POLICIES

Privacy Policy

We are committed to protecting the privacy, confidentiality, integrity and security of personal information entrusted to us by our clients, partners, employees and the communities we serve.

Effective Date: 1 July 2026

At Ganttory Ltd ("Ganttory", "we", "our", or "us"), we recognize that trust is fundamental to every relationship we build—with our clients, employees, suppliers, consultants, contractors, investors, development partners, regulators, and the communities we serve.

This Privacy Policy explains how Ganttory collects, uses, stores, secures, transfers, discloses, and otherwise processes personal information in connection with our business operations, professional services, infrastructure projects, digital platforms, supplier relationships, recruitment activities, and stakeholder engagement.

1. Introduction

1.1 Purpose

At Ganttory Ltd ("Ganttory", "we", "our", or "us"), we recognize that trust is fundamental to every relationship we build—with our clients, employees, suppliers, consultants, contractors, investors, development partners, regulators, and the communities we serve.

As an integrated infrastructure development company operating across Sub-Saharan Africa, we understand that responsible stewardship of information is essential to delivering projects with integrity, professionalism, and accountability.

This Privacy Policy explains how Ganttory collects, uses, stores, secures, transfers, discloses, and otherwise processes personal information in connection with our business operations, professional services, infrastructure projects, digital platforms, supplier relationships, recruitment activities, and stakeholder engagement.

Privacy is embedded into the way we conduct business. We are committed to protecting personal information through robust governance, internationally recognized security practices, and compliance with applicable data protection laws wherever we operate.

1.2 Objectives

This Policy aims to:

  • Explain what personal information Ganttory collects.
  • Describe how and why personal information is processed.
  • Outline the legal basis upon which personal information is processed.
  • Describe how information is protected.
  • Explain the circumstances in which information may be shared.
  • Inform individuals of their rights.
  • Demonstrate Ganttory's commitment to internationally recognized privacy principles.


1.3 Applicability

This Policy applies to:

  • Website visitors
  • Clients
  • Prospective clients
  • Suppliers
  • Contractors
  • Consultants
  • Employees
  • Job applicants
  • Investors
  • Development partners
  • Government agencies
  • Community stakeholders
  • Individuals interacting with Ganttory in any capacity
2. Our Privacy Commitment

Privacy is fundamental to maintaining trust. Ganttory is committed to ensuring that all personal information entrusted to us is processed responsibly, securely, transparently, and in accordance with applicable legal and ethical standards.


Commitment
Description

Lawfulness

Process information only where a lawful basis exists.

Fairness

Handle information in ways individuals reasonably expect.

Transparency

Clearly explain how information is collected and used.

Data Minimization

Collect only information necessary for legitimate business purposes.

Security

Protect information through appropriate technical and organizational safeguards.

Accountability

Hold ourselves accountable for responsible information management.

Integrity

Process information honestly and ethically.

Confidentiality

Restrict access to authorized personnel only.

Continuous Improvement

Regularly review and strengthen our privacy programme.

Privacy considerations are incorporated into project planning, digital systems, procurement processes, supplier management, and operational decision-making.

3. Scope

3.1 Business Activities

This Privacy Policy applies to all personal information processed by Ganttory in connection with:

  • Infrastructure development
  • Engineering
  • Procurement
  • Engineering, Procurement & Construction (EPC)
  • Project Development
  • Project Management
  • Infrastructure Advisory
  • Operations Support
  • Renewable Energy Development
  • Technical Consulting
  • Commercial Advisory
  • Business Development
  • Corporate Administration


3.2 Channels Covered

This Policy applies regardless of how information is collected, including through:

  • Corporate website
  • Project enquiry forms
  • Contact forms
  • Proposal submissions
  • Client engagements
  • Procurement portals
  • Recruitment portals
  • Email correspondence
  • Telephone communications
  • Social media
  • Events
  • Conferences
  • Mobile applications
  • Collaboration platforms
  • Physical documentation
  • Site visits
  • Security systems
  • CCTV (where applicable)


3.3 Geographic Scope

This Privacy Policy applies across all jurisdictions in which Ganttory operates or conducts business.

