Privacy Policy

Effective date: 13 September 2026 | Last updated: 13 September 2026

This Privacy Policy explains how Joe Adinma & Co. ("we", "us", "our" or "the Firm") collects, uses, stores, discloses and otherwise processes personal data when you visit joeadinma.com (the "Site"), communicate with us, or interact with us in connection with our professional services. It is intended to operate in accordance with the Nigeria Data Protection Act, 2023 ("NDP Act") and applicable directives, guidance and requirements of the Nigeria Data Protection Commission ("NDPC"), including the General Application and Implementation Directive ("GAID") 2025.

This Policy should be read together with any applicable client engagement letter, professional confidentiality obligations and any more specific privacy notice provided for a particular service or processing activity.

1. Who We Are

Joe Adinma & Co. is a firm of Chartered Accountants based at Plot 500 East West Road, Rumuodara, Port Harcourt, Rivers State, Nigeria. Where we determine the purposes and means of processing personal data, we act as a Data Controller for the purposes of the NDP Act.

Contact: info@joeadinma.com

Data protection enquiries: info@joeadinma.com

2. Personal Information We Collect

Depending on how you interact with us, we may collect and process:

• Identification and contact information - such as name, email address, telephone number, company or organisation name, job title and other contact details.

• Correspondence and enquiry information - information contained in contact forms, messages, emails, telephone conversations and other communications with us.

• Client and engagement-related information - information provided by or on behalf of clients in connection with accounting, audit, tax, advisory or other professional services. Such information remains subject to applicable data-protection law as well as engagement terms and professional confidentiality obligations.

• Technical and usage information - such as IP address, browser type, device information, pages visited, time spent on pages, referring URLs and information obtained through cookies, analytics and similar technologies.

• Payment and transaction information - where applicable. If payments are processed by a third-party payment processor, we may receive transaction-related information but do not ordinarily receive or store complete payment-card details.

• Other information lawfully obtained where necessary for a professional engagement, legal or regulatory obligation, or another legitimate purpose described in this Policy.

3. How We Collect Personal Information

We may obtain personal information:

1. Directly from you when you contact or correspond with us;

2. When you request or engage us to provide professional services;

3. When you complete or submit a form through our website;

4. When you create or use an account, client portal or other digital service that we may make available;

5. During the provision of accounting, audit, tax, advisory or other professional services;

6. Through correspondence by email, telephone or other communication channels;

7. From your company, employer, authorised representative or other persons acting on your behalf;

8. From publicly available sources;

9. From government agencies, regulators and other lawful sources where appropriate; and

10. Automatically when you visit or use our website, including through cookies, analytics and similar technologies.

4. How We Use Personal Information

We may process personal information to:

• Respond to enquiries and provide requested information, proposals or quotations;

• Establish, manage and perform professional engagements and provide accounting, audit, tax, advisory or related services;

• Deliver purchased digital resources or other content, where applicable;

• Administer client relationships, accounts, portals and communications;

• Improve the Site's content, usability, security and performance;

• Send newsletters, updates or similar communications where permitted and, where required, where you have opted in;

• Maintain professional, accounting, tax and regulatory records;

• Comply with legal, regulatory, professional and ethical obligations;

• Establish, exercise or defend legal claims; and

• Detect, investigate and prevent fraud, abuse, security incidents or other unlawful activity.

5. Lawful Bases for Processing

We process personal data only where a lawful basis applies. Depending on the circumstances, this may include consent; processing necessary for the performance of a contract or steps requested before entering into a contract; compliance with a legal obligation; protection of vital interests; performance of a task carried out in the public interest or exercise of official authority where applicable; and legitimate interests pursued by the Firm or a third party, provided those interests are not overridden by the rights and interests of the data subject.

Where we rely on consent, you may withdraw that consent, subject to applicable law. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.

