Legal and Compliance

Privacy Policy

Last updated September 2026

This policy explains, in detail, what information Pathmark Energy Limited collects, the lawful reasons we use it, who can see it, how long we keep it, and the rights you have under Nigerian data-protection law. It applies to this website, estate power assessments, and the operational data we handle once a plant is commissioned.

1. Who we are

Pathmark Energy Limited ("Pathmark Energy", "we", "our", or "us") is an institutional energy company within the Pathmark Group. We fund, design, build, own and operate solar-hybrid mini-grid systems for gated residential estates, commercial parks, and related developments. We are the data controller for personal information collected through this website and for the project files created when you request an assessment.

Our engineering desk and registered correspondence address is T007 Plot 1248 Orji Uzor Kalu Close, Mabushi, Federal Capital Territory, Abuja, Nigeria. Privacy questions, access requests, and complaints should be sent to info@pathmarkenergy.com or by telephone to 070-72846275 (070-PATHMARK). Please mark the subject line "Privacy request" so the desk can route it without delay.

Where a commissioned plant is operated under a separate project company, concession, or operations agreement, that document may name an additional controller for resident metering data. In those cases this policy still describes our website and assessment practices, and the project agreement governs plant-level billing records.

2. What this policy covers

This policy applies to anyone who visits pathmarkenergy.com, submits the estate power assessment form, emails or calls the engineering desk, attends a site meeting, or shares drawings and load data during project evaluation. It also describes, at a high level, how we treat telemetry and prepaid-metering information after a plant is in service.

It does not replace a non-disclosure agreement, a term sheet, an EPC or build-own-operate contract, a mini-grid tariff schedule, or household metering terms issued to residents. If those documents say something different about a specific dataset, the signed document controls for that project.

We handle personal data in line with the Nigeria Data Protection Act 2023, the Nigeria Data Protection Regulation, and guidance from the Nigeria Data Protection Commission (NDPC). Where a processor or cloud tool is located outside Nigeria, we also consider the transfer rules in that Act. This page is written for developers, estate managers, and ordinary site visitors. It is not legal advice to you, and it is not a substitute for counsel on a particular transaction.

3. Information we collect

We collect only what we need to evaluate an estate, reply to you, and operate infrastructure safely. The categories below are the ones we actually use in this business. We do not ask for national identity numbers, bank-card details, or health data on the public form.

Enquiry and contact data. When you use the assessment form you provide full name, company or organisation, email address, telephone number, estate or project name, location, number of units or plots, construction stage, a description of the current power situation, and any extra requirements (peak load, EV charging, service levels, and similar notes). If you telephone or write to us instead, we keep the same types of details from that conversation.

Correspondence and files. Emails, call notes, meeting minutes, and documents you later attach — master plans, load schedules, single-line diagrams, photographs of existing generators, or letters of authority from a developer — become part of the project file. You should only send material you are allowed to share.

Technical project data. After an NDA or engagement letter we may collect detailed load profiles, transformer and cable layouts, geotechnical notes, and commercial assumptions. This is usually business information rather than personal data, but it can include names and contact details of site staff.

Operational plant data. On a commissioned mini-grid we record inverter and battery telemetry, diesel run-hours, fault events, prepaid-meter token purchases, and household-level consumption needed for billing, reliability, and NERC mini-grid reporting. Residents of an estate are typically customers of the plant, not visitors to this website; their metering terms are explained at connection.

Website technical data. Our hosting environment may log the date and time of a visit, browser type, and a rough network address as part of ordinary security. The site also stores a light-or-dark theme preference on your device. We do not run advertising pixels or third-party analytics dashboards on this marketing site. See the Cookies Policy for the full list.

4. How we collect it

Most enquiry data comes directly from you: the public form, email, telephone, or a meeting at Mabushi or on site. We do not buy marketing lists of developers. We do not scrape social networks to build prospect files.

We may receive your name and role from a Pathmark Group colleague, a referring developer, or a professional adviser who asks us to contact you. In that case we will tell you, when we first write, who pointed us to you and why. If you ask us not to continue, we will close the outreach and keep only a short suppression note so we do not contact you again by mistake.

Plant telemetry and prepaid-meter events are generated by equipment we own or operate. They are not collected through this website.

5. Why we use it and on what basis

Nigerian law requires a lawful basis for each use of personal data. For this business the usual bases are as follows.

  • Steps toward a contract, or performance of a contract. Reviewing an assessment, preparing a design or term sheet, and later operating a plant under a signed agreement.
  • Legitimate interests. Keeping a record of who asked for an assessment, protecting the site from abuse, improving the clarity of our pages, and defending legal claims. We balance those interests against your right to object.
  • Legal obligation. Tax records, NERC mini-grid permits and reporting, safety investigations, and responses to a lawful request from a Nigerian court or regulator.
  • Consent. Only where we specifically ask for it — for example if we later introduce optional marketing mail. The assessment form itself is a request for work, not a consent to newsletters. You may withdraw consent without affecting earlier lawful processing.

We do not use automated decision-making that produces a legal or similarly significant effect about you. An engineer reviews every assessment. We do not sell personal data and we do not rent enquiry forms to third-party marketers.

