Last updated: 28 August 2026
1. Who we are
Gianni Capital LLC is the data controller for personal data collected through gianni.capital.
Gianni Capital LLC
23 Lord Lugard Street, Area 11 Garki, Abuja 900108, Nigeria
Email: info@gianni.capital
Phone: +234 817 722 2400
This policy explains what we collect, why, and what rights you have under the Nigeria Data Protection Act 2023.
2. What we collect
Information you give us
- Enquiry and contact forms: your name, email address, phone number, message, and where you request a viewing, your preferred date.
- Newsletter signup: your email address.
- Blog comments: your name, email address, comment text, and, as recorded automatically by WordPress, your IP address and browser user agent.
- Direct correspondence: anything you send us by email, phone or WhatsApp.
Information collected automatically
Our web server keeps standard access logs (IP address, date and time, pages requested, browser type) for security and diagnostics. [TO CONFIRM: name of the hosting provider, which acts as a data processor and stores these logs.]
We do not currently run Google Analytics, Google Tag Manager, Meta Pixel or any advertising or behavioural tracking on this website. [TO CONFIRM: if analytics or advertising pixels are added later, this section must be updated and a cookie consent notice added.]
3. Why we use it, and our lawful basis
| Purpose | Lawful basis under the NDPA 2023 |
|---|---|
| Responding to your enquiry and arranging viewings | Steps taken at your request prior to entering a contract |
| Administering a purchase, reservation or allocation | Performance of a contract |
| Sending you our newsletter | Your consent, withdrawable at any time |
| Publishing blog comments | Your consent |
| Website security, fraud prevention and diagnostics | Our legitimate interest in keeping the site secure |
| Meeting legal, tax and regulatory obligations | Compliance with a legal obligation |
4. Who we share it with
We do not sell your personal data. We share it only with:
- Mailchimp (Intuit Inc., United States), which delivers our newsletter. Subscribing means your email address is stored on Mailchimp servers outside Nigeria.
- Our web hosting provider, which stores the website and its database.
- Professional advisers such as lawyers, accountants and surveyors, where a transaction requires it.
- Regulators or law enforcement, where we are legally required to disclose.
[TO CONFIRM: any other third parties, for example a CRM, estate agency partner, payment processor or cloud storage provider, that receive client data.]
5. Cookies
This site uses only functional cookies set by WordPress and the page builder, which keep the site working correctly and remember your session. We do not use advertising or profiling cookies. You can block or delete cookies through your browser settings, though parts of the site may then not work as intended.
6. How long we keep it
[TO CONFIRM: retention periods. For example: enquiries not leading to a transaction kept for X months; client and transaction records kept for X years to meet tax and statutory obligations; newsletter subscribers kept until they unsubscribe.]
7. Your rights
Under the Nigeria Data Protection Act 2023 you have the right to:
- be told what personal data we hold about you, and receive a copy of it;
- have inaccurate data corrected;
- have your data deleted, where we have no continuing lawful reason to keep it;
- restrict or object to how we use it;
- receive your data in a portable format;
- withdraw consent at any time, where consent is the basis we rely on.
To exercise any of these, email info@gianni.capital. We will respond within one month. You can unsubscribe from our newsletter using the link at the foot of any newsletter email.
8. Security
The site is served over HTTPS, and access to the website administration and to client records is restricted to authorised personnel. No transmission over the internet can be guaranteed completely secure, but we take reasonable measures to protect your data.
9. Children
This website is not directed at children, and we do not knowingly collect personal data from anyone under 18.
10. Complaints
If you are not satisfied with how we have handled your data, you may lodge a complaint with the Nigeria Data Protection Commission (NDPC). We would ask that you contact us first so we can try to resolve the matter.
11. Changes to this policy
We may update this policy from time to time. The date at the top of this page shows when it was last revised.
This policy is a working draft prepared for Gianni Capital from an audit of what this website actually collects. It has not been reviewed by a qualified legal practitioner or a data protection specialist. The highlighted items above must be completed before it can be relied upon as a compliant NDPA privacy notice.