Privacy Policy

Last updated: February 2026

TP HOLD CO. Ltd, trading as THE PULSE Nigeria ("we", "us", "our"), is committed to protecting the privacy of everyone who visits our website and uses our services. This Privacy Policy explains how we collect, use, store, and protect your personal data in accordance with the Nigeria Data Protection Act (NDPA) 2023 and the General Application and Implementation Directive (GAID) 2025.

Data Controller: TP HOLD CO. Ltd (THE PULSE Nigeria). Email: [email protected]. Phone: +234 812 222 9102.

1. What Data We Collect

Data you provide directly

When you fill in forms on our website (such as the contact form or partner enquiry form), we may collect: your name, email address, phone number, company or organisation name, and your message or enquiry.

Data collected automatically

When you visit our website, we may automatically collect: your IP address, browser type and version, device type and screen size, pages visited and time spent, referring website, and date and time of your visit.

Cookies and similar technologies

We use cookies and similar technologies on our website. For full details, please see our Cookie Policy.

2. How and Why We Use Your Data

We only process your personal data when we have a lawful basis to do so under the NDPA (Section 25). We use your data for the following purposes: responding to your enquiries (legal basis: consent/contract performance), providing our services (contract performance), understanding how our website is used via analytics cookies (consent), sending newsletters or updates (consent), complying with legal obligations (legal obligation), and protecting vital interests (vital interests).

3. Who We Share Your Data With

We may share your personal data with: our hosting provider Hetzner Online GmbH (servers in Germany — see Section 5 for details), email service providers, analytics services (only with your consent), government or regulatory authorities where required by Nigerian law, and related group companies including THE PULSE Holding GmbH (Germany).

We do not sell your personal data to third parties.

4. How Long We Keep Your Data

We retain your personal data only for as long as necessary, in accordance with the GAID 2025 default storage limitation of 6 months unless there are lawful grounds for longer retention. Contact form submissions are kept for 12 months after we respond, then deleted. Newsletter subscriptions are kept until you unsubscribe, then deleted within 30 days. Analytics data is anonymised after 6 months. Website server logs are kept for 30 days, then deleted.

5. International Data Transfer

Your personal data is stored on servers located in Germany, operated by Hetzner Online GmbH. Germany is a member of the European Union and is subject to the EU General Data Protection Regulation (GDPR), which provides one of the highest standards of data protection in the world.

We have assessed that Germany provides an adequate level of protection for your personal data as required by the Nigeria Data Protection Act 2023 (Sections 41–42). We also maintain a Data Processing Agreement with our hosting provider to ensure your data is handled securely and in accordance with applicable data protection laws.

6. Your Rights

Under the Nigeria Data Protection Act, you have the following rights: Right of Access — you can request a copy of the personal data we hold about you. Right to Rectification — you can ask us to correct inaccurate or incomplete data. Right to Erasure — you can ask us to delete your personal data. Right to Restrict Processing — you can ask us to limit how we use your data. Right to Data Portability — you can request your data in a structured, machine-readable format. Right to Object — you can object to us processing your data, especially for marketing. Right to Withdraw Consent — you can withdraw any consent at any time (this does not affect lawfulness of past processing). Right Regarding Automated Decision-Making — you have the right not to be subject to decisions based solely on automated processing.

To exercise any of these rights, contact us at [email protected]. We will respond within 30 days. There is no fee for reasonable requests.

If you are not satisfied with how we handle your request, you have the right to lodge a complaint with the Nigeria Data Protection Commission (NDPC) at https://ndpc.gov.ng.

7. Children's Data

Our website is not directed at persons under the age of 18. We do not knowingly collect personal data from children. If we become aware that we have collected personal data from a child without appropriate parental consent, we will take steps to delete that information promptly.

8. How We Protect Your Data

We take appropriate technical and organisational measures to protect your personal data, including: HTTPS/SSL encryption on every page, secure hosting with access controls and regular security updates, Data Processing Agreements with all third-party service providers, and access to personal data restricted to authorised personnel only.

9. Changes to This Policy

We may update this Privacy Policy from time to time. When we do, we will update the 'Last updated' date at the top. For significant changes, we will place a notice on our website.

10. Contact Us

Data Protection Officer: Thomas Rieger, Email: [email protected]. If you have concerns about how we handle your personal data, you may contact our Data Protection Officer directly.

If you have concerns about how we handle your personal data, you may contact our Data Protection Officer directly. If you are not satisfied with our response, you have the right to lodge a complaint with the Nigeria Data Protection Commission (NDPC) at https://ndpc.gov.ng.