6. How we use information in practice

Day to day, personal and project information is used to:

  • acknowledge your request and aim to reply within one business day;
  • decide whether the estate is a fit for a build-own-operate mini-grid and what further site work is needed;
  • prepare load studies, hybrid architectures, capital estimates, and commercial terms;
  • arrange site visits, contractor access, and later construction or commissioning;
  • operate, maintain, monitor, and bill commissioned plants, including prepaid token vending;
  • meet permit, tax, audit, insurer, and NERC reporting duties;
  • investigate incidents, fraud against the vending platform, or damage to plant; and
  • keep this website available and record that you have been shown the current policies.

If we ever want to use enquiry data for a purpose that is incompatible with the above — for example a general newsletter — we will say so clearly and give you a way to decline.

7. Who we share information with

Assessment forms on this website are delivered through Formspree, a specialist form processor. Formspree receives the fields you type so our engineering desk can read them in one place. It acts on our instructions and is not free to use your estate details for its own marketing. Formspree's systems may be hosted outside Nigeria. That is the main international transfer created by the public form.

Inside the Pathmark Group we may share a live enquiry with Pathmark Holdings, Pathmark Infrastructure, or Pathmark Technologies where those companies need to support funding, civil works, or digital platforms. Staff see only what their role requires. External lenders, independent engineers, insurers, and legal advisers receive project packs under confidentiality when a transaction is in diligence.

Construction and operations contractors — electrical, civil, security, metering vendors — receive names and site contacts needed to do their job, not the entire marketing database. We may disclose information if a Nigerian court, the NDPC, NERC, a tax authority, or the police lawfully require it, or if we must do so to protect people or plant in an emergency.

We do not publish the contents of your assessment on this website. Case studies such as Jahi Estate use information we are allowed to show, usually after commissioning and without private contact details of third-party staff.

8. How long we keep it

We keep information only as long as there is a business or legal reason to do so. Typical periods are:

  • Closed or abandoned enquiries: long enough to finish the conversation and a short follow-up (ordinarily up to twenty-four months), then deletion or anonymisation of the working file.
  • Active assessments and unsigned proposals: for the life of the discussion plus the period we need to show how a commercial position was reached.
  • Signed projects: for the operating life of the asset and thereafter for tax, limitation, warranty, and NERC record periods. Prepaid-meter and telemetry archives follow the same plant file.
  • Security and hosting logs: for a short rotating window unless an incident requires a longer hold.
  • Theme preference: only on your device, until you clear site data.

When a period ends we delete or irreversibly anonymise the personal fields, or archive them in a restricted legal hold if a dispute is already live.

9. Your rights

Subject to the Nigeria Data Protection Act and any exemption that applies (for example legal privilege or a competing regulatory duty), you may:

  • ask whether we hold personal data about you and receive a copy;
  • require correction of data that is wrong or incomplete;
  • request deletion where we no longer have a lawful basis to keep it;
  • ask us to restrict or object to certain processing;
  • ask who has received your data, in general terms;
  • withdraw consent, where consent was the basis we relied on; and
  • lodge a complaint with the Nigeria Data Protection Commission if you are not satisfied with our response.

Send requests to info@pathmarkenergy.com from the address we already have on file if possible, and include enough detail to find the record (estate name, approximate date of the form, and the nature of the request). We may need to confirm your identity before releasing a file. We aim to respond within the statutory period. We will not charge a fee for a reasonable request; we may refuse or charge for requests that are manifestly unfounded or repetitive.

These rights apply to personal data. They do not give a third party a right to our engineering calculations, pricing models, or another developer's confidential pack.

10. Security and international transfers

We apply organisational and technical measures that match the sensitivity of estate infrastructure work: restricted access to the engineering desk, role-based sharing of project folders, NDA cover before detailed drawings are exchanged, and ordinary hosting protections on this website. Staff are expected to treat enquiry files as confidential.

No internet transmission is perfectly secure. The public form is suitable for names, contacts, and a narrative of the power situation. It is not the right channel for complete as-built drawings, access-control schedules, or other material you would only send through a dedicated data room. If a secure channel has already been opened, use that instead.

Formspree and some cloud tools may store copies outside Nigeria. Where that happens we rely on the processor contract, the security practices of that vendor, and the transfer provisions of Nigerian data-protection law. We do not transfer enquiry files to countries or parties that have no relationship to delivering the assessment or the subsequent project.

11. Children and sensitive data

This website and the assessment form are aimed at property developers, estate managers, and institutional counterparties. They are not directed at children. We do not knowingly collect personal data from anyone under 18 on this site. If you believe a child has submitted a form, write to us and we will delete it.

Please do not include special-category or sensitive data in the public form — for example health information, biometric identifiers, or political opinions. We do not need those fields to size a mini-grid.

12. Changes to this policy

We will update this page when our systems, processors, or the law change. The "Last updated" date at the top is the version in force. Material changes — a new analytics tool, a new processor for forms, or a change in how long we keep enquiries — will be described in the revised text. Continued use of the site after a change means you have had a chance to read the new version.

Older project agreements are not automatically rewritten by an update here. If you need a PDF of a particular dated version for a transaction file, ask the engineering desk.

Need the engineering desk?

Questions on these policies can be sent to info@pathmarkenergy.com.

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