KENNA Privacy Policy

This Policy is issued by KENNA LP (“KENNA”, “the Firm”, “we”, or “us” or “our”), a top-tier law firm headquartered in Lagos, Nigeria.

This policy demonstrates KENNA’s commitment to handling all information shared with the Firm with the highest level of care and professionalism, and in compliance with the Nigeria Data Protection Act, 2023 (the "Act" or "NDPA 2023"), the Nigeria Data Protection Act General Application and Implementation Directive, 2025 (the "GAID"), and other applicable data protection laws, regulations and guidance issued by the Nigeria Data Protection Commission.

The Privacy Policy explains how the Firm collects, uses, discloses, transfers, retains and protects personal data, the lawful basis on which we do so, and the rights available to you under Nigerian data protection law.

 This Policy is addressed to individuals outside the Firm with whom we interact, including:

 a.   individual clients and prospective clients;

b.  directors, officers, employees and other representatives of clients, counterparty and supplier organisations;

c.   visitors to our website at https://kennalp.com/  and users of our online tools;

d.  subscribers to our publications and attendees at our seminars, webinars and events;

e.  job applicants, interns, externs and law students who apply to the Firm;

f.    suppliers, vendors, consultants and service providers; and

g.  other third parties who correspond with us or whose personal data we receive in the course of a matter.

 It also applies to our social media pages and to email messages we send you which contain a link to this Policy (together with our website, the "Internet Services").

In our capacity as a law firm headquartered in Nigeria, we may collect or receive the personal data of clients, staff, job applicants, third parties and vendors in the following ways: a. When you access this website or other Internet Services; b. In the course of providing legal services; c. When we receive services from third parties; d. In relation to our recruitment process; e. When you make your Personal Data public; and f. From Persona Data received from third parties relating to our operations.

For public interest.

KENNA will:

a.      ensure that all processing complies with the applicable laws;

b.     not do anything with your data that you would not expect given the content of this Policy and the fair processing or privacy notice;

c.      only collect and process the personal data that it needs for purposes it has identified in advance;

d.     ensure that, as far as possible, the personal data it holds is accurate, or a system is in place for ensuring that it is kept up to date as far as possible; and

e.     ensure that appropriate security measures are in place to ensure that personal data can only be accessed by those who need to access it and that it is held and transferred securely.

We may collect the following categories of Personal Data about you:

 a. Personal and Contact details including names(s), preferred name, photograph, gender; date of birth/age, nationality, salutation, title and language preferences, passport or national identity number, utility provider details, bank statements, correspondence address, telephone number, email address; and details of your public social media profile(s).

 b. Details of the matter: as it relates to individuals instructing KENNA, Personal Data included in correspondence, transaction documents, evidence or other materials that we process in the course of providing services and legal advice.

 c.  Registration data: Newsletter and article requests, event/seminar registrations, subscriptions, downloads, and username/passwords.

 d. Marketing Data: Data about individual participation in conferences and in-person seminars, credentials organized by or on behalf of KENNA that you have attended.

 e. Consent records: records of any consent you may have given, together with the date and time, means of consent and any related information.

 f.   Job applicant data:  Data provided by job applicants or others on our Sites or offline means in connection with employment opportunities.

 g. Security data: login and access records, including usernames, login locations, IP addresses and failed login attempts; CCTV records where applicable; and information relating to actual or suspected security incidents, misuse of our systems, or breaches of the Firm’s policies, standard operating procedures or applicable law.

 h. Internal communication records: information concerning the use of, and Personal Data transmitted through, internal IT systems {e.g., emails, telephone records); and work-related social media accounts.

 i.  Payment details: billing address, payment method; bank account number, accountholder name, invoice records; payment records; payment amount, payment date and records of cheques.

 j.   Views and opinions: any views and opinions that you choose to send to us, or publicly post about us on social media platforms.

 k.  Device data: we may also be privy to your Computer Internet Protocol (IP) address, unique device identifier (UDID), cookies and other data linked to a device, and data about usage of our Sites (Usage Data) and collect same for record purposes.

