Levenile Group
| Document Detail | Information |
|---|---|
| Effective Date | 19/09/2019 |
| Last Reviewed | 05/01/2026 |
| Document Owner | Group Compliance & Data Protection Office |
| Review Cycle | Annually, or upon material change to data processing activities (in line with our quality management commitment to continual review and improvement) |
1. Scope and Application
This Privacy Policy (“Policy”) applies to Levenile Group and its subsidiaries and affiliated business units (collectively “Levenile,” “the Group,” “we,” “us,” or “our”), including but not limited to:
- Levenile Energy Services Limited – Retail Petroleum Consultancy and Fuel Distribution
- South-Western Energy Nigeria Limited – Oil & Gas Retail Operations
- Levenile Digital Innovations Limited – IT Consultancy, Cybersecurity, and Digital Services
- Levenile Power Engineering – Generator, Solar/Inverter Energy Systems
Each subsidiary operates under this shared Group Policy to ensure a consistent standard of data protection across all Levenile services, while remaining separately responsible as a data controller for the personal data it collects in the course of its specific operations.
1.1 Application of This Policy
This Policy applies to personal data collected through:
- Our websites (including levenilegroup.com and any subsidiary microsites)
- Client onboarding and service agreements
- Customer support and communication channels (phone, email, WhatsApp, in-person)
- Site visits, installations, and field service engagements
- Job applications and vendor/partner registrations
- CCTV and physical security systems at our facilities
2. Information We Collect
2.1 Information You Provide Directly
We collect the following categories of personal data that you voluntarily provide:
- Full name, job title, and company/organization name
- Contact details (phone number, email address, physical address)
- Billing and payment information
- Site plans, technical specifications, and property details (for energy and power engineering services)
- Identification documents where required for regulatory compliance (e.g., petroleum licensing, security clearance for sensitive sites)
- Correspondence and support requests
2.2 Information Collected Automatically
When you interact with our digital platforms, we automatically collect:
- IP address, browser type, and device information
- Website usage data (pages visited, time on site, referral source) via cookies and analytics tools
- Location data, where enabled, for service dispatch and logistics purposes
2.3 Information from Third Parties
We may also receive personal data about you from external sources, including:
- Credit and business verification information from partner banks or credit bureaus
- Information from vendors, subcontractors, or referral partners in connection with service delivery
- Publicly available business registration information
3. How We Use Your Information
We process personal data for the following purposes:
| Purpose | Examples |
|---|---|
| Service Delivery | Fulfilling fuel supply, power engineering, or IT consultancy contracts |
| Client Onboarding | Verifying identity, setting up accounts, tailoring service tiers (Essential, Professional, Enterprise) |
| Communication | Responding to inquiries, sending service updates, dispatch notifications |
| Compliance | Meeting HSSE, petroleum licensing, and other regulatory obligations |
| Security | Monitoring facilities, preventing fraud, protecting staff and client safety |
| Improvement | Analyzing service performance, monitoring generator/solar system data via our AI-assisted monitoring tools |
| Marketing | Sending relevant updates about services, with your consent where required |
Important: We do not sell personal data to third parties.
4. Legal Basis for Processing
Where applicable under the Nigeria Data Protection Act (NDPA) 2023, we rely on one or more of the following legal bases:
| Legal Basis | Description |
|---|---|
| Consent | Where you have given clear permission (e.g., marketing communications) |
| Contract Performance | To deliver the services you have engaged us for |
| Legal Obligation | To comply with petroleum, energy, and data protection regulations |
| Legitimate Interest | For security, fraud prevention, and service improvement, balanced against your rights |
5. How We Share Information
We may share personal data with the following categories of recipients:
- Affiliated Levenile subsidiaries – where necessary for coordinated service delivery (e.g., a client using both energy and IT services)
- Regulatory bodies – including but not limited to the Nigerian Midstream and Downstream Petroleum Regulatory Authority (NMDPRA) and the Nigeria Data Protection Commission (NDPC)
- Service providers and subcontractors – engaged to deliver installations, maintenance, or technical support, bound by confidentiality obligations
- Financial institutions – for payment processing
- Law enforcement or courts – where legally required
Important: We do not share personal data with third parties for their independent marketing purposes without your explicit consent.
6. Data Retention
We retain personal data only as long as necessary for the purposes described in this Policy, including to satisfy legal, accounting, or regulatory reporting requirements. Retention periods vary by data category and are documented in our internal data retention schedule.
6.1 General Retention Guidelines
| Data Category | Retention Period |
|---|---|
| Client contract and transaction records | Minimum of 6 years after contract end (per standard Nigerian tax and business record-keeping requirements) |
| CCTV footage | 30 days, unless required for an active investigation |
| Job applications (unsuccessful candidates) | 12 months |
7. Your Rights
Subject to applicable law, you have the following rights regarding your personal data:
- Right of Access – Request access to the personal data we hold about you
- Right to Rectification – Request correction of inaccurate or incomplete data
- Right to Erasure – Request deletion of your data, where legally permissible
- Right to Object/Restrict – Object to or restrict certain processing activities
- Right to Withdraw Consent – Withdraw consent at any time, where processing is based on consent
- Right to Lodge a Complaint – Lodge a complaint with the Nigeria Data Protection Commission (NDPC)
To exercise any of these rights, contact our Data Protection Office using the details in Section 11 below.
8. Data Security
In line with our commitment to quality and operational excellence, we maintain administrative, technical, and physical safeguards designed to protect personal data, including:
- Access controls and role-based permissions
- Encryption of sensitive data in transit and at rest, where applicable
- Regular security assessments (particularly through Levenile Digital Innovations’ cybersecurity practice)
- Staff training on data handling and confidentiality
- Incident response procedures for suspected data breaches
Important: No system is completely secure, and we cannot guarantee absolute security. In the event of a data breach affecting your personal data, we will notify affected individuals and the NDPC in accordance with applicable law.
9. Cookies and Website Tracking
Our website uses cookies and similar technologies to improve user experience, analyze traffic, and support site functionality. You can control cookie preferences through your browser settings. Disabling cookies may affect certain website features.
10. International Data Transfers
Where personal data is transferred outside Nigeria (for example, to cloud service providers used by Levenile Digital Innovations), we take steps to ensure such transfers comply with NDPA requirements, including:
- Verifying that the recipient jurisdiction provides an adequate level of data protection, or
- Ensuring that appropriate safeguards are in place
11. Contact Us
For questions, concerns, or to exercise your data protection rights, contact:
Levenile Group — Data Protection Office
| Channel | Details |
|---|---|
| dataprotection@leveniilegroup.com | |
| Phone | 07065518300 |
| Address | 12th Floor, Western House Building, 8/10 Broad Street, Marina, Lagos |
You may also lodge a complaint directly with the Nigeria Data Protection Commission (NDPC) if you believe your data protection rights have been violated.
12. Changes to This Policy
We review this Policy at least annually as part of our internal quality management process. Material changes will be communicated via our website and, where appropriate, directly to affected clients. Continued use of our services after changes take effect constitutes acceptance of the updated Policy.