Where local legislation imposes additional privacy obligations, Ganttory will comply with those requirements in addition to this Policy.

4. Who We Are

Ganttory is an integrated infrastructure development company that develops and delivers infrastructure to power economies, strengthen industries, and improve communities across Sub-Saharan Africa.

We help governments, businesses, investors, and development partners transform ambitious ideas into resilient, commercially viable infrastructure through a disciplined approach to project development, engineering, procurement, construction (EPC), project management, infrastructure advisory, and long-term operational support.

Our multidisciplinary capabilities span the entire infrastructure lifecycle—from strategic planning, feasibility studies, commercial structuring, engineering, procurement, construction, commissioning, operations support, and asset optimization.

We provide integrated infrastructure solutions across a broad range of sectors including:

Sector
Examples

Energy

Renewable Energy, Grid Infrastructure, Battery Energy Storage

Industrial

Manufacturing Facilities, Industrial Utilities

Commercial

Commercial Buildings, Mixed-Use Developments

Public Infrastructure

Government Projects, Public Facilities

Telecommunications

Communications Infrastructure

Water

Water Supply and Treatment

Healthcare

Hospitals and Medical Facilities

Education

Schools and Universities

Mining

Mining Infrastructure

Agriculture

Agricultural Infrastructure

Real Estate

Infrastructure for Property Developments

As a trusted infrastructure partner, Ganttory is committed to delivering projects safely, responsibly, and sustainably while upholding the highest standards of governance, engineering excellence, environmental stewardship, ethical conduct, and data protection.

5. Guiding Privacy Principles

Ganttory's privacy programme is founded on internationally recognized principles.

Principle
Description

Lawfulness

Personal information is processed only where an appropriate legal basis exists.

Fairness

Information is handled fairly and without prejudice.

Transparency

Individuals are informed about how their information is used.

Purpose Limitation

Information is collected only for specific, explicit, and legitimate purposes.

Data Minimization

Only the minimum information necessary is collected.

Accuracy

Information is maintained accurately and kept up to date where practical.

Storage Limitation

Information is retained only as long as necessary.

Integrity & Confidentiality

Appropriate safeguards protect information against unauthorized access or misuse.

Accountability

Ganttory accepts responsibility for compliance with this Policy.

Privacy by Design

Privacy considerations are incorporated into systems, processes, and projects from the outset.

Privacy by Default

Systems are configured to collect and process only the information necessary for their intended purpose.

6. Information We Collect

Depending on the nature of your relationship with Ganttory, we may collect the following categories of personal information.

Category
Examples

Identity Information

Name, title, nationality, government-issued identification (where required), photograph

Contact Information

Email address, telephone number, mailing address, business address

Professional Information

Employer, job title, qualifications, certifications, licenses, professional memberships

Commercial Information

Contracts, invoices, quotations, purchase orders, financial records

Project Information

Project enquiries, technical specifications, budgets, project documentation

Recruitment Information

CVs, references, qualifications, interview notes, employment history

Supplier Information

Company details, contact persons, banking information, tax information

Technical Information

IP address, browser type, operating system, device information, cookies

Website Usage Information

Pages visited, referral source, session duration, downloads

Marketing Information

Event registrations, newsletter preferences, communication preferences

Security Information

Visitor logs, access records, CCTV footage where applicable

Other Information

Any information voluntarily provided through correspondence or project engagements

Special Categories of Personal Information

Where required for legitimate business purposes and permitted by law, Ganttory may process limited categories of sensitive personal information, such as health or accessibility information required for workplace safety, project site access, or legal compliance. Such information will be subject to enhanced safeguards and processed only where there is an appropriate legal basis.

7. How We Collect Information

7.1 General Principles

Ganttory collects personal information in a transparent and lawful manner and only where it is necessary for legitimate business purposes.

Where required by applicable law, we will inform individuals about the collection of their personal information before or at the time of collection.

We do not knowingly collect information using deceptive or misleading practices.

