Privacy Notice

1. Introduction

Commodore Sports Agency Limited - RC. 9656961 ("Commodore Sports Agency", "we", "us" or "our") respects your privacy and is committed to processing personal data lawfully, fairly, transparently and securely. This Privacy Notice explains how we collect, use, disclose, retain and protect personal data obtained through Commodoresports.org and/or CommodoreGrandPrix.com (the "Website") and through communications initiated from the Website (s).

This Notice is prepared with regard to the Nigeria Data Protection Act 2023, the Nigeria Data Protection Act - General Application and Implementation Directive 2025, and other applicable Nigerian data-protection and professional obligations.

2. Who is responsible for your personal data?

Commodore Sports Agency Limited is the data controller for personal data processed through the Website, except where another organisation determines the purposes and means of a particular processing activity.

3. Scope of this Notice

This Notice applies to Website visitors, persons who contact us through the Website, newsletter subscribers and persons who communicate with us using Website links.

4. Personal data we may collect

Depending on how you use the Website, we may collect:

• Identity and contact data, such as your name, email address, telephone number, and organisation.
• Enquiry data and non-confidential description you submit through our contact form.
• Communication data, including correspondence, call records and follow-up communications.
• Newsletter data, including your email address, subscription preferences and unsubscribe status.
• Technical data, such as IP address, browser type, device type, operating system, referral source and request logs.
• Usage data, such as pages viewed, links selected, visit dates and times, interaction events and consent preferences.
• Any other information you choose to provide, subject to the warnings in section 7 below.

5. How we collect personal data

We collect personal data:

• directly from you when you complete a form, subscribe to updates, call, email or contact us through a Website link;
• automatically through server logs, cookies, pixels, event-reporting tools and similar technologies;
• from third-party platforms that you choose to use, and
• from publicly available sources or persons involved in a proposed instruction where necessary for governance, conflict checks, client acceptance, and/or legal compliance.

6. Why we process personal data and our lawful bases

7. Do not submit confidential or sensitive information

The Website form is intended for first contact and initial inquiries. Please do not submit privileged documents, identification numbers, financial account information, medical information, passwords, trade secrets or other confidential or sensitive material through the Website.

8. Sharing personal data

We do not sell personal data. We may disclose personal data only where reasonably necessary to:

• authorised partners, lawyers, employees and consultants who need it for the relevant purpose and are subject to confidentiality obligations;
• technology and professional service providers that support hosting, forms, communications, security, analytics, document management, accounting or professional advice;
• courts, regulators, law-enforcement bodies, public authorities or other persons where disclosure is required or permitted by law;
• persons involved in a reorganisation, merger or transfer of the firm's business, subject to appropriate confidentiality and legal safeguards; or
• another person with your consent or at your direction.

9. International transfers

Some technology providers or their sub-processors may process or store personal data outside Nigeria. Where personal data is transferred internationally, we take reasonable steps to ensure that the transfer is made in accordance with applicable Nigerian data-protection law, including through an adequacy basis, an approved or appropriate transfer instrument, contractual and organisational safeguards, another lawful transfer basis, or your informed consent where legally appropriate.

You may contact us for available information about the safeguards relevant to a particular transfer.

10. Retention

We retain personal data only for as long as reasonably necessary for the purpose for which it was collected and to meet legal, regulatory, professional, accounting, security and claims-management requirements. Our general approach is:

• Enquiries that do not result in an engagement: ordinarily up to 12 months after the last substantive communication, unless a longer period is reasonably necessary for conflict, complaint, security or legal-claim purposes.
• Newsletter records: until you unsubscribe, after which we may retain minimal suppression information to honour your choice.
• Technical and security logs: for the period configured by the relevant system and reasonably necessary for security, diagnostics and legal compliance.
• Client and athletes records: under the applicable engagement terms and the firm's professional and records-retention obligations.

We may retain anonymised information that no longer identifies an individual.

11. Security

We use reasonable technical and organisational measures designed to protect personal data against unauthorised access, alteration, disclosure, loss or destruction. These measures may include access controls, confidentiality obligations, secure systems, backups, monitoring and provider due diligence. No Internet transmission or storage system is completely secure, and we cannot guarantee absolute security.

12. Your rights

Subject to applicable law and any relevant professional, privilege, confidentiality or legal-claims limitations, you may have the right to:

• be informed about how your personal data is processed;
• request access to personal data we hold about you;
• request correction of inaccurate or incomplete data;
• request deletion of personal data in appropriate circumstances;
• object to, or request restriction of, certain processing;
• withdraw consent at any time, without affecting processing already lawfully carried out;
• request portability of eligible personal data;
• not be subject to a decision based solely on automated processing that produces legal or similarly significant effects, where applicable; and
• lodge a complaint with the Nigeria Data Protection Commission.

To exercise a right, send us a mail through our contact form. We may request proportionate information to verify your identity and authority. We will respond within the period required by applicable law.

13. Marketing communications

We will send newsletters or marketing communications where you have requested them or where another lawful basis permits. You may unsubscribe at any time using the unsubscribe link in the communication. Service, security or relationship communications are not marketing and may still be sent where necessary.

14. Children

The Website is intended for adults and business users and is not directed at children. We do not knowingly seek to collect personal data from children through the Website. If you believe a child has submitted personal data, please contact us so that we can take appropriate action.

15. Third-party websites

The Website may link to third-party websites or services. We do not control their processing practices and this Notice does not apply to them. You should review the privacy notice of the relevant third party before providing personal data.

16. Changes to this Notice

We may update this Notice to reflect changes in law, professional requirements, technology or our processing activities. The effective and last-updated dates will be shown at the bottom of the Notice. Material changes may also be highlighted on the Website.

17. Contact and complaints

Questions, requests or complaints about this Notice or our processing of personal data should be sent from our contact page.

You also have the right to lodge a complaint with the Nigeria Data Protection Commission through https://ndpc.gov.ng.

Effective Date: 10 October 2026  |  Last updated: 10 October 2026