Privacy Policy.

2.1 Introduction

Green Courage Global Ltd (“Green Courage”, “we”, “our”, or “Company”) respects your privacy and is committed to protecting your personal data.

This Privacy Policy explains how we collect, process, store, protect, and disclose your information when you use:

• Our website
• Mobile App
• Estate planning services
• Executor & trustee services
• Customer support channels

This Policy is compliant with:

• Nigeria Data Protection Regulation (NDPR)
• Nigeria Data Protection Act (NDPA)
• GDPR principles for international clients

By using our services, you consent to the practices described herein.

2.2 Data We Collect

We may collect the following categories of personal data:

2.2.1 Identity Information

• Full name
• Date of birth
• Gender
• Marital status
• National ID / International passport (where required)

2.2.2 Contact Information

• Phone number
• Email address
• Residential address

2.2.3 Financial Information

• Asset details
• Bank information (where necessary)
• Investment information

2.2.4 Estate Planning Information

• Beneficiary details
• Executor details
• Trust structures
• Digital asset information

2.2.5 Technical Information

• IP address
• Device type
• Browser type
• Login timestamps

2.3 Legal Basis for Processing

We process personal data based on:

• Contractual necessity
• Legal obligation
• Legitimate interest
• Explicit consent (especially for sensitive data)

2.4 Purpose of Data Processing

Your data is used for:

• Creating estate planning documents
• Providing trustee and executor services
• Identity verification (Know Your Customer / Anti-Money Laundering compliance)
• Account administration
• Legal compliance
• Customer support
• Fraud prevention

We do not sell your personal data.

2.5 Sensitive Personal Data

We may process sensitive data including:

• Health declarations (mental capacity confirmation)
• Financial records
• Biometric verification (if implemented)

Such processing requires explicit consent.

2.6 Data Storage & Security

We implement:

• Encrypted cloud storage
• Access controls
• Role-based authorization
• Secure server infrastructure
• Two-factor authentication
• Blockchain technology
• Coded identification (rather than name)

While we ensure and implement reasonable safeguards, no digital platform is 100% secure.

2.7 Data Retention

We retain personal data:

• For the duration of service engagement
• As required by law
• For record-keeping and compliance purposes

After the retention period, data will be securely deleted, anonymized, or destroyed.

2.8 Data Sharing

We may share information with:

• Legal practitioners (where engaged)
• Regulatory authorities
• Courts of competent jurisdiction
• Cloud storage providers
• Payment processors
• Financial institutions

All third parties are contractually obligated to maintain confidentiality.

2.9 International Data Transfers

Where data is transferred outside Nigeria, we ensure:

• Adequate protection mechanisms
• Contractual safeguards
• Compliance with applicable data protection laws

2.10 Your Rights (Under NDPR & GDPR Principles)

You have the right to:

• Access your data
• Request correction
• Request deletion (subject to legal limits)
• Withdraw consent
• Object to processing
• Request data portability
• Lodge a complaint with the relevant data protection authority

Requests may be submitted via our official email: privacy@mygreencourage.com

2.11 Cookies Policy

We use cookies to:

• Improve website functionality
• Enhance user experience
• Monitor system performance

You may disable cookies in your browser settings, though functionality may be affected.

2.12 Children’s Privacy

Our services are not intended for persons under 18 years of age, except as beneficiaries. We do not knowingly collect data from minors.

2.13 Breach Notification

In the event of a data breach:

• Affected users will be notified where required by law
• Relevant authorities will be informed
• Remedial action will be taken promptly

2.14 Updates to this Policy

We may update this Privacy Policy periodically. Continued use of services constitutes acceptance of updates.

2.15 Contact Information

Data Protection Officer

Green Courage Global Ltd

Address

[Insert registered office address]

Email

privacy@mygreencourage.com

Phone

[Insert phone number]

3.1 Parties

This Consent & Data Processing Agreement (“Agreement”) is entered into between:

• Green Courage Global Ltd (“Company”, “Data Controller”)
• The registered user or client (“Client”, “Subscriber”, “Data Subject”)

By signing electronically or physically, the Client provides informed consent for the processing of personal data.

3.2 Purpose of Processing

The Client acknowledges that Green Courage will process personal data for:

• Estate planning documentation
• Will drafting and trust structuring
• Executor and trustee administration
• Identity verification (KYC/AML)
• Legal compliance
• Record retention
• Fraud prevention

3.3 Categories of Data Processed

The Client consents to processing of:

• Identity information
• Contact details
• Financial records
• Asset information
• Beneficiary information
• Executor details
• Health declaration confirming mental capacity (“in sound mind”)
• Digital assets information

3.4 Legal Basis

Processing is based on:

• Explicit consent of the Client
• Contractual necessity
• Legal obligations under Nigerian law
• Legitimate business interest

3.5 Sensitive Personal Data

Where sensitive data (e.g., health declarations, biometric identification, financial statements) is processed, explicit consent is required.

By signing this Agreement, the Client confirms voluntary and informed consent.

3.6 Data Storage & Protection

Green Courage shall:

• Store data securely using encrypted systems
• Restrict access to authorized personnel
• Maintain confidentiality
• Implement reasonable security safeguards

However, the Client acknowledges that no system is entirely immune from cyber risks.

3.7 Data Sharing

The Client consents to data sharing with:

• Courts and regulatory authorities
• Legal practitioners engaged in estate matters
• Financial institutions
• Payment processors
• Cloud service providers

Such sharing shall be limited to lawful and necessary purposes.

3.8 Retention Period

Personal data shall be retained:

• During the active service period
• As required by law
• For estate administration and compliance

Thereafter, data may be securely deleted or archived.

3.9 Client Rights

The Client retains the right to:

• Access personal data
• Request corrections
• Withdraw consent (subject to contractual and legal limits)
• Request deletion where legally permissible

Requests must be submitted in writing.

3.10 Withdrawal of Consent

Withdrawal of consent:

• Does not invalidate processing already lawfully carried out
• May limit continued service delivery
• May require account closure

3.11 Declaration

By signing or electronically accepting this Agreement, the Client confirms:

• All information provided is accurate
• Consent is given voluntarily
• They are of legal age and capacity
• They understand the nature of data processing involved

3.12 Governing Law

This Agreement shall be governed by the laws of the Federal Republic of Nigeria.