7.2 Information You Provide

We collect information directly from you when you voluntarily provide it, including when you:

  • Complete contact or enquiry forms
  • Request a proposal or quotation
  • Engage our professional services
  • Submit project documentation
  • Register for events or webinars
  • Subscribe to newsletters
  • Download publications
  • Apply for employment
  • Register as a supplier
  • Participate in surveys
  • Contact us by telephone or email
  • Visit our offices
  • Participate in meetings or workshops


7.3 Information Collected Automatically

When you visit our website, certain information may be collected automatically through technologies such as cookies, server logs, and analytics tools.

Category
Examples

Device Information

Device type, operating system

Browser Information

Browser version and language

Technical Information

IP address, session ID

Usage Information

Pages visited, time spent, clicks

Location Information

Approximate geographic location derived from IP address

Security Information

Failed login attempts, suspicious activity

7.4 Information from Third Parties

Where appropriate and lawful, we may receive information from:

  • Clients
  • Government agencies
  • Regulatory authorities
  • Professional advisers
  • Recruitment partners
  • Business partners
  • Public company registers
  • Credit reference agencies
  • Financial institutions
  • Development finance institutions
  • Professional networking platforms
  • Due diligence providers


Such information will only be processed where there is a lawful basis.


7.5 CCTV and Physical Security

Where CCTV systems operate at our offices, project sites, or facilities, recordings may be collected for purposes including:

  • Security
  • Incident investigation
  • Health & Safety
  • Asset protection
  • Regulatory compliance

Appropriate signage will be displayed where CCTV monitoring is in operation.

7.6 Recruitment

Applicants may provide:

  • Curriculum Vitae
  • Cover Letters
  • Academic qualifications
  • Professional certifications
  • Employment history
  • References
  • Background verification information (where applicable)

Recruitment information is processed solely for evaluating employment opportunities and workforce planning.

8. How We Use Your Information

Personal information is processed only where necessary to conduct our business and fulfil our legal, contractual, and professional responsibilities.

8.1 Service Delivery

We use information to:

  • Deliver engineering services
  • Manage EPC projects
  • Develop infrastructure projects
  • Conduct technical assessments
  • Deliver advisory services
  • Execute procurement activities
  • Manage contracts
  • Coordinate project teams
  • Commission completed assets
  • Provide operations support

8.2 Relationship Management

Information enables us to:

  • Respond to enquiries
  • Prepare proposals
  • Maintain client relationships
  • Communicate project updates
  • Manage stakeholder engagement
  • Provide customer support

8.3 Supplier Management

We process supplier information to:

  • Conduct due diligence
  • Evaluate capability
  • Administer procurement
  • Manage contracts
  • Process payments
  • Monitor supplier performance

8.4 Recruitment

Information is used to:

  • Evaluate candidates
  • Verify qualifications
  • Conduct interviews
  • Contact references
  • Perform background screening where lawful
  • Make employment decisions

8.5 Business Development

Information may be used to:

  • Share industry insights
  • Invite individuals to events
  • Respond to partnership opportunities
  • Communicate company updates
  • Send newsletters (where consent has been provided where required)

8.6 Legal & Regulatory Compliance

We process information where necessary to:

  • Comply with legislation
  • Respond to lawful requests
  • Meet contractual obligations
  • Maintain financial records
  • Conduct audits
  • Meet tax obligations
  • Prevent fraud

8.7 Security

Information helps us:

  • Protect systems
  • Detect cyber threats
  • Investigate incidents
  • Protect personnel
  • Secure project sites
  • Maintain business continuity

8.8 Analytics and Improvement

Information may be analysed to improve:

  • Website performance
  • Digital services
  • Customer experience
  • Project delivery
  • Operational efficiency
  • Cybersecurity

Analytics are generally performed using aggregated or anonymized information wherever practicable.

9. Legal Basis for Processing

Where applicable, including under the General Data Protection Regulation (GDPR), Ganttory processes personal information only where an appropriate legal basis exists.

