1. INTRODUCTION
Euphemia LLP ("Euphemia", "the Firm", "we", "us", or "our") is committed to protecting the privacy, confidentiality, and security of personal data entrusted to us in the course of providing legal, regulatory, advisory, and dispute resolution services. This Client Privacy Notice explains how we collect, use, disclose, store, transfer, and otherwise process personal data in connection with our legal services and professional engagements.
This Notice is issued in accordance with the Nigeria Data Protection Act, 2023 (NDPA), the General Application and Implementation Directive (GAID) 2025 issued by the Nigeria Data Protection Commission (NDPC), and other applicable data protection laws.
2. APPLICATION
This Notice applies to:
- Existing and prospective clients;
- Directors, shareholders, beneficial owners, officers, and employees of clients;
- Opposing parties and their representatives;
- Witnesses and experts;
- Vendors, consultants, and professional advisers;
- Individuals connected with matters on which we act; and
- Any person whose personal data is provided to us in the course of delivering legal services.
3. PERSONAL DATA WE COLLECT
Depending on the nature of our engagement, we may collect and process the following categories of personal data:
Identity Information
- Full name;
- Date of birth;
- Nationality;
- Gender;
- Photograph;
- Government-issued identification details.
Contact Information
- Residential address;
- Business address;
- Email address;
- Telephone number.
Professional Information
- Occupation;
- Employer details;
- Position or title;
- Professional affiliations.
Financial Information
- Banking details;
- Tax information;
- Financial records;
- Transactional information.
Regulatory and Compliance Information
- Know-Your-Client (KYC) information;
- Anti-Money Laundering (AML) documentation;
- Beneficial ownership information;
- Regulatory filings and disclosures.
Matter-Related Information
- Litigation documents;
- Contracts and agreements;
- Corporate records;
- Due diligence materials;
- Correspondence and communications.
4. HOW WE COLLECT PERSONAL DATA
We may obtain personal data:
- Directly from clients;
- Through engagement and instruction processes;
- From public records and regulatory databases;
- From counterparties and opposing parties;
- From courts, tribunals, and regulatory authorities;
- From professional advisers and service providers;
- Through due diligence investigations;
- Through business development and networking activities; and
- From other lawful sources relevant to our professional engagement.
5. PURPOSES OF PROCESSING
We process personal data for purposes including:
- Providing legal and advisory services;
- Conducting conflict checks;
- Client onboarding and engagement management;
- Compliance with professional obligations;
- Regulatory compliance and reporting;
- Litigation, arbitration, mediation, and dispute resolution;
- Corporate transactions and due diligence exercises;
- Debt recovery and enforcement proceedings;
- Internal administration and risk management;
- Billing, invoicing, and financial administration;
- Defending legal claims and protecting legal rights; and
- Any other purpose necessary for the performance of our professional services.
6. LEGAL BASIS FOR PROCESSING
We process personal data on one or more of the following lawful bases:
- Performance of a contract;
- Compliance with legal obligations;
- Legitimate interests pursued by the Firm or our clients;
- Consent where required by law;
- Protection of vital interests;
- Exercise of official authority where applicable; and
- Establishment, exercise, or defence of legal claims.
7. CONFIDENTIALITY AND LEGAL PROFESSIONAL PRIVILEGE
As legal practitioners, we are subject to strict professional duties of confidentiality and legal professional privilege.
Information provided to us in connection with legal instructions is treated as confidential and protected in accordance with applicable laws, professional rules, and ethical obligations.
Nothing in this Notice shall limit or waive legal professional privilege where applicable.
8. DISCLOSURE OF PERSONAL DATA
We may disclose personal data where necessary to:
- Courts and tribunals;
- Regulatory and governmental authorities;
- Law enforcement agencies;
- Opposing counsel and counterparties;
- Professional advisers and consultants;
- Auditors and insurers;
- Technology and cloud service providers;
- Financial institutions; and
- Other third parties where disclosure is required by law or authorised by the client.
9. INTERNATIONAL DATA TRANSFERS
Where it is necessary to transfer personal data outside Nigeria, Euphemia LLP shall implement appropriate safeguards and transfer mechanisms in accordance with the NDPA, GAID, and applicable legal requirements.
10. DATA SECURITY
We implement appropriate technical, organisational, and administrative safeguards designed to protect personal data against unauthorised access, disclosure, alteration, misuse, loss, or destruction.
These measures include:
- Access controls;
- Encryption technologies;
- Secure document management systems;
- Confidentiality obligations;
- Staff training;
- Cybersecurity safeguards; and
- Periodic compliance reviews.
11. DATA RETENTION
We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, comply with legal and professional obligations, preserve legal professional privilege, resolve disputes, and protect legal rights.
Retention periods may vary depending on the nature of the engagement and applicable legal requirements.
12. YOUR RIGHTS
Subject to applicable law, you may have the right to:
- Request access to your personal data;
- Request correction of inaccurate data;
- Request deletion of personal data;
- Restrict processing of personal data;
- Object to processing;
- Request data portability;
- Withdraw consent where consent is the lawful basis for processing; and
- Lodge a complaint with the Nigeria Data Protection Commission (NDPC).
Requests may be submitted using the contact details provided below.
13. DATA PROTECTION CONTACT
For enquiries regarding this Notice or the processing of personal data, please contact:
Euphemia LLP
Email: Contact@euphemiallp.com
Telephone: 08083000163
14. CHANGES TO THIS NOTICE
We may amend this Client Privacy Notice from time to time to reflect changes in applicable law, regulatory requirements, professional obligations, or operational practices. The most current version will be made available upon request and, where appropriate, published on our website.
15. CONTACT US
For general enquiries regarding our legal services or privacy practices, please contact:
Euphemia LLP
Email: contact@euphemiallp.com
Telephone: 08083000163
By instructing Euphemia LLP or continuing to engage with us, you acknowledge that you have read and understood this Client Privacy Notice.
