Legal

Cookies Policy

Effective Date: 19 June 2026 | Version: 1.0 | Nigeria Data Protection Act (NDPA) 2023 Compliant

This Policy should be read alongside our Privacy Policy, which sets out the full scope of our personal data processing activities.

1. Introduction

The Energy Consulting Practice LLP (“TECP”, “we”, “us”, “our”, or “the Company”) is a company incorporated under the laws of the Federal Republic of Nigeria, with its registered office at Block 5, No 11, Philip Aduda Street, Wuye District, Abuja, Nigeria (“Registered Address”).

We operate in the oil and gas sector and maintain this Website to serve a wide range of stakeholders including customers, investors, regulators, contractors, job applicants, vendors, business partners, and the general public.

We are committed to protecting your privacy and handling your personal data responsibly. This Policy explains what cookies are, how we use them, the legal basis for their use, your rights in relation to them, and how you can control your cookie preferences.

By visiting our Website, you acknowledge that you have read and understood this Cookies Policy. Your continued use of the Website following any material update to this Policy will constitute acknowledgement of the revised terms, subject always to your right to withdraw consent for non-essential cookies.

2. What Are Cookies?

Cookies are small text files that are placed on your device, including computer, tablet, smartphone, or other internet-enabled device, when you visit a website. They are widely used by website operators to make their websites function properly, improve efficiency, and provide useful information to the website owner.

Cookies allow the website to recognise your device during a browsing session, known as session cookies, or across multiple visits, known as persistent cookies. They serve a range of functions, including remembering your preferences, understanding how you use the website, and enabling certain features.

In addition to cookies, we may also use similar tracking technologies such as:

• Web beacons, also called pixel tags or clear GIFs, which are small graphic images embedded in web pages or emails that track user activity.
• Local storage objects, which are data stored in your browser outside of cookies, including HTML5 local storage.
• Scripts and tags, which are code embedded on our Website pages to collect information about how users interact with the Website.

References to “cookies” in this Policy include all such similar technologies unless otherwise specified.

3. Legal Basis for Using Cookies

Our use of cookies is governed by the Nigeria Data Protection Act (NDPA) 2023 and the Nigeria Data Protection Commission (NDPC) General Application and Implementation Directive (GAID) 2025. The legal basis for processing personal data through cookies depends on the category of cookie:

3.1 Strictly Necessary Cookies

We process personal data collected through strictly necessary cookies on the basis of our legitimate interest in operating a secure and functional website, and to fulfil our obligations to you as a Website visitor. Strictly necessary cookies do not require your prior consent; however, we remain transparent about their use.

3.2 Non-Essential Cookies

For all non-essential cookies, including performance, functional, and marketing cookies, our legal basis for processing is your freely given, specific, informed, and unambiguous consent, obtained through our Cookie Consent Management Platform (CMP) in accordance with Section 2.2(a) and related provisions of the NDPA 2023 and the GAID 2025.

Consent will only be valid where:

• You have taken an active, affirmative action to indicate consent, for example clicking an “Accept” or “Allow” button;
• You have been provided with clear and intelligible information about the cookies and their purposes before consenting;
• Consent is granular, allowing you to accept or reject specific categories of non-essential cookies;
• Consent is freely given and not conditional on the use of the Website;
• Silence, pre-ticked boxes, inactivity, or continued browsing without affirmative action do not constitute valid consent.

4. Categories of Cookies We Use

We use the following categories of cookies on our Website. Each category is described below, together with the purposes for which they are used, whether consent is required, and examples of specific cookies deployed.

4.1 Strictly Necessary Cookies

Strictly necessary cookies are essential for the operation and security of our Website. Without these cookies, the Website cannot function properly. They enable core functionalities such as:

• Enabling you to navigate between pages and use Website features;
• Maintaining the security and integrity of your browsing session;
• Preventing fraudulent activity and protecting the Website against cyber threats;
• Load balancing to ensure Website performance and availability;
• Remembering items in online forms or applications during a single session;
• Facilitating access to secure areas of the Website, such as contractor or investor portals.

4.2 Performance / Analytics Cookies

Performance cookies collect information about how visitors use our Website, including which pages are visited most frequently, how long visitors spend on certain pages, and any error messages encountered. This information is used in aggregate form to improve how our Website works and to understand our Website's performance.

