1. Introduction
Aso Realty (“we”, “us”, “our”) is committed to protecting the privacy and security of personal data of all individuals (“Data Subjects”) whose data we handle in connection with our real estate operations in Nigeria. We comply with the Nigeria Data Protection Act, 2023 (NDPA) and guidance from the Nigeria Data Protection Commission (NDPC).
This Privacy Policy explains how we collect, use, store, share, transfer, and otherwise process your personal data, what rights you have, and how you may exercise them.
2. Definitions
- Personal Data: information relating to an identifiable natural person as defined under the NDPA.
- Sensitive Personal Data: biometric, genetic, health data, religious or political beliefs and similar special categories.
- Data Controller: entity determining purposes and means of processing personal data.
- Data Processor: entity processing personal data for the controller.
- Data Subject: the identifiable natural person whose data is processed.
- Consent: freely given, specific, informed and unambiguous indication of wishes.
3. Scope / Applicability
This policy applies to all personal data we collect and process in Nigeria or from Data Subjects in Nigeria, via online channels (website, apps), offline channels (office visits, paper forms), service delivery, and marketing contexts.
4. Principles of Data Processing
- Lawfulness, fairness and transparency
- Purpose limitation
- Data minimization
- Accuracy
- Storage limitation
- Security, integrity and confidentiality
- Accountability
5. Lawful Bases for Processing
- Consent
- Contract
- Legal obligation
- Legitimate interests (balanced against your rights)
- Vital interests
- Additional safeguards for Sensitive Personal Data
6. What Data We Collect
| Category | Examples |
|---|---|
| Identification & Contact Data | Name, address, phone, email, national ID/passport, utility bill address |
| Transactional Data | Property interest, ownership details, financial info, payment history |
| Employment Data | CV, education, certifications, references |
| Sensitive Personal Data | Health data (if disclosed), biometric data (if used), religious beliefs (if provided) |
| Technical & Usage Data | IP, device/browser type, cookies, site usage |
| Marketing & Preferences | Communication preferences, opt-ins, survey responses |
7. Purposes of Processing
- Provide real estate services: listings, viewings, sales, rentals, management
- Manage client relationships and communications
- Evaluate and process applications
- Due diligence and background checks where required
- Security, fraud prevention, identity verification
- Marketing with consent
- Legal and regulatory compliance
- Complaints handling, dispute resolution, enforcement of terms
9. Cross-Border Transfers
Where data is transferred outside Nigeria, we ensure an adequate level of protection or implement appropriate safeguards (e.g., standard contractual clauses, binding corporate rules, or NDPC-approved mechanisms) and will inform you of the safeguards in place.
10. Data Subject Rights
- Right to be informed
- Right of access
- Right to rectification
- Right to object (including direct marketing)
- Right to erasure
- Right to data portability (where applicable)
- Right to withdraw consent
- Rights regarding automated decision-making
Use the contact in Section 14 to exercise your rights.
12. Data Retention
We retain personal data only as long as necessary for stated purposes or as required by law. When no longer needed, data will be securely deleted or anonymized. Example periods: property transaction records for [Insert Period] years; marketing data until opt-out; employee records per employment/tax law.
13. Security of Personal Data
- Access controls, encryption where appropriate, secure servers
- Secure physical storage with restricted access
- Employee training on confidentiality and data protection
- Incident response for data breaches, with notifications per NDPA where required
14. Data Protection Officer & Contact
Name: _______________________
Email: _______________________
Phone: _______________________
Address: _____________________
15. Changes to this Policy
We may update this policy to reflect legal, business, or technological changes. Updates will be posted here with an updated effective date. For material changes we may provide additional notice.
16. Complaints & Remedies
If you believe we have not complied with this policy or the NDPA, contact us first via the DPO details above. You may also lodge a complaint with the Nigeria Data Protection Commission (NDPC).
17. Miscellaneous
- Withholding Data: mandatory data may be required to fulfill contracts or legal obligations.
- Minors / Legal Capacity: if under 18 or lacking legal capacity, we require parental/guardian consent unless an NDPA exception applies.
- Automated Decisions & Profiling: where used, we will state the existence, logic, significance, and consequences.