Legal Basis
Examples

Contract

Delivering engineering or EPC services, supplier agreements, employment contracts

Legal Obligation

Tax reporting, health & safety compliance, anti-money laundering requirements

Legitimate Interests

Business development, fraud prevention, cybersecurity, stakeholder engagement

Consent

Marketing communications, optional cookies, event registrations where required

Vital Interests 

Emergency situations involving health or safety

Public Interest

Activities undertaken in support of government infrastructure or statutory obligations where applicable

Where processing is based on consent, consent may be withdrawn at any time. Withdrawal does not affect processing carried out before withdrawal.

10. International Data Transfers

As an infrastructure company operating across multiple jurisdictions, personal information may be transferred to or accessed from countries outside the jurisdiction in which it was originally collected.

International transfers may occur where necessary to:

  • Deliver projects
  • Support multinational clients
  • Engage international consultants
  • Utilize secure cloud services
  • Coordinate cross-border teams
  • Meet legal or contractual obligations

Where transfers occur, Ganttory implements appropriate safeguards, including:

  • Standard Contractual Clauses (SCCs)
  • Data Processing Agreements
  • Confidentiality obligations
  • Encryption in transit and at rest where appropriate
  • Vendor security assessments
  • International transfer impact assessments where required
  • Other lawful transfer mechanisms recognized under applicable legislation

We take reasonable measures to ensure that transferred personal information receives a level of protection substantially equivalent to that provided under this Policy.

11. Sharing Information

Ganttory does not sell personal information.

Personal information may be shared only where necessary and subject to appropriate contractual, legal, or regulatory safeguards.

Information may be disclosed to:

Employees: Project delivery and administration

Consultants: Professional services

Contractors: Project execution

Suppliers: Procurement activities

Financial Institutions: Payment processing

Auditors: Financial and compliance audits

Insurers: Insurance administration

Cloud Service Providers: Secure hosting and collaboration

IT Providers: System administration

Legal Advisers: Legal representation

Regulators: Compliance with legal obligations

Courts and Law Enforcement: Where legally required

Development Finance Institutions: Due diligence, financing, monitoring

Investors and Lenders: Transaction due diligence, subject to confidentiality obligations

Every third party processing personal information on behalf of Ganttory is expected to implement security measures appropriate to the nature of the information processed and comply with applicable contractual and legal obligations.

12. Data Security

Protecting personal information is a fundamental responsibility across Ganttory.

We maintain administrative, technical, physical, and organizational safeguards designed to protect information against unauthorized access, disclosure, alteration, destruction, loss, or misuse.

Our information security framework includes:

Governance: Information security policies and oversight

Access Control: Role-based access, least-privilege principles, multi-factor authentication where appropriate

Network Security: Firewalls, intrusion detection, secure remote access

Encryption: Encryption during transmission and, where appropriate, at rest

Monitoring: Security logging, vulnerability monitoring, threat detection

Physical Security: Controlled office and project site access, visitor management

Vendor Management: Security assessments and contractual obligations for third-party providers

Incident Response: Procedures for detecting, responding to, and recovering from security incidents

Training: Regular employee awareness and privacy training

Business Continuity: Backup, disaster recovery, and resilience planning

Despite these safeguards, no method of transmission over the internet or electronic storage is completely secure. Ganttory therefore cannot guarantee absolute security but continually reviews and enhances its controls to address evolving risks.

Security Incident Management

Where a security incident involving personal information occurs, Ganttory will:

  1. Assess the nature and scope of the incident.
  2. Contain and mitigate the impact.
  3. Investigate the root cause.
  4. Notify affected individuals and competent authorities where required by applicable law.
  5. Implement corrective actions to reduce the likelihood of recurrence.
13. Data Retention

13.1 Retention Principles

Ganttory retains personal information only for as long as necessary to fulfil the purposes for which it was collected, including the delivery of professional services, compliance with contractual obligations, protection of legitimate business interests, and compliance with applicable legal and regulatory requirements.

Personal information will not be retained indefinitely. Once retention is no longer necessary, information will be securely deleted, anonymized, or destroyed using methods appropriate to the sensitivity of the information.

