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Privacy Policy

Effective date: September 2026  ·  Version 1.0

1. Introduction

GRUU Diamond Ltd (“we”, “us”, “our” or “the Company”) is committed to protecting your personal data and respecting your privacy. This policy explains how we collect, use, store, share and protect personal information when you visit gruudn.com, use our services, make purchases through our shop, or otherwise interact with us.

This policy is issued in accordance with the Nigeria Data Protection Act (NDPA) 2023 and the Nigeria Data Protection Regulation (NDPR) 2019, and with international best practice including the General Data Protection Regulation (GDPR) where relevant to data subjects in the European Economic Area.

By using our website or engaging our services, you confirm that you have read and understood this policy. If you do not agree with it, please do not use our website or services.

2. Who we are (data controller)

GRUU Diamond Ltd is the data controller for personal data collected through this website and in connection with our services.

Address: 21 Tourggourt Street, Wuse Zone 2, Abuja, FCT, Nigeria
Email: hello@gruudn.com
Phone: 0809-276-6250

[ PLACEHOLDER — add RC registration number and, if applicable, NDPC data controller registration number. ]

3. What personal data we collect

We collect personal data in the following categories, depending on how you interact with us.

3.1 Website enquiries and contact forms

  • Full name
  • Email address
  • Phone number (if provided)
  • Company name and job title (if provided)
  • The content of your message or enquiry

3.2 Growth assessment and consultation forms

  • Full name and contact details
  • Business name, industry and size
  • Current IT infrastructure details
  • Business challenges, goals and pain points as described by you
  • SAP system usage and maturity information (if applicable)
  • Any other information you volunteer in the assessment form

3.3 Shop and purchases

  • Full name and billing address
  • Email address and phone number
  • Payment card details, processed securely by our payment gateway. We do not store card data
  • Purchase history and transaction records
  • IP address and browser information at the time of purchase

3.4 Newsletter signups

  • Email address
  • First name (if provided)
  • Subscription preferences and communication opt-ins

3.5 Automatically collected data

  • IP address and approximate location
  • Browser type, version and operating system
  • Server log records of pages requested
  • Referral source
  • Device type and screen resolution

This data is collected through essential cookies and standard server logs. See our Cookie Policy for full detail.

4. How we use your personal data

Each purpose below is underpinned by a lawful basis under the NDPA and NDPR.

4.1 Providing and managing our services (contractual necessity)

  • Processing quotes, invoices and payments
  • Delivering project deliverables and digital products
  • Scheduling and managing consultations
  • Communicating about your project, scope of work or support needs
  • Issuing receipts, statements and financial records

4.2 Business operations and legal compliance (legitimate interest / legal obligation)

  • Maintaining accurate financial and project records
  • Complying with Nigerian tax law, FIRS requirements and VAT obligations
  • Detecting and preventing fraud, abuse or unauthorised access
  • Responding to legal requests, court orders or regulatory enquiries
  • Enforcing our Terms and contractual rights

4.3 Communication and marketing (consent / legitimate interest)

  • Responding to your enquiries and messages
  • Sending service-related updates and notifications
  • Sending newsletters or announcements where you have opted in
  • Conducting client satisfaction follow-ups

You may withdraw consent to marketing at any time by using the unsubscribe link in any email, or by contacting hello@gruudn.com.

4.4 Website improvement (legitimate interest)

  • Identifying and fixing technical issues
  • Improving the content, structure and performance of the website

5. Lawful bases for processing

  • Consent: newsletter signups, marketing communications and non-essential cookies. You may withdraw consent at any time.
  • Contractual necessity: enquiries, quotes, invoices, payments and service delivery.
  • Legal obligation: tax record-keeping, financial reporting and compliance with Nigerian law.
  • Legitimate interests: fraud prevention, site security and improving our services, where not overridden by your rights.

6. Who we share your data with

We do not sell, rent or trade your personal data. We share it only in the limited circumstances below.

6.1 Service providers and processors

We engage third-party providers who process data on our behalf. All are contractually bound to handle your data securely and only for the purposes we specify.

