Effective Date: 1^st of November 2025

Filii Magna Limited (“Filii Magna”, “the Company”, “we”, “our”, or “us”) is committed to protecting the privacy and confidentiality of the personal information entrusted to us by Clients, Partners, and Users of our services.

This Privacy Policy outlines how we collect, use, store, disclose, and protect personal data in accordance with the provisions of the Nigeria Data Protection Act 2023 (NDPA) and other applicable data protection regulations.

1. Purpose of this Policy

This Policy establishes the standards and procedures by which Filii Magna ensures that all personal information obtained in the course of providing consultancy and visa services is handled lawfully, fairly, and transparently.

2. Scope

2.1       This Policy applies to:

• All Clients, Applicants, Staff, and Third Parties who provide personal

data to Filii Magna in connection with any service rendered;

• All data processing activities carried out by Filii Magna, whether electronic or manual, within and outside Nigeria.

2.2     It covers all personal information collected through our offices, website, online platforms, and communication channels.

3. Data We Collect

Filii Magna may collect and process the following categories of personal data:

• Identity Data: full name, date of birth, gender, nationality, marital status, passport details, and identification numbers.

• Contact Data: residential address, email address, and telephone numbers.

• Employment and Education Data: academic qualifications, employment history, and professional records.

• Financial Data: payment information, bank account details, and billing records.

• Immigration Data: visa history, travel documents, consular correspondence, and application records.

• Technical Data: IP addresses, browser type, access logs, and device identifiers (where applicable).

Sensitive personal data (such as medical or biometric information) shall only be collected where strictly necessary and with explicit consent of the data subject.

4. Legal Basis for Processing

Filii Magna processes personal data on the following lawful bases:

• Performance of a contract: to provide visa and consultancy services requested by the Client.

• Legal obligation: to comply with statutory, regulatory, and consular requirements.

• Consent: where voluntary consent is provided by the Client for a specific processing purpose.

• Legitimate interest: to improve services, maintain security, and prevent fraud.

5. Purpose of Data Processing

Personal data collected by Filii Magna shall be used solely for the following purposes:

• Processing and managing visa and consultancy applications;

• Communicating with Clients and responding to inquiries;
• Fulfilling legal, regulatory, or contractual obligations;
• Internal record keeping and quality assurance;
• Improving service delivery, systems, and customer experience;
• Managing payments, invoicing, and accounting;
• Complying with applicable immigration and data protection laws.

6. Data Retention

6.1    Personal data shall be retained only for as long as necessary to fulfill the purpose for which it was collected, or as required by applicable laws and regulations.

6.2   Upon expiry of the retention period, Filii Magna shall securely delete, anonymize, or archive personal data in accordance with established data disposal protocols.

7. Data Sharing and Disclosure

7.1    Filii Magna may share personal data only when necessary and in accordance with lawful processing purposes. Such disclosures may include:

• Embassies, Consulates, and Governmental Authorities involved in visa processing;

• Service providers and partners engaged under confidentiality agreements (e.g., courier, IT, or payment processors);

• Legal, accounting, or professional advisors acting on behalf of Filii Magna;

• Regulatory bodies where required by law or court order.

7.2   Filii Magna shall not sell, lease, or otherwise commercially exploit any Client’s personal data.

8. International Data Transfer

8.1     Where personal data is transferred to a jurisdiction outside Nigeria, Filii Magna shall ensure that the receiving country or organization provides an adequate level of data protection in line with NDPA standards.

8.2   Such transfers shall only occur with the consent of the data subject and shall be executed under appropriate data transfer agreements.

9. Data Security

Filii Magna implements appropriate technical and organizational measures to ensure the confidentiality, integrity, and availability of personal data, including:

• Encryption of electronic communications and databases;

• Secure password management and access controls;
• Restricted data access to authorized personnel only;

• Regular security audits, backups, and staff training on data protection compliance.

10. Data Subject Rights

Under the Nigeria Data Protection Act and applicable laws, Clients and Data Subjects have the right to:

• Request access to their personal data;
• Request rectification or correction of inaccurate information;
• Request erasure (“right to be forgotten”) where applicable;
• Object to or restrict processing of personal data;

• Withdraw consent at any time without affecting prior lawful processing;

• Request portability of personal data to another service provider.

All such requests shall be addressed in writing to Filii Magna’s Data Protection Officer and shall be processed within the legally prescribed timeframe.

11. Data Breach Notification

11.1     In the event of a personal data breach likely to result in risk to the rights or freedoms of individuals, Filii Magna shall promptly notify the affected data subjects and the Nigeria Data Protection Commission (NDPC) in compliance with the NDPA 2023.

11.2   Appropriate remedial measures shall be taken immediately to mitigate potential harm and prevent recurrence.

12. Consent and Withdrawal

Where processing is based on the Client’s consent, such consent may be withdrawn at any time by written notice to Filii Magna. Withdrawal of consent shall not affect the lawfulness of processing carried out prior to such withdrawal.

13. Policy Review and Updates

Filii Magna reserves the right to review and amend this Privacy Policy periodically to reflect legal, operational, or technological changes. Updated versions shall take effect immediately upon publication or notification to Clients.

14. Contact Information

For further information, or to exercise any data protection rights, please contact:

Data Protection Officer

Filii Magna Limited

No 8, Providence Street, Lekki Phase 1

Email Address: fi*****@********na.com

Phone Number: 0902739

Approved and Adopted by:

Management, Filii Magna Limited

Date: 1^st of November 2025