KENNA implements a number of commercially reasonable physical, technical and procedural security measures to protect your Personal Data from unauthorized access. Personal Data provided to us are stored on secure server which is only accessed in line with our security protocols and by our Personnel or service providers on a need-to-know basis.

 We have put in place procedures to deal with any suspected Personal Data breach and will notify you and the NDPC of the occurrence of a Personal Data breach where we are legally required to do so.

 Any third-party service providers we may engage in that process personal data on our behalf (for the purposes listed above) are also contractually obligated to respect the confidentiality of personal data.

We may engage trusted third-party service providers to support the delivery of our Services, including but not limited to website hosting, server maintenance, data storage and management, email communication, analytics, and customer support. Where necessary, we may share your Personal Data and, in some cases, non-Personal Data with these service providers to enable them to perform such tasks on our behalf.

 Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to fulfil the service they provide you on our behalf. When they no longer need your data to fulfil this service, they will dispose of the details in accordance with KENNA’s procedures. If we wish to pass your sensitive personal data to a third party, we will only do so with your consent.

 In addition to sharing your Personal Data or non-Personal Data with third-party service providers as stated above, we may disclose your Personal Data or non-Personal Data where we believe it is necessary or appropriate to:

 a.      comply with applicable laws, regulations, or legal processes (such as court orders or subpoenas);

b.      respond to lawful requests from government or law enforcement agencies;

c.      protect the rights, property, or safety of the Firm, our users, our Personnel, or others; or

d.      detect, investigate, and help prevent fraud or other illegal activity.

We may transfer your personal data outside Nigeria where:

 a.      The transfer is subject to your explicit consent after being informed of the risks;

b.     The transfer is necessary for the performance of a contract between you and the Firm;

c.      The transfer is necessary for important reasons of public interest;

d.     The transfer is necessary for the establishment, exercise, or defence of legal claims;

e.     The transfer is necessary to protect your vital interests; or

f.       The Nigerian Data Protection Commission has issued an adequacy decision with respect to the recipient country, territory, or sector.

 Where none of the above applies, we will only transfer your data if the recipient is subject to binding corporate rules, standard contractual clauses, a code of conduct, or a certification mechanism approved by the Commission that provides an adequate level of protection in accordance with the NDPA 2023 and the relevant provisions of the GAID.

Our website contains links to other sites which are controlled by third parties. If you click on these links, KENNA is not to be held responsible for your data and privacy protection. Visiting those websites is not governed by this privacy policy agreement. You should review these other sites’ privacy policies. We do not accept any responsibility for their use of your personal data.

a.  You may opt out at any time by using the unsubscribe facility in any communication we send you, or by contacting us using the details in clause ^17. We will act on your request without undue delay.

 b.  We do not sell your personal data, and we do not share it with third parties for their own direct marketing purposes. If we intend to disclose your data to a third-party service provider for marketing purposes on our behalf, we will inform you.

Our website and Internet Services are not directed at children, and we do not knowingly collect personal data from children. Where we process the personal data of a child, we will obtain the consent of the parent or legal guardian of the child and take reasonable steps to verify the identity of the parent or legal guardian and the authenticity of the consent provided, in accordance with the Act, save where the Act permits processing without such consent.

We will retain your personal data only for as long as is necessary to fulfil the purposes for which it was collected, and in accordance with applicable data protection laws. In determining the appropriate retention period, we will consider the following:

 a.      the amount, nature, and sensitivity of the personal data;

b.     the potential risk of harm from unauthorised use or disclosure;

c.      the purposes for which we process the data and whether those purposes can be achieved through other means;

d.     the applicable legal, regulatory, and professional obligations; and

e.     if the data relates to ongoing litigation, court order or an investigation by law enforcement agencies or our regulators.

 After the applicable retention period, your personal data will be securely deleted or anonymised in accordance with the NDPA 2023 and the GAID.

