Legal

Privacy Policy

Effective Date: March 2026

1. Introduction

SWAD Holdings Ltd ("SWAD Holdings", "we", "us", or "our") is committed to protecting the privacy and personal data of individuals who interact with our Website. This Privacy Policy explains what personal information we collect, why we collect it, how we use and protect it, and your rights in relation to it.

This Policy applies to all personal data collected through the Website, including data submitted via contact/enquiry forms, job application forms, and newsletter or email sign-up forms. It should be read alongside our Terms of Use.

We operate globally and are mindful of applicable data protection frameworks, including Nigeria's Nigeria Data Protection Act 2023 (NDPA), the European Union's General Data Protection Regulation (GDPR) and UK GDPR, the UAE Personal Data Protection Law (Federal Decree-Law No. 45 of 2021), and equivalent laws in other jurisdictions where our visitors are located.

2. Data Controller

The data controller responsible for your personal information collected through the Website is:

SWAD Holdings Ltd
29/31 Awolowo Rd, Ikoyi, Eti Osa 101233
Lagos, Nigeria
privacy@swadonline.com

3. Information We Collect

We collect personal information only when you voluntarily provide it to us through one of the following Website features:

3.1 Contact / Enquiry Forms

When you submit a contact or enquiry form, we may collect:

• Full name
• Email address
• Phone number (if provided)
• Company or organisation name (if provided)
• The content of your message or enquiry

3.2 Job Application Forms

When you submit a job application through the Website, we may collect:

• Full name and contact details (email, phone, location)
• Curriculum vitae (CV) or resume
• Cover letter and supporting documents
• Employment history, educational background, and professional qualifications
• Any other information you voluntarily include in your application

3.3 Newsletter / Email Sign-Up

When you subscribe to our newsletter or mailing list, we collect:

• Email address
• Name (if provided)

3.4 Automatically Collected Information

When you visit the Website, our web server and analytics tools may automatically collect certain technical information, including:

• IP address and approximate geographic location
• Browser type and version
• Device type and operating system
• Pages visited, time spent on pages, and referring URLs
• Date and time of access

This information is collected using cookies and similar technologies. Please see Section 9 (Cookies) for further details.

4. Legal Bases for Processing

We process your personal data on the following legal bases, depending on the context:

• Consent — where you have given us explicit consent, such as when subscribing to our newsletter or submitting a job application.
• Legitimate Interests — where processing is necessary for our legitimate interests and your interests and rights do not override those interests, such as responding to general enquiries, improving Website functionality, and maintaining security.
• Compliance with Legal Obligations — where we are required to process data to comply with applicable law.

Where we rely on consent, you have the right to withdraw it at any time without affecting the lawfulness of processing prior to withdrawal.

5. How We Use Your Information

We use the personal information we collect for the following purposes:

• To respond to your enquiries or requests submitted via the contact form.
• To process and evaluate your job application and communicate with you regarding the recruitment process.
• To send you newsletters, updates, and communications relating to SWAD Holdings and the Group (where you have subscribed or consented).
• To maintain and improve the Website, including analysing usage patterns and diagnosing technical issues.
• To comply with legal and regulatory obligations.
• To protect the security and integrity of the Website and our systems.

We will not use your personal data for purposes incompatible with those listed above without obtaining your prior consent.

6. Data Sharing and Disclosure

6.1 Within the SWAD Holdings Group

SWAD Holdings Ltd may share your personal data with its wholly owned subsidiaries and related entities within the SWAD Holdings Group where necessary for the purposes described in this Policy, subject to equivalent data protection standards.

6.2 Service Providers

We may share your data with trusted third-party service providers who assist us in operating the Website and delivering our services, including email delivery platforms, cloud hosting providers, analytics providers, and recruitment management systems. All such providers are contractually required to process data only on our instructions and in accordance with applicable data protection law.

6.3 Legal Requirements

We may disclose personal data where required to do so by law, court order, or governmental or regulatory authority, or where we believe in good faith that such disclosure is necessary to protect the rights, property, or safety of SWAD Holdings, its personnel, or third parties.

