Legal

Privacy Policy

Your privacy matters to us. This policy explains how Shugaland collects, uses, and protects your personal data in accordance with the Nigeria Data Protection Act.

Effective Date: April 2025
[email protected]
1

Introduction

Shugaland Technologies Limited ("Shugaland"), a property management technology limited Company is the controller of your personal data on this platform. Shugaland is committed to protecting your privacy and ensuring the security of your personal data. This privacy policy ("policy") sets out how your personal information is collected, used and protected in accordance with the Nigeria Data Protection Act ("NDPA") and applicable data protection laws and legislations in Nigeria. This policy applies to Shugaland's website and all its applications, services, tools and content irrespective of how you access or use them.

You can contact us at: [email protected]

2

Consent

When you sign up for, access, or use our services, content, features, technologies or functions offered on our website, applications and services (collectively "Shugaland services"), you have accepted this policy, and consented to the collection, use, processing and sharing of your personal data as outlined in this privacy policy. Your personal data will only be collected and processed for the exact purposes stated in this policy which include providing you with our services or communicating with you about our offers.

3

Personal Data We Collect

Shugaland collects and processes various types of personal data to provide you with our services. Some of the personal data we may collect include, but are not limited to:

Information you provide voluntarily

i.Contact Information: This includes your name, email address, phone number, and postal address and company data.
ii.Financial Information: We may collect information about your payment transactions such as payment card information, billing, contact information.
iii.Identity Verification: To comply with legal requirements and to verify your identity, we may collect identity documents, such as government-issued identification or utility bills.
iv.Communication Data: Information related to your interactions with us, including e-mails, customer support inquiries, completion of our forms to contact us, subscribe to our newsletter, subscribe to receive our marketing messages, participate in our surveys and any feedback you provide.
v.Other Information: Any additional information you provide to us voluntarily.

Information we collect automatically

i.Usage Data: We collect data about how you use our platform, such as login information, device information, and browsing history.
ii.Device and Log Information: We gather information about the devices you use to access our services, including device type, operating system, and unique device identifiers. Also, we collect log information, such as IP addresses, browser type, and access times, to analyse user trends and improve our platform.
iii.Geographical Data: In some cases, we may collect your geographical location to provide location-specific services.
iv.Any additional information that we collect in connection with our services.

The above details are collected using cookies and other tracking technology.

b.We will always ensure that we minimize the collection of personal data to only what is necessary for the intended purpose. Where applicable and required by law, we will obtain your consent before collecting certain categories of data. Our data collection is always conducted in accordance with applicable data protection laws and best practices.
c.It is important to note that certain personal data may be necessary to provide you with our services, and refusal to provide such data may impact our ability to serve you effectively. We are committed to ensuring the security and confidentiality of your personal data, and our data processing activities are conducted in accordance with this Privacy Policy and applicable laws.
d.For personal data collected by our payment partners, including credit/debit card details, Subscribers should refer to the privacy notices provided by these payment partners. These notices contain essential information about how our payment partners process personal data. It is important to review and understand the privacy practices of our payment partners as they may differ from our own data processing practices. We do not control the privacy practices of our payment partners, and you should contact them directly for any inquiries or concerns related to the processing of your payment information.
4

Legal Grounds for Processing Your Personal Data

We will share your information based on the following lawful basis:

a.Necessary for the performance of the contract with you (for example, to process your personal data in order to provide you with access to products and services on the platform, and to process your payments);
b.Necessary to comply with our legal obligations (for example, to comply with applicable property management rules and to make mandatory disclosures to law enforcement);
c.Necessary for our legitimate interests (for example, to manage our relationship with you, to ensure the security of our services, to communicate with you about our services); and
d.In limited circumstances, based on consent (for example, to place certain cookies and to share your information with third parties for advertising purposes).
e.Detect, prevent, or otherwise address security, fraud, or technical issues.
f.Protect the rights, property or safety of us, our users, a third-party or the public as required or permitted by law (including exchanging information with other companies and organizations for the purposes of fraud protection).
g.Enforce our terms of service and other agreements, policies and standards including investigation of any potential violation.
h.Personalize advertisements and marketing communications based on your preferences and interactions with our platform, as permitted by applicable laws and regulations.
5

What We Do With Your Personal Information

We collect and process your personal data for some of the purposes listed below:

a.Authenticate your identity and prevent unauthorised access to restricted data.
b.To manage our website and our platforms to ensure the customer has an efficient, enjoyable and secure experience.
c.To provide you with relevant information of our services and improve our services;
d.To facilitate property acquisition for individuals in Nigeria and globally;
e.To comply with legal obligations; and
f.To develop a business relationship with our customers.
g.With your consent send targeted marketing information about our services and promotional communications by email, SMS and push notifications (depending on your choice of contact.)
6