6. How We Share Personal Information

We do not sell personal information. Where necessary and lawful, we may disclose it to:

• Service providers supporting our website, hosting, information technology, communications, analytics and related operations, including our web developer where applicable;

• Payment processors, where applicable;

• Professional advisers, including legal counsel and other specialists, where necessary;

• Government agencies, regulators, courts, law-enforcement bodies or other authorities where required or permitted by law;

• Other parties where disclosure is necessary for a professional engagement and is authorised or otherwise lawful.

Where a third party processes personal data on our behalf, we seek to put appropriate contractual, confidentiality, security and data-protection arrangements in place as required by applicable law.

7. Cookies and Analytics

The Site may use cookies and similar technologies that are necessary for its operation and, where enabled, analytics technologies to understand how visitors use the Site, improve performance and support security. Where consent is required for non-essential cookies or similar technologies, we will seek that consent before placing or using them. You may also control cookies through your browser settings, although disabling certain cookies may affect Site functionality.

8. Data Retention

We retain personal data for no longer than is reasonably necessary for the purposes for which it was collected or further processed, subject to legal, regulatory, tax, audit, professional, contractual, dispute-resolution and legitimate record-keeping requirements. Retention periods may therefore differ according to the nature of the information and the purpose of processing. When information is no longer required, we take reasonable steps to securely delete or anonymise it.

9. Your Data Protection Rights

Subject to the NDP Act and any applicable limitations or exemptions, you may have rights to:

• Be informed about the processing of your personal data;

• Request access to personal data we hold about you;

• Request correction of inaccurate or incomplete personal data;

• Request deletion or erasure where the legal requirements are met;

• Object to or request restriction of certain processing;

• Withdraw consent where processing is based on consent;

• Receive or request transfer of personal data where the right to data portability applies;

• Not be subject to certain decisions based solely on automated processing where applicable; and

• Lodge a complaint with the Nigeria Data Protection Commission.

To exercise a right, contact us using the details in Section 1. We may request information reasonably necessary to verify your identity and assess the request. Rights are subject to applicable legal and professional record-retention requirements.

10. Data Security

We implement reasonable and appropriate technical and organisational measures designed to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access. Measures may include access controls, secure hosting, authentication, confidentiality controls, backups and encryption where appropriate. No method of electronic transmission or storage can be guaranteed to be completely secure.

11. Personal Data Breaches

We maintain procedures for assessing and responding to suspected personal data breaches. Where applicable law requires notification of a breach, we will notify the NDPC and affected data subjects, as appropriate, within the applicable statutory timeframes.

12. International Transfers

Some service providers or technology platforms used by the Firm may process personal data outside Nigeria. Where personal data is transferred internationally, we will take reasonable steps to ensure that the transfer is made in accordance with the NDP Act and applicable NDPC requirements, including the use of an applicable lawful transfer mechanism or other permitted basis.

13. Children's Privacy

The Site and our professional services are not directed at children for the purpose of soliciting personal data. We do not knowingly collect personal data from children through the Site except where there is a lawful and appropriate basis for doing so. Where processing involving a child is necessary, we will apply the safeguards required by applicable law.

14. Third-Party Links

The Site may contain links to third-party websites or services. Their privacy practices are governed by their own notices and policies. We encourage you to review the relevant privacy information before providing personal data.

15. Changes to This Policy

We may update this Privacy Policy periodically to reflect changes in our practices, technology or legal and regulatory requirements. The "Last updated" date at the top of this Policy will identify the most recent revision. Where appropriate, material changes may also be communicated through the Site or another suitable channel.

16. Contact and Complaints

Joe Adinma & Co. (Chartered Accountants)

Plot 500 East West Road, Rumuodara, Port Harcourt, Rivers State, Nigeria

Email: info@joeadinma.com

If you have a question, complaint or request concerning our processing of personal data, please contact us first using the details above. You also have the right, where applicable, to lodge a complaint with the Nigeria Data Protection Commission.