Privacy Policy
1. Who We Are
This Privacy Policy explains how the Thomas Macaulay Pangea Group (“TMPG”, “we”, “us”) collects, uses, and protects personal information provided through thomasmacaulaypangea.com (the “Website”).
The entities responsible for personal information collected via the Website are:
- Thomas Macaulay Pangea Group Ltd — Global Business Licence company incorporated in Mauritius and regulated by the Financial Services Commission (FSC) of Mauritius;
- Thomas Macaulay Capital Limited — capital market operator (Issuing House) regulated by the Securities and Exchange Commission of Nigeria (SEC Nigeria); and
- Pangea Global Investments Inc. — incorporated under the Canada Business Corporations Act (CBCA), Ontario.
References to “the Group” include these entities.
2. Information We Collect
We collect personal information that you choose to provide to us, including:
- Enquiry details submitted through the Website’s enquiry form or by email, including your full name, organisation, email address, nature of enquiry, and message;
- Correspondence and any information you provide when communicating with any Group mailbox or representative; and
- Business information you provide in the course of an engagement, investor conversation, or application.
Please do not submit confidential or sensitive information through the general enquiry form. Where an engagement requires the exchange of sensitive material, we will direct you to an appropriate channel.
3. How We Use Your Information
We use personal information to:
- respond to, route, and manage enquiries addressed to the Group;
- assess and pursue business, investment, and career opportunities;
- comply with legal, regulatory, and professional obligations, including requirements of SEC Nigeria and the FSC Mauritius;
- maintain the security and integrity of the Website and Group communications; and
- keep records as required for the operation of the Group’s business.
4. Legal Bases for Processing
Depending on the Group entity involved and your jurisdiction, we process personal information on the following bases: your consent; our legitimate interests in operating the Group’s business and responding to enquiries; compliance with legal and regulatory obligations; and, where applicable, the performance of a contract or steps prior to entering into one.
Processing of Nigerian personal data is carried out in accordance with the Nigeria Data Protection Act 2023 and applicable regulations; processing of Mauritian personal data in accordance with the Data Protection Act 2017 of Mauritius; and processing of Canadian personal data in accordance with applicable Canadian privacy legislation.
5. Disclosure of Your Information
We do not sell personal information. We may disclose personal information:
- within the Group, where reasonably required to handle your enquiry or operate the Group’s business;
- to regulators, courts, law enforcement, or public authorities where required by law or regulation, including SEC Nigeria and the FSC Mauritius;
- to professional advisers (including legal, audit, and compliance advisers) under duties of confidentiality; and
- to service providers who support our communications and information technology, under contractual protections.
6. International Transfers
As a cross-border group, personal information may be transferred to and processed in Nigeria, Canada, Mauritius, and other jurisdictions in which the Group or its service providers operate. Where personal information is transferred across borders, we apply appropriate safeguards consistent with applicable data protection laws.
7. Retention
We retain personal information only for as long as is necessary to fulfil the purposes described in this Policy, to manage our relationship with you, and to meet legal, regulatory, and record-keeping requirements. Enquiry records are retained for a reasonable period following our final response, after which they are securely deleted or anonymised.
8. Your Rights
Subject to applicable law, you have the right to:
- request access to the personal information we hold about you;
- request correction of inaccurate or incomplete personal information;
- request deletion of personal information, subject to legal and regulatory retention requirements;
- object to or request restriction of processing;
- withdraw consent where processing is based on consent; and
- lodge a complaint with the applicable data protection supervisory authority.
To exercise any of these rights, contact us using the details in Section 10. We may require verification of your identity before acting on a request.
9. Cookies and Similar Technologies
The Website is informational and does not use advertising, analytics, or third-party tracking cookies. Enquiries submitted through the Website are handled by email.
10. How to Contact Us
Questions, requests, or complaints regarding this Policy or our handling of personal information may be directed to info@thomasmacaulaypangea.com.
11. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. The current version will always be published on this page with its effective date.