At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:

 a.   Right of access: you have the right to request a copy of your Personal Data.

 b.   Right of rectification: you have a right to correct data that we hold about you that is inaccurate or incomplete.

 c.    Right to be forgotten: in certain circumstances, you can ask for the data we hold about you to be erased from our records.

 d.    Right to restriction of processing: where certain conditions apply to have a right to restrict the processing.

 e.    Right of portability: you have the right to have the data we hold about you transferred to another organisation.

 f.     Right to object: you have the right to object to certain types of processing, such as direct marketing.

 g.    Right to object to automated processing, including profiling: you also have the right to be subject to the legal effects of automated processing or profiling.

Data Subjects can exercise any of their rights by submitting a request to counsel@kennapartners.ng.  

 Complaints

 In the event that you wish to make a complaint about how your personal data is being processed by KENNA or how your complaint has been handled, you have the right to lodge a complaint directly with the Nigerian Data Protection Commission via info@ndpc.gov.ng and/or KENNA’s assigned Data Protection Officer via counsel@kennapartners.ng. 

Consent

 We use strictly necessary cookies to operate our website https://kennalp.com/ and keep it secure. We will only use non-essential cookies, including analytics, preference, functionality, advertising, marketing, or tracking cookies, where you have given specific, informed, and unambiguous consent through our cookie banner or preference.

 We use strictly necessary cookies to operate our website centre. The cookie banner or preference centre will allow you to accept all optional cookies, reject all optional cookies, or manage your preferences by cookie category. You may withdraw or update your cookie consent at any time through the cookie settings link on our website or by adjusting your browser settings.

 Withdrawal of consent will not affect the lawfulness of any cookie-based processing carried out before your consent was withdrawn.

What are cookies?

 Cookies are text files containing small amounts of information which are downloaded to your device when you visit a website. Cookies are then sent back to the originating web domain on your subsequent visits to that domain. 

 Cookies are useful because they allow a website to recognise a user’s device and improve the user experience. Cookies allow you to navigate between pages efficiently, remember preferences and generally improve the user experience. They can also be used to tailor advertising to your interests through tracking your browsing across websites.

 Session cookies are deleted automatically when you close your browser and persistent cookies remain on your device after the browser is closed (for example to remember your user preferences when you return to the site).

What types of cookies does KENNA use?

 Our website uses both session cookies and persistent cookies. The firm uses session cookies in connection with its Internet Services, specifically for cybersecurity purposes, to provide you with customizations of your experience, such as highlighting your recently viewed items, to detect and remember your language preferences, and track your activities on the Internet Services.

Disabling cookies

 If you do not agree to the use of these cookies, please disable them by following the instructions for your browser or use an automated disabling tool where available. However, disabling strictly necessary cookies may affect the availability or functionality of some services on our website.

 Third party websites

 Please note that the Cookies policy does not apply to, and we are not responsible for, the privacy practices of third-party websites which may be linked to or accessible through this website.

 Changes to the Cookies policy

 We may update the Cookies policy to reflect changes in the cookies or similar technologies used on our website, changes in applicable data protection law or regulatory guidance, changes to our website functionality, or changes to our third-party providers. We will record material changes in the version control record for this Policy and, where required, request renewed consent before using new or materially different non-essential cookies. This Cookies Policy was last updated September 2026.

This Policy will be reviewed and updated as necessary to ensure its continued compliance with applicable data protection laws, regulations and regulatory guidance. KENNA will review this Policy where there is a material change in applicable law or regulatory guidance, our processing activities, website functionality, cookies, analytics or other technologies, or following a significant Personal Data Breach, material complaint, audit finding or any other development that reasonably requires the Policy to be updated.

 Material changes to this Policy, including the effective date of the revised version, will be recorded in the version control record maintained for this Policy. We encourage you to review this Policy periodically for updates.

If you have any questions about this Privacy notice or how we process your personal data, please contact us by sending an email to:  counsel@kennapartners.ng.com , or by writing to:

 The Data Protection Officer
KENNA LP
8 Ogunyemi Road, Oniru
Victoria Island,
Lagos.

Nigeria