Retention decisions are based on:

  • Applicable legal and regulatory requirements
  • Contractual obligations
  • Statutory limitation periods
  • Business and operational needs
  • Ongoing litigation, investigations, or audits
  • Information security requirements
  • Industry best practices

13.2 Typical Retention Periods

Client Contracts: Duration of contract plus applicable statutory limitation period

Project Documentation: Project lifecycle plus contractual and legal retention requirements

Financial Records: In accordance with applicable tax and financial reporting laws

Recruitment Records: As permitted under applicable employment laws

Supplier Records: Duration of supplier relationship plus legal retention period

Marketing Records: Until consent is withdrawn or the information is no longer required

Website Analytics: In accordance with our Cookie Policy and operational requirements

Security Logs: Based on operational and cybersecurity requirements

CCTV Recordings: As required for security purposes unless retained for investigations

Retention periods may be extended where reasonably necessary to establish, exercise, or defend legal claims.

14. Your Rights

Ganttory respects the privacy rights of individuals.

Subject to applicable law, individuals whose personal information we process may have the following rights.


14.1 Right of Access

You may request confirmation as to whether Ganttory processes your personal information and obtain access to that information together with certain additional information regarding its processing.


14.2 Right to Rectification

You may request that inaccurate or incomplete personal information be corrected or updated.


14.3 Right to Erasure

Where permitted by applicable law, you may request the deletion of your personal information where:

  • The information is no longer required.
  • Consent has been withdrawn and no alternative legal basis exists.
  • Processing is unlawful.
  • Deletion is required by law.

This right may be limited where Ganttory has overriding legal or contractual obligations requiring continued retention.


14.4 Right to Restrict Processing

You may request that processing be restricted under circumstances prescribed by applicable law.


14.5 Right to Object

You may object to certain processing activities, including processing based upon legitimate interests or direct marketing.

Ganttory will carefully consider every objection in accordance with applicable legislation.


14.6 Right to Data Portability

Where applicable, you may request that personal information be provided in a structured, commonly used, and machine-readable format or transmitted to another organization where technically feasible.


14.7 Right to Withdraw Consent

Where processing relies upon consent, you may withdraw consent at any time.

Withdrawal does not affect the lawfulness of processing undertaken before consent was withdrawn.


14.8 Exercising Your Rights

Requests relating to personal information should be submitted to:

Legal & Compliance

Email: privacy@ganttory.com

Ganttory may request additional information necessary to verify identity before responding.

15. Marketing Communications

Ganttory may communicate with clients, suppliers, investors, partners, and other stakeholders regarding:

  • Company news
  • Industry insights
  • Technical publications
  • Events
  • Webinars
  • Service updates
  • Business opportunities

Where required by applicable law, such communications will only be sent with appropriate consent.

Recipients may unsubscribe at any time using the unsubscribe link included in electronic communications or by contacting us directly.

Operational communications relating to projects, contracts, safety, regulatory matters, or legal obligations may continue where necessary.

16. Cookie and Similar Technologies

Our website uses cookies and similar technologies to enhance functionality, improve user experience, understand website usage, maintain security, and support analytics.

Cookies may include:

Essential Cookies: Enable core website functionality

Functional Cookies: Remember user preferences

Performance Cookies: Improve website performance

Analytics Cookies: Measure website usage and effectiveness

Security Cookies: Detect suspicious activity and maintain website security

Users may manage cookie preferences through their browser settings or our Cookie Preference Centre where available.

17. Third-Party Websites

Our website may contain links to third-party websites operated independently from Ganttory.

These websites maintain their own privacy practices and policies.

Ganttory is not responsible for:

  • Third-party privacy practices
  • Third-party security controls
  • Third-party content
  • Information collected after leaving our website


Users are encouraged to review the privacy policies of all third-party websites before providing personal information.

18. Children’s Privacy

Ganttory's services are designed primarily for governments, businesses, institutions, investors, suppliers, and professional stakeholders.

We do not knowingly collect personal information from children unless required in connection with community development initiatives or where authorized by applicable law.

Where we become aware that personal information relating to a child has been collected unintentionally without appropriate authorization, reasonable steps will be taken to delete the information promptly.

