cannot guarantee or warrant the security of any information you transmit to us, or to or from our online products or services.
5.3. All persons who have access to confidential information (including Personal Data) that we hold, including our partners, staff and third-party service providers are subject to confidentiality obligations. Our IT usage and security policy is supported by various security standards, processes and procedures.
To ensure the safety of personal and company data, the following security measures are in place:
- Restricted Access: Backup files stored on Google
- Drive can only be accessed by the assigned user.
- Secure Login: All users must use strong passwords to protect their accounts.
- Computer Protection: All company computers must have updated antivirus software and should be locked when not in use.
- Safe Data Storage: Files backed up to Google Drive are automatically encrypted, ensuring they are protected during transfer and storage.
- Controlled Sharing: Users should not share backup files with external persons unless approved by the IT team.
- Account Management: The IT team manages all accounts. When a staff member leaves the organization, their access will be disabled immediately.
- Regular Monitoring: The IT team will periodically check that backups are working properly and that data is secure.
6. Your rights
6.1. You have certain rights that you can exercise in relation to any of your Personal Data that we process. These are:
a. the right to be informed of the use to which your Personal Data is to be put;
b. the right to object to the processing of all or part of your Personal Data;
c. the right to access your Personal Data;
d. the right to the correction of any false or misleading parts of your Personal Data;
e. the right to the deletion any false or misleading parts of your Personal Data.
f. the right to data portability, which is the right to receive your Personal Data in a sructured, commonly used and machine-readable format and to transmit it from us to a
other data controller or data processor without hindrance;
g. the right not to be subjected to a decision based solely on automated processing which produces legal effects that concern or significantly affect you;
h. the right to the rectification of any inaccurate, outdated, incomplete or misleading portions or parts of your Personal Data; and
i. the right to the erasure or destruction of any portions or parts of your Personal Data that are irrelevant, excessive, unlawfully obtained or that we are no longer authorized to retain.
6.2. In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your Personal Data for a specific purpose, you have the right to withdraw your consent for that specific purpose at any time. Once we receive notification that you withdraw your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
6.3. If you would like to exercise any of these rights, please contact us in writing by emailing or by letter to: contact@elin-group.com
7. Contact information
7.1. If you would like more information concerning this privacy policy and how it affects you, please contact our data privacy officer at the email address contact@elin-group.com
7.2. Address: 23B, Ogidi Crescent Off Admiralty Road, Lekki Phase 1, Lagos State, Nigeria.
8. modification
This version is applicable as from October 1, 2026 .
We reserve the right to update or modify this Policy from time to time. Any updates will be published through appropriate communication channels, including the Group’s website where applicable.
9. Categories of Personal Data We Collect
9.1. The Group may collect and process different categories of Personal Data depending on the nature of its relationship with individuals, including employees, customers, contractors, business partners, and website users.
9.2. Such Personal Data may include, but is not limited to:
i. Identification data (such as name, date of birth, nationality, and government-issued identification numbers);
ii. Contact information (such as address, telephone number, and email address);
iii. Professional and employment information (such as job title, employer details, curriculum vitae, employment history, qualifications, and payroll records);
iv. Financial information (such as bank account details, payment records, and tax identification numbers); and
v. Technical and electronic information (such as IP addresses, device identifiers, browser type, and website usage data).
The specific Personal Data collected will depend on the purpose for which it is processed and the nature of the interaction between the individual and the Group.
10. Data Retention
10.1. The Group will retain Personal Data only for as long as is necessary to fulfil the purposes for which it was collected and processed, including for the purposes of complying with legal or regulatory obligations, resolving disputes, and enforcing contractual or legal rights.
10.2. Subject to applicable law, Data Subjects may request the deletion or erasure of their Personal Data where such data is no longer required for the purpose for which it was collected or where the Data Subject withdraws consent to its processing.