1. Introduction

Frontline Advisory (“Frontline Advisory,” “we,” “us,” or “our”) respects your privacy and is committed to protecting the personal data of everyone who visits this website or otherwise interacts with us online. This Privacy Policy explains what personal data we collect, why we collect it, how we use and protect it, and the rights you have over it.
This Policy applies to frontlineadvisory.org (the “Website”) and to personal data we collect through the Website — including contact forms, newsletter sign-ups, and job applications. It does not cover personal data we collect in the course of a specific client engagement, which is governed by the terms of the relevant engagement letter and our internal Confidentiality and Non-Disclosure Policy.
We are guided by the Nigeria Data Protection Act 2023 (“NDPA”) and its implementing regulations, and we have benchmarked our practices against internationally recognised standards, so that this Policy reflects good international practice as well as Nigerian law.

 

2. Who We Are

Frontline Advisory is a Pan-African ESG and sustainability advisory firm headquartered in Lagos, Nigeria. For the purposes of the NDPA and this Policy, Frontline Advisory is the data controller responsible for personal data collected through the Website.
Contact details: Frontline Advisory Lagos, Nigeria Email: info@frontlineadvisory.org

 

3. What Personal Data We Collect

Depending on how you interact with the Website, we may collect:

• Contact and enquiry data — your name, email address, phone number, organisation, and the content of any message you send us through a contact or enquiry form.
• Newsletter and mailing list data — your name and email address, if you subscribe to receive updates from us.
• Job application data — your name, contact details, CV, cover letter, and any other information you choose to submit if you apply for a role or express interest in working with us through the Website.
• Technical and usage data — your IP address, browser type, device information, pages visited, and time spent on the Website, collected automatically through cookies and similar technologies (see Section 6).
• We do not knowingly collect any special category of personal data (such as health, biometric, or religious information) through the Website.

 

4. How We Use Your Data

We use the personal data described above to:

• Respond to your enquiries and communicate with you;
• Send you newsletters or updates you have subscribed to;
• Consider your application if you apply for a role with us;
• Understand how visitors use the Website, and improve its content and performance;
• Meet our legal and regulatory obligations; and
• Protect the security and integrity of the Website.
• We do not sell your personal data to any third party, and we do not use it for automated decision-making that produces a legal or similarly significant effect on you.

5. Legal Basis for Processing

Under the NDPA, we process your personal data on one or more of the following bases:

• Consent — for example, when you subscribe to our newsletter or accept cookies.
• Legitimate interest — for example, to respond to an enquiry you have sent us, or to understand and improve how the Website is used, provided this does not override your own rights and interests.
• Contract or pre-contractual steps — for example, if you apply for a role with us and we need to process your application.
  Legal obligation — where we are required to process or retain data to comply with applicable law.
• Where we rely on your consent, you may withdraw it at any time using the contact details in Section 13, without affecting the lawfulness of processing carried out before you withdrew it.

6. Cookies and Tracking Technologies

The Website uses cookies and similar technologies to operate correctly and to help us understand how visitors use it.

• Essential cookies are necessary for the Website to function and cannot be switched off.
• Analytics cookies help us understand visitor behaviour (for example, which pages are most visited) so we can improve the Website. These are only set with your consent, where required.
• Functionality cookies remember choices you make (such as language preference) to improve your experience.
  You can control or disable cookies through your browser settings at any time. Disabling certain cookies may affect how parts of the Website function.

7. How We Share Your Data

We do not sell or rent your personal data. We may share it with:

• Service providers who support our Website and business operations — for example, website hosting providers, email service providers, and analytics providers — who process data on our behalf and are contractually required to protect it and use it only for the purposes we specify.
• Regulators and authorities, where we are required by law to disclose information, such as in response to a valid request from the Nigeria Data Protection Commission (NDPC) or another competent authority.
• Professional advisors, such as our lawyers or auditors, on a confidential, need-to-know basis.

We do not otherwise share your personal data with third parties without your consent, unless required or permitted by law.

8. International Data Transfers

Some of our service providers (for example, email or analytics platforms) may process data outside Nigeria. Where this occurs, we take reasonable steps to ensure the transfer complies with the NDPA’s cross-border transfer requirements — including relying on an adequacy determination by the NDPC, appropriate contractual safeguards, or another lawful transfer mechanism.

9. Data Retention

We retain personal data collected through the Website only for as long as necessary for the purpose for which it was collected, or as required by law:

• Contact and enquiry data is generally retained for up to 24 months after our last interaction with you, unless a longer period is needed to resolve an ongoing matter.
• Newsletter data is retained until you unsubscribe.
• Job application data is generally retained for up to 12 months after a recruitment process closes, unless you consent to it being retained for longer to consider you for future roles.

After the applicable retention period, we securely delete or anonymise your data.

10. Data Security

We implement appropriate technical and organisational measures to protect personal data collected through the Website against unauthorised access, loss, misuse, or alteration, consistent with the security standards described in our internal Confidentiality and Non-Disclosure Policy. No method of transmission over the internet or electronic storage is completely secure, and we cannot guarantee absolute security.

11. Children’s Privacy

The Website is intended for a professional and business audience and is not directed at children. We do not knowingly collect personal data from anyone under the age of 18. If you believe a child has provided us with personal data, please contact us using the details in Section 13 so we can delete it.

12. Your Rights

Under the NDPA, you have the right to:

• Access the personal data we hold about you;
• Correct inaccurate or incomplete data;
• Request deletion of your data, where applicable;
• Restrict or object to certain processing of your data;
• Data portability, where technically feasible; and
• Withdraw consent at any time, where processing is based on consent.

To exercise any of these rights, contact us using the details in Section 13. We will respond within the timeframe required by the NDPA. You also have the right to lodge a complaint with the Nigeria Data Protection Commission (NDPC) if you believe your data protection rights have been violated.

13. How to Contact Us

If you have a question about this Policy or wish to exercise your data protection rights, please contact:
Frontline Advisory Email: info@frontlineadvisory.org

14. Changes to This Policy

We may update this Policy from time to time to reflect changes in our practices or in applicable law. The “Last updated” date at the top of this page shows when it was last revised. We encourage you to review this Policy periodically.

15. Third-Party Links

The Website may contain links to third-party websites. We are not responsible for the privacy practices or content of those websites, and we encourage you to review their own privacy policies before providing any personal data to them.