  • Paystack — payment processing at checkout
  • Google LLC — reCAPTCHA form protection, and Google Workspace for email and document storage
  • Automattic Inc. — WordPress and WooCommerce platform and ecommerce infrastructure
  • [ PLACEHOLDER — add hosting provider name, and any email marketing platform once one is in use. ]

6.2 Legal and regulatory disclosure

We may disclose personal data to regulatory authorities, law enforcement or courts where required by Nigerian law or a valid legal order.

6.3 Business transfers

In the event of a merger, acquisition or sale of all or part of GRUU Diamond Ltd, your personal data may transfer to the successor entity. We will notify you of any such transfer and your rights in that context.

7. International data transfers

Some of our providers are based outside Nigeria, including in the United States. Where personal data is transferred outside Nigeria, we ensure appropriate safeguards are in place in accordance with the NDPA and NDPR, including:

  • Transfers to countries with adequate data protection laws as recognised by the Nigeria Data Protection Commission
  • Standard contractual clauses or data processing agreements with providers
  • Transfers to providers certified under recognised international frameworks, such as the EU-US Data Privacy Framework

The primary international processors involved are Google LLC and Automattic Inc., both based in the United States, and both of which maintain GDPR-compliant data processing agreements.

8. How long we keep your data

We retain personal data only for as long as necessary for the purpose it was collected, or as required by Nigerian law.

  • Client project records, invoices and financial documents: 5 years from project completion, in line with Nigerian tax and record-keeping requirements.
  • Enquiry and contact form data: 12 months from last contact, unless the enquiry becomes a client engagement.
  • Growth assessment submissions: 12 months from submission, or for the duration of the client relationship.
  • Newsletter subscriptions: until you unsubscribe or withdraw consent.
  • Server logs: as retained by our hosting provider in the ordinary course.

On expiry of the applicable retention period, data is securely deleted or anonymised.

9. Your data protection rights

Under the NDPA 2023 and NDPR 2019 you have the following rights in relation to your personal data:

  • Right of access: request a copy of the personal data we hold about you.
  • Right to rectification: request correction of inaccurate or incomplete data.
  • Right to erasure: request deletion where we no longer have a lawful basis to retain it.
  • Right to restrict processing: request that we limit processing in certain circumstances.
  • Right to data portability: request your data in a structured, machine-readable format where processing is based on consent or contract.
  • Right to object: object to processing based on legitimate interests, or to direct marketing.
  • Right to withdraw consent: withdraw consent at any time, without affecting the lawfulness of prior processing.

To exercise any of these rights, contact us in writing at hello@gruudn.com. We will respond within 30 days. We may need to verify your identity before acting on a request.

If you are dissatisfied with our response, you may lodge a complaint with the Nigeria Data Protection Commission at ndpc.gov.ng.

10. Data security

We implement appropriate technical and organisational measures to protect personal data against unauthorised access, loss, alteration or disclosure. These include:

  • TLS encryption for all data transmitted through our website
  • Access controls and password policies for internal systems
  • Access to personal data limited on a need-to-know basis
  • Regular security review of our WordPress and WooCommerce installation
  • Use of reputable, security-audited third-party processors

While we take all reasonable steps, no method of transmission over the internet is entirely secure. We cannot guarantee absolute security, but we commit to notifying you and the NDPC promptly of any breach likely to result in a risk to your rights and freedoms, in accordance with our obligations under the NDPA 2023.

11. Children’s privacy

Our website and services are directed exclusively at businesses and professionals. We do not knowingly collect personal data from anyone under 18. If you believe a minor has provided us with personal data, contact hello@gruudn.com and we will delete it promptly.

12. Third-party links

Our website may link to third-party websites, tools or resources. This policy applies only to gruudn.com. We are not responsible for the privacy practices of third-party sites and encourage you to review their policies before providing personal data.

13. Cookies

Our website uses cookies to make the site work and to support the shop and checkout. We do not currently use analytics, advertising or profiling cookies. For full detail of the cookies we set and how to manage them, see our Cookie Policy.

14. Changes to this policy

We may update this policy to reflect changes in our practices, legal obligations or services. Material changes are communicated by email to active clients, or by prominent notice on our website, at least 14 days before taking effect. The effective date at the top of this page always reflects the most recent update.

15. Contact and complaints

For any question, request or concern about this policy or how we handle your personal data, email hello@gruudn.com, call 0809-276-6250, or use the form on our contact page.

Last updated: September 2026.

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