Privacy Policy

Privacy Policy

Effective Date: [Insert Date] Last Updated: [Insert Date]

urbanpropertee.com (the "Website", "we", "us", "our") respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, share, and protect information when you visit or use our Website, in compliance with the Nigeria Data Protection Act, 2023 ("NDPA") and regulations issued by the Nigeria Data Protection Commission ("NDPC").

This Policy should be read alongside our Terms and Conditions. By using the Website, you consent to the practices described here.

1. Who We Are

urbanpropertee.com is operated by [Full Legal Company Name], a company registered in Nigeria (RC: [RC Number]), with its registered office at [Registered Address, Nigeria].

For data protection purposes, we act as the Data Controller for personal data collected through the Website. Our designated contact for privacy matters is:

  • Email: [privacy/support email]
  • Phone: [support phone]
  • Data Protection Officer (if applicable): [Name / "To be appointed"]

2. Information We Collect

We collect the following categories of personal data:

a) Information you provide directly:

  • Full name, phone number, email address
  • Property preferences (location, budget, property type)
  • Account login credentials
  • Payment information (processed by third-party payment providers — see Section 6)
  • Any Listing content, images, or descriptions submitted by Agents/Partners
  • Messages, enquiries, or communications sent through the Website

b) Information collected automatically:

  • IP address, device type, browser type, and operating system
  • Pages visited, time spent, click behaviour, and referral source
  • Cookies and similar tracking technologies (see Section 8)
  • Approximate location (based on IP address or, with permission, device GPS)

c) Information from third parties:

  • Data from Agents/Partners about properties or leads
  • Data from payment processors confirming successful transactions
  • Data from identity verification providers, where used

3. Legal Basis for Processing

Under the NDPA, we process your personal data on one or more of the following legal bases:

  • Consent — where you have given clear, informed consent (e.g., marketing communications, optional cookies).
  • Performance of a contract — to provide the Services you request, such as connecting you with an Agent or processing your account.
  • Legal obligation — where processing is required by Nigerian law (e.g., AML/KYC checks, tax records).
  • Legitimate interest — for purposes such as fraud prevention, improving the Website, and business analytics, provided this does not override your fundamental rights.

4. How We Use Your Information

We use your personal data to:

a. Create and manage your account; b. Connect you with relevant Listings, Agents, or Partners; c. Process payments and transactions made through the Website; d. Respond to enquiries, complaints, and customer support requests; e. Send service updates, transactional notices, and (with consent) marketing communications; f. Detect, investigate, and prevent fraud, security incidents, or violations of our Terms; g. Improve and personalise the Website through analytics; h. Comply with legal, regulatory, or law enforcement requirements.

We do not use your personal data for any purpose incompatible with the above without first obtaining your consent, where required.

5. How We Share Your Information

We may share your personal data with:

  • Agents/Partners — where you make an enquiry about a specific Listing, we share relevant contact details with that Agent so they may respond to you.
  • Service providers — including payment processors (e.g., licensed Nigerian payment gateways), cloud hosting providers, SMS/email delivery services, and analytics providers, strictly for the purpose of delivering the Services.
  • Legal and regulatory authorities — where required by law, court order, or to protect our rights, safety, or property, or that of our Users.
  • Business transfers — in connection with a merger, acquisition, or sale of assets, subject to equivalent privacy protections.

We do not sell your personal data to third parties.

Where we transfer personal data outside Nigeria (e.g., to a cloud provider with servers abroad), we ensure such transfers comply with the NDPA's cross-border data transfer requirements, including verifying that the receiving country or organisation maintains an adequate level of data protection, or by using appropriate safeguards (such as contractual clauses) approved under NDPC guidance.

6. Payment Information

We do not store your full debit/credit card details on our servers. Payments made through the Website are processed by PCI-DSS-compliant, CBN-licensed third-party payment processors (e.g., Paystack, Flutterwave, or similar), who handle your payment data under their own privacy and security policies.

7. Data Retention

We retain personal data only for as long as necessary to fulfil the purposes described in this Policy, including:

  • For as long as your account remains active;
  • As required to comply with legal, tax, or regulatory obligations;
  • To resolve disputes and enforce our agreements.

When data is no longer needed, we securely delete or anonymise it.

8. Cookies and Tracking Technologies

We use cookies and similar technologies to:

  • Keep you logged in and remember your preferences;
  • Understand how visitors use the Website (analytics);
  • Support advertising and retargeting (only with your consent, where required).

You can manage or disable cookies through your browser settings. Disabling certain cookies may affect the functionality of the Website. Where required by law, we will present a cookie consent banner allowing you to accept or reject non-essential cookies.

9. Data Security

We implement reasonable technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction, including:

  • Encryption of data in transit (SSL/TLS);
  • Access controls limiting staff access to personal data on a need-to-know basis;
  • Regular security reviews of our systems.

However, no method of transmission or storage is 100% secure, and we cannot guarantee absolute security.

10. Your Rights Under the NDPA

As a data subject, you have the right to:

a. Be informed about how your data is processed (this Policy); b. Access the personal data we hold about you; c. Rectify inaccurate or incomplete data; d. Erasure — request deletion of your data, subject to legal retention requirements; e. Restrict or object to certain processing, including marketing; f. Data portability — request your data in a structured, machine-readable format, where technically feasible; g. Withdraw consent at any time, where processing is based on consent, without affecting the lawfulness of processing carried out before withdrawal; h. Lodge a complaint with the Nigeria Data Protection Commission (NDPC) if you believe your data protection rights have been violated.

To exercise any of these rights, contact us at [privacy email]. We will respond within the timeframe required under the NDPA (generally within a reasonable period, and no later than statutory deadlines where applicable).

11. Children's Privacy

The Website is not intended for individuals under the age of 18. We do not knowingly collect personal data from children. If we become aware that we have inadvertently collected such data, we will take steps to delete it promptly.

12. Third-Party Links

The Website may contain links to third-party websites (e.g., mortgage providers, surveyors, payment gateways). This Policy does not apply to those third-party sites, and we encourage you to review their privacy policies independently.

13. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. Material changes will be communicated via email or a prominent notice on the Website. The "Last Updated" date at the top reflects the most recent revision.

14. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or your personal data, please contact:

urbanpropertee.com [Registered Company Name] [Registered Address, Nigeria] Email: [privacy/support email] Phone: [support phone]

You may also contact the Nigeria Data Protection Commission (NDPC) at www.ndpc.gov.ng if you have unresolved concerns.