These cookies may collect:

• The pages you visit and the time spent on each page;
• The links you click;
• The source from which you arrived at our Website;
• Technical information such as browser type and operating system;
• Approximate geographic location, at country or city level, derived from IP address.

We use third-party analytics providers, including Google Analytics and other specified providers, to process this data on our behalf. These providers act as data processors under the NDPA 2023 and are bound by data processing agreements with us.

4.3 Functional Cookies

Functional cookies allow our Website to remember choices you make and provide enhanced, personalised features. The information these cookies collect may be anonymised and cannot track your browsing activity on other websites.

Functional cookies enable:

• Remembering your language or region preference;
• Storing your preferred display settings, such as text size or accessibility features;
• Remembering your login details for protected areas of the Website, where applicable;
• Storing form completion data to improve user experience.

4.4 Marketing / Advertising Cookies

Marketing cookies are used to track visitors across websites and display advertisements that are relevant and engaging to you. They are usually placed by advertising networks with the Website operator's permission. These cookies:

• Build a profile of your interests based on your browsing activity;
• Deliver targeted advertisements relevant to you and your interests;
• Limit the number of times you see an advertisement;
• Measure the effectiveness of advertising campaigns.

Where we deploy marketing cookies, the data collected may be shared with third-party advertising platforms, such as LinkedIn, Google Ads, or other platforms. Where such sharing constitutes a transfer of personal data to third parties, the requirements of the NDPA 2023 and GAID 2025 will be complied with.

4.5 Third-Party Cookies

Some cookies on our Website are set by third-party service providers who deliver services on our behalf or whose content appears on our Website. These third-party cookies may include:

• Analytics providers, such as Google Analytics and other providers;
• Social media platforms, such as LinkedIn and Twitter/X, when you interact with social sharing buttons;
• Embedded video platforms, such as YouTube and Vimeo, when we embed video content;
• Advertising and remarketing networks;
• Customer support chat tools or service desk platforms.

We do not control these third-party cookies and are not responsible for their placement or operation. We recommend that you consult the respective privacy and cookies policies of these third parties. Links to relevant third-party policies are set out in Schedule 1 to this Policy.

5. How We Obtain Your Consent

5.1 Cookie Consent Management Platform (CMP)

When you first visit our Website, you will be presented with a cookie consent banner powered by our Cookie Consent Management Platform. The banner will clearly inform you of:

• The categories of cookies we use;
• The purposes for which each category of cookie is used;
• Your options to accept, reject, or customise cookie settings;
• A link to this Cookies Policy for detailed information.

5.2 Your Consent Choices

Our CMP provides you with the following options:

• Accept All Cookies: You consent to the use of all cookie categories, including performance, functional, and marketing cookies.
• Reject Non-Essential Cookies: You decline all non-essential cookies; only strictly necessary cookies will be activated.
• Customise Preferences: You select which categories of non-essential cookies you are willing to accept.

5.3 Standards of Consent

Consent obtained through our CMP will meet the following standards required under the NDPA 2023 and GAID 2025:

• Freely given: Consent is not a condition of accessing the Website or receiving our services.
• Specific: Consent is sought separately for each category of non-essential cookies.
• Informed: Clear information is provided before consent is sought.
• Unambiguous: Consent requires a positive opt-in action; pre-ticked boxes, silence, or inactivity do not constitute consent.
• Granular: You may accept or reject individual categories of non-essential cookies.

5.4 Record-Keeping

We maintain records of consent obtained through our CMP, including the date and time of consent, the version of the policy presented at the time of consent, and the specific categories of cookies accepted. These records are maintained in compliance with the NDPA 2023 accountability requirements.

6. Withdrawal of Consent

You have the right to withdraw your consent to non-essential cookies at any time. Withdrawal of consent shall be as straightforward as giving it. You may withdraw consent by:

• Clicking the “Cookie Settings” or “Manage Preferences” button located in the footer of our Website and updating your preferences through our CMP;
• Adjusting your browser settings to block or delete cookies. See Section 7 below;
• Contacting us directly using the contact details in Section 17 of this Policy.

Please note that withdrawal of consent does not affect the lawfulness of processing carried out prior to withdrawal. Withdrawing consent to non-essential cookies may limit certain Website features or functionalities.

Upon withdrawal of consent, non-essential cookies will be deactivated. We will endeavour to give effect to your withdrawal as promptly as technically practicable.

