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Privacy Policy

Version 1.0  ·  Effective Date: 1 June 2026  ·  Owner: Data Protection Officer, Sungas Company Limited

1. Who We Are

Sungas Company Limited (“Sungas”, “we”, “our”, “us”) is a limited liability company registered in Nigeria with RC No. 3010, having its principal office at 1, Obasa Road, Ikeja, Lagos, Nigeria. We are the Data Controller of the personal data described in this Policy. We provide LPG-related products and services in Nigeria across our various product and service channels.

2. Scope

This Policy explains how we collect, use, share, store, and protect your personal data when you interact with us as a customer, employee, applicant, contractor, vendor, visitor, or other business contact. It applies to all personal data we hold about identifiable individuals.

3. Personal Data We Collect

3.1 Customer data (mandatory for service delivery)

• Identity: name and other identifiers reasonably required to provide services
• Contact: contact and location information needed to communicate with you or provide our services
• Transactional: records relating to orders, payments, preferences, and account activity

3.2 Customer data (optional, with explicit consent)

• Preferences: your communication choices and optional preferences
• Feedback: feedback, enquiries, complaints, and similar communications

3.3 Employee, contractor and vendor data

Identity, official identifiers, statutory records, employment records, and health-related information where required by law.

3.4 Technical data (digital channels)

Technical and usage information from our digital channels, communications metadata, and cookies or similar technologies where applicable.

3.5 Sensitive personal data

We do not routinely collect sensitive personal data. Where exceptionally required by law, we rely on explicit consent and store such data with enhanced security controls.

4. Lawful Basis for Processing (NDPA s.25)

Purpose	Lawful Basis
Providing products and services and fulfilling orders	Contract (NDPA s.25(b))
Payment processing and accounting records	Legal obligation
Efficient service delivery and business operations	Legitimate interest
Sending transactional messages (delivery confirmations, receipts)	Contract
Sending marketing SMS / WhatsApp / email	Consent (withdrawable at any time)
Analysing usage patterns to improve services	Legitimate interest
Recording calls for quality and training	Legitimate interest + notice to caller
Employee payroll, tax, pension, statutory benefits	Contract, Legal obligation
Background checks during recruitment	Consent, Legitimate interest
Responding to queries and complaints	Contract, Legitimate interest
Security monitoring at premises	Legitimate interest in safety and asset protection

We use automated logic to support service administration and analytics. These processes do not make decisions that produce legal or significant effects without human review.

5. Who We Share Your Data With

We share personal data only with service providers necessary for our operations, statutory/regulatory recipients where required by law, and professional advisers under confidentiality obligations. We do not sell your personal data to third parties for their own marketing purposes.

6. How Long We Keep Your Data

We retain personal data only as long as necessary for the purposes for which it was collected and to meet applicable legal, regulatory, accounting, and business continuity requirements. At the end of the applicable retention period, data is deleted, anonymised, or otherwise handled in accordance with our retention and disposal practices.

7. Where Your Data Is Stored

Your data may be stored in Nigeria and, where necessary, in other jurisdictions where our service providers operate. International transfers rely on lawful mechanisms recognised under applicable data protection law. You may request details of safeguards in place by contacting the DPO.

8. Your Rights (NDPA s.34–39)

You have the right to: access, rectification, erasure (“right to be forgotten”), restriction, portability, object to processing, withdraw consent at any time, and not be subject to solely automated decisions that produce significant effects.

To exercise your rights:

• Email: dpo [at] sungas [dot] org
• Post: Office of the DPO, Sungas Company Limited, 1, Obasa Road, Ikeja, Lagos

We will respond within 30 days (NDPA s.34(2)), free of charge unless your request is manifestly unfounded or excessive.

9. How We Protect Your Data

We implement appropriate technical and organisational measures including access controls, security monitoring, staff training, contractual controls with processors, and incident management procedures. In the event of a breach affecting your data, we will notify you and the NDPC without undue delay where required by law.

10. Data Protection Officer

Email: dpo [at] sungas [dot] org
Post: Office of the DPO, Sungas Company Limited, 1, Obasa Road, Ikeja, Lagos

11. Complaints

If you are not satisfied with how we have handled your personal data, you may lodge a complaint with:

Nigeria Data Protection Commission (NDPC)
Plot 1093, Cadastral Zone B07, Saka Tinubu Street, Mabushi, Abuja
Phone: 09-461-3601  ·  Email: info [at] ndpc [dot] gov [dot] ng  ·  Web: ndpc.gov.ng

EU data subjects may also complain to their local supervisory authority.

12. Children’s Data

Our services are not directed at children under 18. We do not knowingly collect personal data from children. If you believe a child has provided us data without verifiable parental consent, please contact the DPO and we will delete it promptly.

13. Changes to This Policy

We may update this Policy from time to time. The version and effective date at the top indicate the last update. For material changes, we will take reasonable steps to notify you before they take effect.