Privacy Policy

Effective Date: 15 September 2026  ·  thomasmacaulaypangea.com

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:

References to “the Group” include these entities.

2. Information We Collect

We collect personal information that you choose to provide to us, including:

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:

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:

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:

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.