Recipients of Personal Data

We only share your personal data with third parties when it is necessary to provide you with our services or to comply with legal or regulatory requirements. Your personal data may be shared with the following categories of recipients:

a.Service providers and merchants to process your payments.
b.KYC verification companies to verify biodata and identity information that you provide to help identify potential customers.
c.Property developers and other partners to help you find and purchase or sell properties or land;
d.Government agencies to comply with tax and other reporting requirements.
e.We may provide third-party providers that have been procured to provide certain services on behalf of Shugaland that include but are not limited to, analyzing data, providing marketing assistance, transferring contenting, assessing and provision of customer services.
f.Detection of fraud – We may provide details and other personal data to other companies, organizations and government agencies (if required) for fraud protection.
g.In the event that we sell or buy any business or assets (whether a result of liquidation, bankruptcy or otherwise), in which case we will disclose your data to the prospective seller or buyer of such business or assets; or
h.If we sell, buy, merge, are acquired by, or partner with other companies or businesses, or sell some or all of our assets. In such transactions, user information may be among the transferred assets.
i.Occasionally, we may send you relevant information such as new service offerings and other relevant updates.
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Rights of Data Subjects

As a data subject, you have the following rights:

a.Access

You can request access to your personal data provided that you give us reasonable notice of such a request. Also, we may require you to give us some more additional information that we will use to verify your identity before releasing your personal data.

b.Rectification

You can request the correction of inaccurate personal data where the correction is not feasible personally.

c.Erasure

You can request the deletion of your personal data without undue delay where the personal data is inaccurate, out of date, incomplete, or misleading.

d.Portability

You can request to receive your personal data in a structured, commonly used format e.g. an electronic format provided that such data would not impose unreasonable costs on us.

e.Objection or Restriction

You can object to the processing of your personal data or request that we limit the use of it.

f.Withdraw Consent

You can withdraw your consent at any time for the specific processing activities you consented to.

g.Automated Processing

You have the right not to be subject to a decision based solely on automated processing of personal data, including profiling.

h.You can opt-out or unsubscribe from receiving marketing campaign communications at any time. If you register on our website or platform, your personal data will be stored in our Customer Relationship Management system. If you have unsubscribed or opted out, your contact details will remain in our opt-out list to ensure that we do not inadvertently contact you in the future and your data will be erased completely.
8

Data Retention

We retain your personal data for as long as it is necessary to provide you with our services and to comply with legal and regulatory requirements. Once we no longer require your personal data, we will securely delete it.

The retention periods vary depending on the different criteria such as the type of information and the purpose for which we use the information. For instance, when we process your information such as your profile information which is secure on our website or platform, we retain this for as long as you still maintain an account with us. If you violate our Terms of Service or other conditions and policies, we may remove your profile and user content from public view immediately, but may keep other information about you to process the violation.

We will also retain and use your personal data for as long as is necessary to resolve disputes.

9

How We Secure Your Personal Data

Shugaland is committed to protecting your personal data and maintaining its confidentiality and integrity. We implement robust security measures and follow industry best practices to protect your information from unauthorized access, disclosure, alteration, and destruction. Our security measures include but are not limited to:

a.Encryption: We use encryption techniques to protect the transmission of data between your device and our servers. This ensures that your personal data remains confidential during transit.
b.Access Control: We restrict access to your personal data to authorized personnel only, and access is granted on a need-to-know basis. Our employees and third-party service providers are subject to strict confidentiality obligations.
c.Regular Security Audits: We conduct regular security audits and assessments of our systems and infrastructure to identify and address potential vulnerabilities.
d.Data Backup: We regularly back up your data to prevent data loss and ensure business continuity in the event of unforeseen circumstances.
e.Incident Response Plan: We have established an incident response plan to promptly address any data breaches or security incidents and to notify the appropriate authorities and affected individuals, as required by law.
f.User Authentication: We implement strong user authentication methods to ensure that only authorized users have access to your account and personal data.

While we take every reasonable precaution to safeguard your data, it is important to note that no system can be entirely immune to security risks. We encourage you to take steps to protect your personal data, such as using strong and unique passwords, keeping your login credentials confidential, and immediately reporting any suspicious activity.

