DRAFT for review by a Nigerian legal practitioner — not published. Built on
GAID 2025 Article 19, read verbatim at the Commission’s website 13 August
2026; see NG-VERIFICATION-RECORD.md §4.1. Site audited the same day.

Nigeria’s cookie rule is the most prescriptive of the three jurisdictions.
The UK works through PECR Sch A1 gateways; South Africa has no cookie-specific
regime at all; Nigeria specifies the banner itself — including that a visitor
“shall not be required to scroll to any part of a website before seeing the
cookie banner” (Art 19(7)(a)). Do not reuse either sibling document here.

This notice is short because the site sets no cookies. If that changes, the
design requirements in the internal note below are mandatory, not stylistic.

Last updated: [[ date of publication ]]

The short version

We do not set cookies on this website. We use no analytics, no advertising
trackers and no social media pixels. There is no cookie banner because there is
nothing to consent to.

What the law requires

GAID 2025 Article 19(2) provides that, except as the GAID otherwise provides,
the use of cookies on a website or other digital platform requires consent, and
Art 19(3) requires that consent be freely given, informed and specific.
Art 19(1) requires cookie operation to comply with the data protection principles
in section 24 of the NDP Act.

We rely on no exception, because we operate no cookies.

What happens when you visit anyway

1. Our hosting provider records the request — your IP address, the page
requested, the time, and your browser’s user-agent. We use this to run and secure
the site, not to identify you. These logs are held in the United Kingdom, where
this website is hosted. See our Privacy Notice.

2. Fonts are currently loaded from Google. The typefaces on this site are served
from fonts.googleapis.com and fonts.gstatic.com, so your browser requests them
from Google directly and Google receives your IP address and user-agent.

[[ R-EWDOC1 — self-hosting the fonts matters MORE in Nigeria than elsewhere ]]

GAID Art 19(8) provides that the Commission “shall treat any personal data
tracking tool which performs functions that are similar to cookies as bound by the
rules that apply to the use of cookies – taking into account the legal ground that
where the same facts exist the same rules shall apply.”

A third-party resource that causes a visitor’s IP address to be disclosed to a
foreign company on every page load is at least arguably within that wording.
Nigeria’s rule is drawn more widely than the UK’s, which is tied to storing or
accessing information on terminal equipment.

Self-hosting the fonts removes the argument entirely, on all three sites, at no
visual cost. Of the three jurisdictions this is the one where leaving it in
place carries the most risk. If the fix is made, delete point 2 above and the
matching paragraph of the Privacy Notice.

The application

This notice covers the public website. The Nigerian application service is not
currently available. When it is, it will be reached by signing in, and strictly
necessary storage will be used to keep you signed in — cookies enabling core
functionality such as security, network stability management and accessibility,
which under GAID Art 19(5)–(6) are “necessary cookies” that do not require
the ticking of a box.

If we add cookies

We will update this notice before switching anything on. GAID Art 19 sets
requirements that are design requirements, not drafting ones, and any
implementation must meet them:

Internal — the mandatory checklist, from Art 19(6)–(7):

• Necessary cookies only — core functionality such as security, network
  stability management and accessibility, and not processing sensitive data,
  financial data or data stored privately by the data subject — need no tick
  box (Art 19(5)–(6)).
• Everything else requires a specific “yes or no” (or “accept”/”reject”)
  selection presented to the data subject (Art 19(6)). A banner offering only
  “Accept” does not comply.
• The banner must be conspicuous and obvious (Art 19(4)) and visible without
  scrolling — “a data subject shall not be required to scroll to any part of a
  website before seeing the cookie banner” (Art 19(7)(a)). Every tracking tool
  must be made known at the section of the web page which appears first.
• Cookie information must be clear and easy to understand (Art 19(7)(b)).
• Users must be notified of the presence and purpose of the cookies
  (Art 19(7)(c)).
• The organisation responsible for the cookies must be identified
  (Art 19(7)(d)).
• How to withdraw consent must be explained (Art 19(7)(e)).
• Art 19(8): any tracking tool performing similar functions is bound by the
  same rules — so this checklist applies to pixels, fingerprinting scripts and
  embedded third-party resources, not only to things called “cookies”.

Contact

TKJ Global Media Ltd, 94 Queen Elizabeth Road, Wakefield, WF1 4RJ, United Kingdom ·
ops@tkjlegal.co.uk

We are a United Kingdom company. This website is hosted in the United Kingdom.