Privacy Policy

Virgin Forest Energy Limited is a wholly indigenous Nigerian energy company engaged in the procurement, importation, marketing, storage, distribution and transportation of refined petroleum products, depot operations, trucking, LPG solutions and retail fuel services across Nigeria.

For the purposes of applicable data protection legislation, Virgin Forest Energy Limited is the Data Controller responsible for determining the purposes and means of processing personal information.

Registered Office

This Privacy Policy applies to all personal information collected through:

• Our corporate website;
• Contact and business enquiry forms;
• Email and telephone communications;
• Customer and supplier engagements;
• Vendor registration processes;
• Recruitment and employment applications;
• Newsletter subscriptions;
• Physical visits to our offices; and
• Any other interaction with Virgin Forest Energy Limited.

This Policy applies whether personal information is collected electronically, verbally or in physical form.

We collect only the personal information that is necessary for legitimate business, contractual, operational and regulatory purposes.

Information You Provide Directly

Depending on your interaction with us, we may collect:

• Full name;
• Email address;
• Mobile or office telephone number;
• Company or organisation;
• Job title or designation;
• Business or residential address;
• Service enquiry or message;
• Curriculum Vitae (CV);
• Educational and professional qualifications;
• Employment history;
• References; and
• Any other information voluntarily included in correspondence with us.

Information Collected Automatically

When you access our website, certain technical information may be collected automatically, including:

• Internet Protocol (IP) address;
• Browser type and version;
• Device information;
• Operating system;
• Pages visited;
• Date and time of access;
• Referral source;
• Website usage statistics; and
• Cookie preference settings.

This information helps us improve website functionality, maintain security and better understand how visitors use our digital services.

Virgin Forest Energy collects personal information through lawful and transparent means.

We collect information when you:

• Submit an enquiry through our Contact Us form;
• Request a quotation or business consultation;
• Subscribe to our newsletter;
• Apply for employment opportunities;
• Communicate with us by email or telephone;
• Register as a supplier or contractor;
• Visit our offices or attend business meetings; or
• Use our website and related digital services.

We may also collect limited technical information through cookies and similar technologies. Details of these technologies are available in our Cookie Policy.

We process personal information only for specified, legitimate and lawful purposes.

Your information may be used to:

• Respond to enquiries and customer requests;
• Provide quotations and petroleum supply services;
• Deliver our products and services;
• Manage contracts and commercial relationships;
• Process supplier and vendor engagements;
• Recruit and assess employment applicants;
• Communicate operational or service-related updates;
• Improve our website and customer experience;
• Maintain cybersecurity and prevent fraud;
• Comply with legal and regulatory obligations; and
• Protect the safety, security and integrity of our business operations.

We will not process your personal information for purposes that are incompatible with those described in this Policy without notifying you or obtaining another lawful basis where required.

Virgin Forest Energy processes personal information only where a lawful basis exists under the Nigeria Data Protection Act.

Depending on the nature of the processing activity, the lawful basis may include:

• Your consent;
• The performance of a contract;
• Steps taken prior to entering into a contract;
• Compliance with a legal obligation;
• Protection of vital interests; or
• Our legitimate business interests provided such interests do not override your fundamental rights and freedoms.

Where consent is relied upon, it will be freely given, informed, specific and capable of being withdrawn at any time.

Virgin Forest Energy respects your communication preferences.

Where you subscribe to newsletters or request corporate updates, we will use your contact details solely for that purpose. You may withdraw your consent or unsubscribe at any time by contacting our Privacy Office or using the unsubscribe option included in our communications.

Virgin Forest Energy treats all personal information as confidential.

We may disclose personal information only where necessary to:

• Government and regulatory authorities;
• Financial institutions;
• Professional advisers and external auditors;
• Logistics and operational partners;
• Cloud and information technology service providers;
• Insurance providers; and
• Other service providers acting on our behalf under appropriate contractual safeguards.

We do not sell, rent or trade personal information.

Every third party processing personal information on our behalf is required to implement appropriate technical and organisational measures to protect your information.

Certain technology services used to support our business operations may process personal information outside Nigeria.

Where personal data is transferred internationally, Virgin Forest Energy Limited will ensure that appropriate safeguards are implemented in accordance with the Nigeria Data Protection Act 2023. Such safeguards may include contractual data protection clauses, encryption, access controls and other lawful transfer mechanisms recognised under applicable legislation.

We will not transfer personal information internationally unless an appropriate level of protection is maintained.

Virgin Forest Energy retains personal information only for as long as necessary to fulfil the purpose for which it was collected and to comply with legal, contractual and regulatory obligations.

Where litigation, investigations or regulatory proceedings are ongoing, relevant records may be retained until the matter has been concluded.

Upon expiry of the applicable retention period, personal information is securely deleted or anonymised.

Under the Nigeria Data Protection Act, you have the right to:

• Be informed about how your personal information is processed;
• Request access to the personal information we hold about you;
• Request correction of inaccurate or incomplete information;
• Request deletion where lawful grounds exist;
• Restrict or object to certain processing activities;
• Withdraw your consent where processing is based on consent;
• Request the portability of your personal information where applicable; and
• Lodge a complaint with the Nigeria Data Protection Commission if you believe your privacy rights have been infringed.

Virgin Forest Energy implements appropriate technical and organisational measures to protect personal information against accidental loss, unauthorised access, disclosure, alteration and destruction.

These measures include:

• Secure HTTPS encryption;
• Firewall and network monitoring;
• Role-based access controls;
• Secure cloud infrastructure;
• Vulnerability assessment and patch management;
• Confidentiality obligations for authorised personnel; and
• Regular information security monitoring.

While we continually strengthen our security controls, no method of electronic transmission or storage can be guaranteed to be completely secure.

Our website and services are intended for business and general informational purposes and are not directed at children under the age of 18 years.

We do not knowingly collect personal information from children. Where we become aware that information relating to a child has been collected inadvertently, it will be deleted or anonymised without undue delay unless retention is required by law.

Virgin Forest Energy Limited does not use your personal information to carry out automated decision-making or profiling that produces legal or similarly significant effects on individuals. Any decisions relating to customers, employees, suppliers or applicants involve appropriate human review.

Our website may contain links to third-party websites or services for your convenience.

Virgin Forest Energy is not responsible for the privacy practices, security or content of external websites. We encourage users to review the privacy policies of any third-party websites they visit before providing personal information.

Virgin Forest Energy Limited maintains an effective privacy governance framework to ensure that personal information is processed lawfully, fairly and transparently.

This Privacy Policy is reviewed at least once every twelve (12) months, or earlier where there are material changes to:

• Applicable data protection legislation or regulatory guidance;
• Business operations or digital services;
• Information security or cybersecurity practices;
• Third-party service providers; or
• The categories of personal information processed by the Company.

The Compliance & Legal Department is responsible for overseeing the implementation and periodic review of this Privacy Policy.

Virgin Forest Energy Limited may update this Privacy Policy from time to time to reflect changes in legislation, regulatory guidance, technological developments or business operations.

Any amendments will become effective immediately upon publication on this page, and the Effective Date at the top of this Policy will be updated accordingly. We encourage visitors to review this Policy periodically to remain informed about how their personal information is protected.

If you have any questions about this Privacy Policy, wish to exercise your privacy rights, or would like to make a complaint regarding the processing of your personal information, please contact:

Privacy Office