19. Changes To This Privacy Policy

This Privacy Policy may be updated periodically to reflect changes in:

  • Applicable legislation
  • Regulatory guidance
  • Technology
  • Business operations
  • Information security practices
  • International best practice

The latest version will always be published on the Ganttory website.

Where material changes significantly affect the way personal information is processed, Ganttory may provide additional notice where appropriate.

20. Governing Standards

Ganttory's privacy programme is informed by internationally recognized legal, regulatory, and governance frameworks, including, where applicable:

  • General Data Protection Regulation (GDPR)
  • UK General Data Protection Regulation
  • Nigeria Data Protection Act (NDPA)
  • OECD Privacy Guidelines
  • ISO/IEC 27001 – Information Security Management Systems
  • ISO/IEC 27701 – Privacy Information Management Systems
  • ISO 37301 – Compliance Management Systems
  • ISO 31000 – Risk Management
  • ISO 9001 – Quality Management Systems
  • United Nations Global Compact Principles
  • Applicable privacy legislation in jurisdictions where Ganttory operates

Where local legislation imposes more stringent requirements than this Policy, Ganttory will comply with those requirements.

21. Contact Us

Questions regarding this Privacy Policy or Ganttory's privacy practices may be directed to:

Legal & Compliance

Ganttory Ltd

Email: privacy@ganttory.com

Website: www.ganttory.com

Correspondence relating to privacy matters should include sufficient information to enable Ganttory to identify the request and verify the identity of the requester where appropriate.

22. Effective Date

This Privacy Policy is effective from July 1st 2026 and supersedes all previous versions relating to the processing of personal information by Ganttory.

This Policy shall be reviewed at least annually or more frequently where changes in law, regulation, technology, or business operations require amendment.

APPENDIX A – Personal Information Processing Schedule

Category of Personal Information
Examples
Purpose of Processing
Lawful Basis (where applicable)
Typical Recipients
Typical Retention

Identity Information

Name, title, identification documents

Identity verification, contracts

Contract, Legal Obligation

Internal project teams

Contract period + statutory retention

Contact Information

Email, telephone, address

Communications

Contract, Legitimate Interest

Employees, service providers

Duration of relationship

Professional Information

Employer, qualifications, certifications

Project delivery

Contract, Legitimate Interest

Project teams

Business relationship

Commercial Information

Contracts, invoices, purchase orders

Financial administration

Contract, Legal Obligation

Finance, auditors

Statutory financial retention

Recruitment Information

CVs, interview notes

Recruitment

Consent, Legitimate Interest

HR

Recruitment retention period

Supplier Information

Banking details, company records

Procurement

Contract

Procurement & Finance

Supplier relationship

Technical Information

IP address, browser

Website administration

Legitimate Interest

IT providers

Operational retention

Website Usage

Analytics

Website improvement

Legitimate Interest, Consent

Analytics providers

Cookie retention schedule

Security Information

Visitor logs, CCTV

Security

Legitimate Interest

Security personnel

Security retention period

APPENDIX B – Definitions

Category of Personal Information
Examples

Applicable Data Protection Laws

All privacy and data protection legislation applicable to Ganttory's operations, including GDPR, UK GDPR, NDPA, and equivalent laws.

Business Partner

Any client, government entity, contractor, consultant, supplier, investor, financier, or development partner with whom Ganttory conducts business.

Consent

A freely given, specific, informed, and unambiguous indication of an individual's agreement to the processing of personal information.

Controller

The natural or legal person determining the purposes and means of processing personal information.

Data Subject

An identified or identifiable natural person whose personal information is processed.

Personal Information

Any information relating to an identified or identifiable individual.

Processing

Any operation performed on personal information, including collection, storage, use, disclosure, transfer, restriction, deletion, or destruction.

Processor

A natural or legal person that processes personal information on behalf of a Controller.

Professional Services

Infrastructure development, engineering, procurement, EPC, project management, infrastructure advisory, operations support, and related services provided by Ganttory.

Sensitive Personal Information

Categories of personal information requiring enhanced protection under applicable law, such as health information or biometric data

Third Party

Any individual or organization other than the Data Subject, Ganttory, or persons acting under Ganttory's direct authority.