7. Managing Cookies Through Your Browser

In addition to the controls available through our CMP, you can manage cookies through your web browser settings. Most browsers allow you to:

• View cookies that have been set on your device;
• Block cookies from being set;
• Delete cookies that have already been set;
• Set your browser to notify you when a website attempts to set a cookie.

Please note that blocking all cookies may impair the functionality of our Website. Instructions for managing cookies in commonly used browsers are available at the following links. These are external links and we are not responsible for their content:

• Google Chrome: Settings > Privacy and Security > Cookies and other site data
• Mozilla Firefox: Options > Privacy & Security > Cookies and Site Data
• Microsoft Edge: Settings > Cookies and site permissions
• Safari: Preferences > Privacy
• Opera: Settings > Advanced > Privacy & Security

For information on managing cookies on mobile devices, please refer to the settings on your specific device.

8. Data Retention: Cookie Duration

Cookies may be classified by their duration as follows:

Session Cookies

Session cookies are temporary and are deleted from your device automatically when you close your browser or end your browsing session. They are used to remember your actions during a single session.

Persistent Cookies

Persistent cookies remain on your device for a fixed period after your browsing session ends. The duration varies depending on the specific cookie and its purpose. Persistent cookies are deleted either when they expire or when you delete them manually through your browser settings.

We apply the principle of storage limitation under the NDPA 2023. We retain data collected through cookies only for as long as is necessary for the purposes for which it was collected, or as required by law. The specific retention period for each cookie is set out in the tables in Section 4 of this Policy.

Where retention periods are not fixed, for example where cookies are retained until you opt out or close your account, we will apply appropriate criteria to determine the appropriate retention period having regard to the purpose of the cookie, the nature of the data collected, and any applicable legal requirements.

9. Children's Data

Our Website is intended for use by adults and professionals. It is not directed at or designed for use by children under the age of 18 years, nor do we knowingly collect personal data from children through our Website.

To the extent that any cookies on our Website may collect personal data relating to children under 18 years of age, we require verifiable parental or guardian consent before such processing may take place, in accordance with the NDPA 2023.

If you are a parent or guardian and you believe that your child has provided us with personal data without your consent, please contact us immediately using the details set out in Section 17. We will take prompt steps to delete such information from our systems.

Children should not use this Website without appropriate parental supervision.

10. International Data Transfers

Some of our third-party service providers, including analytics and advertising platforms, are based outside of Nigeria. Where cookies facilitate the transfer of personal data to countries outside Nigeria, we will ensure that such transfers are made in compliance with the NDPA 2023 and the NDPC GAID 2025.

Lawful transfer mechanisms we rely upon include:

• Adequacy decisions: Where the Nigeria Data Protection Commission (NDPC) has determined that the destination country provides an adequate level of data protection.
• Standard Contractual Clauses (SCCs): Approved contractual provisions that provide appropriate safeguards for cross-border transfers.
• Binding Corporate Rules: Where applicable within corporate groups.
• Explicit consent: Where you have been specifically informed of the risks associated with the transfer and have explicitly consented to it.

By accepting non-essential cookies that involve international data transfers, you acknowledge that your personal data may be transferred to and processed in countries outside Nigeria. Where we rely on your consent as a transfer mechanism, you may withdraw that consent at any time as described in Section 6 of this Policy.

For further information on the international transfer safeguards applicable to specific third-party service providers, please contact our Data Protection Officer using the details in Section 17.

11. Security of Cookie Data

We implement appropriate technical and organisational measures to protect personal data collected through cookies against unauthorised access, accidental loss, destruction, alteration, or disclosure. Our security measures include:

• Encryption of data in transit using Secure Sockets Layer (SSL) / Transport Layer Security (TLS) technology;
• Access controls restricting access to cookie data to authorised personnel only;
• Use of secure, reputable servers and cloud infrastructure with appropriate security certifications;
• Regular security assessments and vulnerability testing of our Website and associated systems;
• Monitoring and logging of access to systems that process cookie-related data;
• Data Processing Agreements with third-party processors that impose equivalent security obligations;
• Staff training on data protection and information security obligations.

Notwithstanding these measures, no method of transmission over the internet or method of electronic storage is entirely secure. We cannot guarantee absolute security of your data; however, we are committed to taking all reasonable steps to protect it.

In the event of a personal data breach involving data collected through cookies, we will notify the Nigeria Data Protection Commission (NDPC) and, where required, affected data subjects, in accordance with the timeframes and requirements prescribed by the NDPA 2023 and GAID 2025.

