Privacy Policy

Who we are

Pentagon Nominees Services Limited is a corporate services and advisory firm registered in Nigeria, with its office at 16 Rasheed Alaba Williams Street, Lekki Phase 1, Lagos. In this policy, “we” and “us” mean Pentagon Nominees Services Limited.

We are the data controller for the personal data described in this policy. Where we act on a client’s instructions in administering an entity or an estate, we may also process personal data as a data processor on that client’s behalf.

Personal data we collect

The data we hold depends on the service. Across our engagements it may include:

• Identification data: name, date of birth, nationality, identification documents, photographs and signatures
• Contact data: postal address, email address and telephone numbers
• Corporate data: directorships, shareholdings, beneficial ownership and positions held in other entities
• Financial data: bank details, source of funds and source of wealth information, and transaction records
• Estate and family data: relationships, dependants, beneficiaries, wills and testamentary intentions
• Employment data for applicants: CVs, references, qualifications and interview records
• Technical data from this website: IP address, browser type, and pages visited

How we collect it

Most of the data we hold comes directly from you: through enquiry and application forms on this website, through correspondence, and through the documents you provide during onboarding.

We also obtain data from public and third-party sources where the engagement requires it, including the register maintained by the Corporate Affairs Commission, probate registries, land registries, sanctions and politically exposed person screening providers, and referees you have nominated.

Why we use it, and our lawful basis

We process personal data only where we have a lawful basis under the Nigeria Data Protection Act 2023. In practice:

• To perform our contract with you: delivering the service you have engaged us for, and administering the engagement
• To comply with a legal obligation: client due diligence, anti-money-laundering checks, statutory filings and beneficial ownership disclosures
• For our legitimate interests: managing our relationship with you, maintaining our records, and protecting the firm against fraud and legal claims
• With your consent: responding to a website enquiry, holding a speculative job application on file, and any marketing communications

Who we share it with

We do not sell personal data. We share it only where the engagement or the law requires, and then only what is necessary:

• Regulators and authorities, including the Corporate Affairs Commission, tax authorities, probate registries and courts
• Our affiliated Nigerian law firm, where legal advice or representation forms part of your matter
• Professional advisers instructed on your matter, including valuers, auditors and accountants
• Banks and financial institutions, where an escrow account or a payment is involved
• Service providers who support our operations, including IT and document storage providers, under written confidentiality obligations

Transfers outside Nigeria

Some of the systems we use to store documents and email may process data outside Nigeria. Where personal data is transferred abroad, we do so only where the destination provides an adequate level of protection, or where appropriate contractual safeguards are in place, as required by the Nigeria Data Protection Act 2023.

How long we keep it

We keep personal data for as long as the engagement continues, and afterwards for the period required by law, by our professional obligations, and by the limitation periods that apply to potential claims.

We retain client due diligence and transaction records for at least five years after the relationship ends or the transaction completes, as the Money Laundering (Prevention and Prohibition) Act 2022 requires. Estate and fiduciary files stay with us for longer, because people may rely on the arrangements they record many years later. Speculative job applications stay with us for twelve months, and after that we delete them.

How we protect it

We apply administrative, technical and physical controls appropriate to the sensitivity of what we hold: access on a need-to-know basis, confidentiality obligations binding every member of staff, secured premises and file storage, and controlled access to our systems.

Confidentiality is central to nominee, escrow and estate work. We build our engagement terms, file handling and staff obligations around it.

Your rights

Subject to the exemptions in the Act, you have the right to:

• Be informed about how your personal data is used
• Request access to the personal data we hold about you
• Ask us to correct data that is inaccurate or incomplete
• Ask us to delete data where we no longer have a basis for holding it
• Object to processing carried out on the basis of our legitimate interests
• Ask us to restrict processing while a concern is being resolved
• Withdraw consent at any time, where consent is the basis on which we hold the data
• Receive data you have provided to us in a commonly used, machine-readable format, and have it transmitted to another controller (data portability)
• Not be subject to a decision based solely on automated processing that produces legal or similarly significant effects for you
• Lodge a complaint with the Nigeria Data Protection Commission

Where rights are limited

Some of our obligations override a request. We cannot delete records we are required by law to keep, including client due diligence records and statutory filings, and we cannot restrict a disclosure that a regulator or a court is entitled to receive.

Where we cannot act on a request, we will tell you why.

Cookies

This website sets one essential cookie to record your cookie choice and, only with your consent, Google Analytics cookies that measure which pages people read. Our typefaces load from our own server. Our cookie policy lists each cookie and explains how to change your choice.

Changes to this policy

We review this policy periodically and will publish any updated version on this page with a new effective date. Where a change materially affects how we use your personal data, we will tell you directly.