6.4 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of assets, personal data held by SWAD Holdings may be transferred to the relevant successor entity, subject to appropriate confidentiality and data protection safeguards.

6.5 No Sale of Data

SWAD Holdings Ltd does not sell, rent, or trade personal data to third parties for their own marketing or commercial purposes.

7. International Data Transfers

SWAD Holdings Ltd operates across multiple jurisdictions, including Nigeria, the United Kingdom, the United Arab Emirates, and the United States. Your personal data may be transferred to and processed in countries outside your home country.

Where we transfer personal data across borders, we take appropriate steps to ensure that such transfers comply with applicable data protection laws and that your data receives an adequate level of protection, including through standard contractual clauses, adequacy decisions, or other lawful transfer mechanisms as required.

8. Data Retention

We retain personal data only for as long as is necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.

• Enquiry form data: Retained for up to 24 months from the date of receipt, unless an ongoing relationship is established.
• Job application data: Retained for up to 12 months following the conclusion of the relevant recruitment process, after which it will be securely deleted unless you have given consent to be retained in our talent pool.
• Newsletter subscriber data: Retained until you unsubscribe or request deletion.
• Website analytics data: Retained in aggregated or anonymised form; identifiable data retained for up to 26 months.

9. Cookies and Similar Technologies

The Website uses cookies and similar tracking technologies to enhance user experience, analyse traffic, and support the proper functioning of certain features. Cookies are small text files placed on your device when you visit a website.

We use the following categories of cookies:

• Strictly Necessary Cookies — essential for the Website to function and cannot be disabled.
• Analytics Cookies — help us understand how visitors interact with the Website (e.g., pages visited, session duration). These may be provided by third-party analytics tools.
• Preference Cookies — remember your settings and preferences to improve your experience.

You may control or disable cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the Website. Where required by law, we will request your consent before placing non-essential cookies.

10. Your Rights

Subject to applicable law, you may have the following rights in relation to your personal data:

• Right of Access — to request a copy of the personal data we hold about you.
• Right to Rectification — to request correction of inaccurate or incomplete data.
• Right to Erasure — to request deletion of your personal data in certain circumstances.
• Right to Restriction — to request that we limit the processing of your data in certain circumstances.
• Right to Data Portability — to receive your data in a structured, commonly used, machine-readable format.
• Right to Object — to object to processing based on legitimate interests or for direct marketing purposes.
• Right to Withdraw Consent — where processing is based on consent, to withdraw that consent at any time.
• Right to Lodge a Complaint — to lodge a complaint with the relevant supervisory authority in your jurisdiction (e.g., the Nigeria Data Protection Commission, the UK Information Commissioner's Office, or other applicable authority).

To exercise any of these rights, please contact us at privacy@swadonline.com. We will respond within the timeframe required by applicable law (generally within 30 days).

11. Children's Privacy

The Website is not directed at children under the age of 18. We do not knowingly collect personal data from minors. If we become aware that we have inadvertently collected personal data from a child under 18, we will take prompt steps to delete such data.

12. Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, destruction, or alteration. These measures are reviewed and updated regularly in line with best practices and applicable regulatory requirements.

While we take reasonable precautions, no method of data transmission over the internet or electronic storage is completely secure. We cannot guarantee absolute security, and you provide your information at your own risk.

13. Third-Party Websites

The Website may contain links to third-party websites. This Privacy Policy applies solely to data collected by the SWAD Holdings Website. We are not responsible for the privacy practices of third-party sites and encourage you to review their privacy policies before providing any personal information.

14. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. Any updates will be posted on this page with a revised effective date. We encourage you to review this Policy periodically. Where changes are material, we will take reasonable steps to notify you.

15. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:

SWAD Holdings Ltd
29/31 Awolowo Rd, Ikoyi, Eti Osa 101233
Lagos, Nigeria
privacy@swadonline.com