In the event of a data breach that could result in a high risk to your rights and freedoms, we will notify you and the appropriate regulatory authorities in accordance with legal requirements. Our commitment is to continuously enhance our security practices to ensure the safety of your personal data.

10

Cookies

Our website may use cookies to optimize the customer's experience. Cookies are small files placed on your computer's hard drive that enables the website to identify your computer as you view different pages. Cookies allow websites and applications to store your preferences in order to present contents, options or functions that are specific to you. Like most interactive websites, our website uses only encrypted session cookies which are erased either after a predefined timeout period or once the user logs out of the platform and closes the browser. Session cookies do not collect information from the user's computer or device. They will typically store information in the form of a session identification that does not personally identify the user.

You may be able to refuse or disable cookies by adjusting your device browser settings. Since each browser is different, please go through the instructions provided by your browser. Please note that you may need to take further steps to refuse or disable certain types of cookies. For instance, due to the differences in how browsers and mobile apps function, you may need to take different steps to opt out of cookies used for targeted advertising in a browser and to opt out of targeted advertising for a mobile application, which you may control through your device settings or mobile apps permissions. In addition, your opt-out selection is specific to the particular browser or device that you are using when you opt out, so you may need to opt-out separately for each browser or device. If you choose to refuse, disable, or delete cookies some of the functionality of the Platform may no longer be available to you.

We do not have access or control over the cookies of our partners, affiliates, and service providers. We are therefore not responsible for the use of their cookies.

11

Automated Decision-Making and Profiling

[We do not use automated decision-making, including profiling, to process your personal data.]

OR

[We may employ automated decision-making and profiling processes to evaluate the eligibility and suitability for the connection between buyers and sellers of real estate in Nigeria or anywhere in the world. These processes utilize algorithms and data analysis to assess various factors, including your preference of the type of real estate that you want to invest in as a buyer and the type of real estate that a seller wants to trade off or any other relevant information. The purpose of these automated processes is to make well-informed decisions that enhance our services and ensure they meet your specific needs.

You have the right to object to the use of automated decision-making and profiling processes. If you believe that the outcomes are unfair or inaccurate, you can request human intervention in the decision-making process. We will also provide you with the opportunity to express your point of view, provide additional information, and challenge the decision.]

12

Personal Data Breach

A data breach protocol has been set up to address such incidents that bother on accidental and unlawful destruction, loss, unauthorized access or disclosure of Personal Data that is transmitted, stored or processed.

We will investigate any reported breach to determine its authenticity and the necessary steps to manage it. Additionally, we will also notify you and other relevant authorities promptly in line with the Nigerian Data Protection Act and the Nigeria Data Protection Regulation in high-risk instances.

We shall also agree on appropriate measures to compensate for the breach within a month of notifying you.

13

Third-Party Links

This website may include links to third-party websites ("links"), plug-ins and applications as certain transactions processing channels may require these links. Clicking on these links or enabling those connections may allow third-parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit. Furthermore, you should evaluate the security and trustworthiness of any other site connected to this website or accessed through this site yourself before disclosing any personal information to it.

14

Our Policy Towards Children

Our Platform is not intended for minors who are under the age of 18 and we do not knowingly collect data from children under the age of 18. If you become aware that your child has provided us with personal data without your consent, please send an email to [insert support email address]. If we become aware that a child under the age of 18 has provided us with personal information, we take steps to remove such information and terminate the child's account.

15

Right to Lodge a Complaint

If you believe that your data protection rights have been violated, you can contact the person you usually deal with at Shugaland. The complaint will be investigated and you will be provided with an information of how this will be handled.

If after a month, you still feel that the violation of your data protection rights has not been resolved, you have the right to lodge a complaint with the Nigeria Data Protection Commission.

16

Privacy Policy Update

Shugaland reserves the right to update or modify this Privacy Notice to reflect changes in our data processing practices or legal requirements. We will notify you of any material changes by posting the updated notice on our platform or by other means of communication, where appropriate. We encourage you to review this notice periodically to stay informed about how we are protecting your personal data.

Your continued access to our use of the Platform after the date of the updated policy constitutes your acceptance of the updated policy. If you do not agree to the updated policy, you must stop using or accessing the Platform.

17

Contact Us

If you have any questions, concerns, or requests regarding your personal data and this Privacy Policy, please contact us using the details in section 1 above.

Contact Information

Shugaland Technologies Inc.

[email protected]

We are committed to protecting your privacy and ensuring a secure and reliable experience.

By using Shugaland, you agree to the terms outlined in this Privacy Policy.