12. Your Data Subject Rights

In accordance with the Nigeria Data Protection Act (NDPA) 2023, you have the following rights in relation to personal data collected about you through cookies:

12.1 Right of Access

You have the right to request confirmation of whether we process your personal data through cookies and, if so, to receive a copy of that data and information about how it is processed.

12.2 Right to Rectification

Where we hold inaccurate personal data collected through cookies, you have the right to request that we correct it.

12.3 Right to Erasure

In certain circumstances, you have the right to request that we delete personal data collected through cookies. This right applies where, for example, the data is no longer necessary for the purpose for which it was collected, or where you have withdrawn your consent and there is no other lawful basis for processing.

12.4 Right to Restrict Processing

You have the right to request that we restrict the processing of your personal data in certain circumstances, including while we investigate a complaint about accuracy.

12.5 Right to Data Portability

Where we process your personal data based on your consent, you have the right to receive the data in a structured, commonly used, and machine-readable format, and to transmit that data to another controller.

12.6 Right to Object

You have the right to object to the processing of your personal data for purposes of direct marketing, including profiling for marketing purposes, or where we rely on our legitimate interests as a basis for processing. Where you object, we will cease processing unless we can demonstrate compelling legitimate grounds that override your interests or where processing is required for the establishment, exercise, or defence of legal claims.

12.7 Right to Withdraw Consent

Where we rely on your consent to use cookies, you have the right to withdraw that consent at any time. See Section 6. Withdrawal will not affect the lawfulness of prior processing.

12.8 Rights Related to Automated Decision-Making

You have the right not to be subject to a decision based solely on automated processing, including profiling, where that decision produces a legal or similarly significant effect. If we use cookie data for such purposes, we will inform you and provide appropriate safeguards.

12.9 Right to Lodge a Complaint

You have the right to lodge a complaint with the Nigeria Data Protection Commission (NDPC) if you believe that our processing of your personal data violates the NDPA 2023. Contact details for the NDPC are provided in Section 13 below.

To exercise any of these rights, please contact our Data Protection Officer using the details in Section 17 below. We will respond to your request within the timeframes prescribed by the NDPA 2023, ordinarily within 30 days unless extended in accordance with the Act.

13. Regulatory Authority: NDPC

The Nigeria Data Protection Commission (NDPC) is the principal data protection supervisory authority in Nigeria, established under the NDPA 2023. If you have concerns about how we handle your personal data through cookies that we have been unable to address to your satisfaction, you may contact the NDPC as follows:

We encourage you to contact us directly in the first instance. See Section 17, as we are committed to resolving any concerns promptly and to your satisfaction.

14. Cookie Consent Records and Accountability

We maintain a record of all consents obtained through our CMP, consistent with our accountability obligations under the NDPA 2023. These records include:

• The identity of the data subject, where ascertainable;
• The date and time consent was given;
• The specific categories of cookies consented to;
• The version of the Cookies Policy in force at the time of consent;
• The method by which consent was obtained.

These records are held securely and are available for review by the NDPC upon request. We conduct periodic audits of our cookie practices to ensure ongoing compliance with the NDPA 2023 and GAID 2025.

15. Updates to This Cookies Policy

We reserve the right to update, modify, or replace this Cookies Policy at any time to reflect:

• Changes in applicable law or regulatory guidance, including updates to the NDPA 2023 or NDPC GAID;
• Changes in our Website functionality or the cookies we deploy;
• Changes in the services provided by our third-party partners;
• Improvements in our data protection practices.

The Effective Date at the top of this Policy indicates the date on which the current version came into force. Where we make material changes to this Policy, we will notify you through a prominent notice on our Website and, where we hold your contact details and where required by law, by direct notification.

We encourage you to review this Policy periodically. Your continued use of the Website after any changes to this Policy, subject to your right to manage cookie preferences, will constitute acknowledgement of the updated Policy. If you do not agree with any changes, you may withdraw consent for non-essential cookies as described in Section 6 and/or discontinue use of the Website.

16. Glossary

The following definitions apply throughout this Cookies Policy:

17. Contact Information

If you have any questions, concerns, or requests regarding this Cookies Policy or our use of cookies, please contact us using the details below:

Schedule 1: Third-Party Cookie Providers

The following third-party service providers may set cookies on our Website. Please refer to their respective privacy and cookies policies for detailed information on their data practices: