Privacy Policy

This Privacy Policy ("Policy") describes how Global Propylink Platforms Ltd, doing business as Homesngr ("Company," "we," "us," or "our"), a technology company incorporated under the laws of the Federal Republic of Nigeria with its principal office located in the Federal Capital Territory, Abuja, Nigeria, collects, uses, stores, shares, and protects personal data and other information relating to individuals ("you," "your," or "User") who access or use the Homesngr website, mobile applications, and all related platforms, tools, and services (collectively, the "Platform").

By accessing, browsing, or using the Platform, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy. If you do not agree with the terms of this Privacy Policy, you must immediately discontinue use of the Platform. This Policy should be read in conjunction with our Terms of Service, Cookie Policy, and any other supplementary notices or policies we may provide from time to time.

We are committed to protecting your personal information and your right to privacy in accordance with the Nigeria Data Protection Regulation (NDPR), the Nigeria Data Protection Act 2023 (NDPA), and other applicable data protection and privacy laws.

1. DEFINITIONS AND INTERPRETATION

For the purposes of this Privacy Policy, the following definitions shall apply:

"Personal Data" means any information relating to an identified or identifiable natural person, including but not limited to a name, identification number, location data, online identifier, or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

"Processing" means any operation or set of operations performed on Personal Data, whether or not by automated means, including collection, recording, organisation, structuring, storage, adaptation, alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.

"Data Controller" means the entity that determines the purposes and means of the Processing of Personal Data. For the purposes of this Policy, Homesngr is the Data Controller.

"Data Processor" means a natural or legal person, public authority, agency, or other body that processes Personal Data on behalf of the Data Controller.

"Data Subject" means an identified or identifiable natural person whose Personal Data is being processed.

"Consent" means any freely given, specific, informed, and unambiguous indication of the Data Subject's wishes by which the Data Subject, by a statement or by a clear affirmative action, signifies agreement to the Processing of Personal Data relating to him or her.

"Third Party" means a natural or legal person, public authority, agency, or body other than the Data Subject, the Data Controller, the Data Processor, and persons who, under the direct authority of the Data Controller or Data Processor, are authorised to process Personal Data.

2. INFORMATION WE COLLECT

2.1 Personal Data You Provide Directly

We collect Personal Data that you voluntarily provide to us when you register for an account on the Platform, list a property, submit an application, make a purchase, communicate with us, or otherwise interact with the Platform. The categories of Personal Data we may collect include, but are not limited to:

(a) Identity Data: Full legal name, date of birth, gender, photograph, government-issued identification documents (such as National Identification Number, International Passport, Driver's Licence, or Voter's Card), and professional credentials (for lawyers, developers, and agents).

(b) Contact Data: Email address, telephone number, residential address, mailing address, and emergency contact information.

(c) Account Data: Username, password, account preferences, security questions and answers, and profile information.

(d) Financial Data: Bank account details, debit or credit card numbers, billing address, transaction history, payment instrument details, and financial statements submitted for verification purposes.

(e) Property Data: Property descriptions, photographs, videos, location coordinates, pricing information, title documents, survey plans, certificates of occupancy, deed of assignment, and any other documents relating to properties listed, searched for, or transacted on the Platform.

(f) Professional Data: For legal professionals, real estate developers, and agents using the Platform, we may collect professional credentials, bar association membership details, areas of practice, company registration documents, professional references, and portfolio information.

(g) Employment Data: For career applicants, we collect resumes, cover letters, employment history, educational qualifications, salary expectations, and professional references.

(h) Communication Data: Messages, enquiries, feedback, complaints, and any other correspondence submitted through the Platform's messaging system, contact forms, or email.

(i) User-Generated Content: Reviews, ratings, testimonials, forum posts, community contributions, and any other content you voluntarily publish on the Platform.

2.2 Information Collected Automatically

When you access or use the Platform, we automatically collect certain technical and usage information. This information does not, on its own, directly identify you by name but may be used in conjunction with other data to identify you. Automatically collected information includes:

(a) Device Information: Device type, operating system and version, browser type and version, device identifiers (including IMEI, advertising ID, and similar unique identifiers), screen resolution, and hardware specifications.

(b) Log Data: Internet Protocol (IP) address, access dates and times, pages viewed, time spent on pages, referring and exit URLs, clickstream data, and error logs.

(c) Location Data: Approximate geographic location derived from your IP address, and, where you grant permission, precise geolocation data from your mobile device or browser.

(d) Cookies and Similar Technologies: Information collected through cookies, web beacons, pixel tags, local storage, and similar tracking technologies. For detailed information about our use of cookies, please refer to our Cookie Policy.

2.3 Information from Third-Party Sources

We may receive Personal Data about you from third-party sources, including identity verification services, credit reference agencies, government registries, social media platforms (where you choose to link your social media account), business partners, real estate regulatory bodies, and other publicly available sources. We may combine this information with data we already hold to verify your identity, assess risk, improve our services, and comply with our legal obligations.

3. LEGAL BASIS FOR PROCESSING

We process your Personal Data only where we have a lawful basis to do so. The legal bases upon which we rely include:

(a) Consent: Where you have given clear, informed, and unambiguous consent for us to process your Personal Data for one or more specific purposes. You have the right to withdraw your consent at any time, though withdrawal shall not affect the lawfulness of processing carried out prior to such withdrawal.

(b) Contractual Necessity: Where the Processing is necessary for the performance of a contract to which you are a party, or to take steps at your request prior to entering into a contract. This includes processing required to provide our services, manage your account, and facilitate property transactions.

(c) Legitimate Interests: Where the Processing is necessary for the purposes of our legitimate business interests or those of a Third Party, provided that such interests are not overridden by your fundamental rights and freedoms. Our legitimate interests include fraud prevention, network and information security, direct marketing, and improving our services.

(d) Legal Obligation: Where the Processing is necessary for compliance with a legal obligation to which we are subject under Nigerian law or any other applicable jurisdiction, including but not limited to anti-money laundering regulations, tax laws, and court orders.

(e) Vital Interests: Where the Processing is necessary to protect the vital interests of the Data Subject or another natural person, such as in cases of fraud, threats to personal safety, or emergency situations.

4. HOW WE USE YOUR INFORMATION

We use the Personal Data we collect for the following purposes:

4.1 Service Delivery

• To create, maintain, and manage your user account.
• To facilitate property listings, searches, enquiries, and transactions.
• To process payments, commissions, and refunds.
• To connect property buyers, sellers, renters, developers, and legal professionals.
• To enable messaging and communication between users of the Platform.
• To provide customer support and respond to enquiries.
• To process career applications and manage recruitment activities.

4.2 Verification and Security

• To verify your identity and the authenticity of documents submitted.
• To detect, prevent, and investigate fraud, money laundering, and other illegal activities.
• To enforce our Terms of Service, Community Guidelines, and other policies.
• To monitor and protect the security and integrity of the Platform.
• To conduct risk assessments and due diligence checks.

4.3 Communication

• To send you transactional communications, including order confirmations, account notifications, and service updates.
• To send administrative communications relating to changes in our policies or terms.
• To send marketing and promotional communications, subject to your preferences and applicable law. You may opt out of marketing communications at any time by clicking the "unsubscribe" link in our emails or by contacting us directly.

4.4 Analytics and Improvement

• To analyse usage patterns, trends, and user behaviour on the Platform.
• To conduct internal research and development to improve our products and services.
• To personalise your experience and deliver content relevant to your interests.
• To measure the effectiveness of our marketing campaigns and advertising.

4.5 Legal and Regulatory Compliance

• To comply with applicable laws, regulations, court orders, and governmental directives.
• To respond to lawful requests from law enforcement and regulatory authorities.
• To establish, exercise, or defend legal claims.
• To comply with anti-money laundering and counter-terrorism financing obligations.

5. DISCLOSURE OF YOUR INFORMATION

We may share your Personal Data with the following categories of recipients, solely for the purposes described in this Policy:

(a) Service Providers: Third-party companies and individuals who perform services on our behalf, including payment processors, cloud hosting providers, email service providers, analytics providers, identity verification services, and customer support tools. These service providers are contractually obligated to protect your data and may only process it in accordance with our instructions.

(b) Other Users: In the course of facilitating property transactions, certain information (such as your name, contact details, and property-related information) may be shared with other users of the Platform, including buyers, sellers, tenants, landlords, developers, and legal professionals, as necessary to complete the transaction or service.

(c) Legal Professionals: Where you request legal services through the Platform, relevant information may be shared with verified lawyers and legal practitioners registered on the Platform, subject to professional confidentiality obligations.

(d) Law Enforcement and Regulatory Bodies: We may disclose your Personal Data to law enforcement agencies, courts, regulatory bodies, or other governmental authorities where we are legally required to do so, or where such disclosure is necessary to protect our rights, your safety, the safety of others, or to investigate fraud or respond to a government request.

(e) Business Transfers: In the event of a merger, acquisition, reorganisation, bankruptcy, asset sale, or other business transfer, your Personal Data may be transferred as part of the transaction. We will notify you of any such transfer and any changes to the processing of your data.

(f) Affiliates and Group Companies: We may share your data with our parent company, subsidiaries, and affiliates for purposes consistent with this Policy.

(g) With Your Consent: We may share your Personal Data with Third Parties where you have expressly consented to such disclosure.

6. INTERNATIONAL DATA TRANSFERS

Your Personal Data may be transferred to, stored in, and processed in countries other than Nigeria, including countries where our service providers and technology infrastructure are located. Where such transfers occur, we shall ensure that appropriate safeguards are in place to protect your Personal Data in accordance with this Policy and applicable data protection laws, including:

• Standard contractual clauses approved by the relevant data protection authority.
• Binding corporate rules for intra-group transfers.
• Transfers to countries that have been recognised as providing an adequate level of data protection.
• Any other legally recognised transfer mechanism under the NDPA or NDPR.

By continuing to use the Platform, you acknowledge and consent to the transfer of your Personal Data to jurisdictions outside Nigeria, subject to the safeguards described herein.

7. DATA RETENTION

We will retain your Personal Data only for as long as is reasonably necessary to fulfil the purposes for which it was collected, including to satisfy any legal, regulatory, tax, accounting, or reporting requirements. In determining the appropriate retention period, we consider the amount, nature, and sensitivity of the data, the potential risk of harm from unauthorised use or disclosure, the purposes for which we process your data, and whether we can achieve those purposes through other means.

In general, we will retain your Personal Data for the duration of your account with us and for a period of six (6) years following the termination or closure of your account, or for such longer period as may be required by applicable law. Specific retention periods include:

• Account information: retained for the lifetime of the account plus six (6) years.
• Transaction records: retained for a minimum of six (6) years after the date of the transaction, in accordance with Nigerian tax and commercial laws.
• Communication records: retained for three (3) years after the date of the communication, unless a longer period is required for legal proceedings.
• Identity verification documents: retained for five (5) years after the last transaction or the closure of the account, in accordance with anti-money laundering regulations.
• Marketing consent records: retained for the duration of the consent plus two (2) years.

Upon expiry of the applicable retention period, your Personal Data will be securely deleted, anonymised, or destroyed. Where deletion is not immediately possible (for example, where data is stored in backup archives), we will securely store the data and isolate it from any further processing until deletion is possible.

8. DATA SECURITY

We implement appropriate technical and organisational measures to protect your Personal Data against unauthorised or unlawful processing, accidental loss, destruction, or damage. These measures include, but are not limited to:

• Encryption of Personal Data in transit (using TLS/SSL protocols) and at rest.
• Access controls and authentication mechanisms to restrict access to Personal Data to authorised personnel only.
• Regular security assessments, vulnerability testing, and penetration testing.
• Secure data storage on reputable cloud infrastructure providers with industry-standard certifications.
• Staff training on data protection and information security best practices.
• Incident response and breach notification procedures.
• Regular backups and disaster recovery measures.

Notwithstanding the foregoing, no method of electronic transmission or storage is completely secure, and we cannot guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials and for restricting access to your devices. You must notify us immediately if you become aware of any unauthorised access to or use of your account.

9. COOKIES AND TRACKING TECHNOLOGIES

We use cookies and similar tracking technologies (including web beacons, pixel tags, local storage objects, and software development kits) to collect and store information when you use the Platform. Cookies are small text files placed on your device by a web server that enable us to recognise your device and remember certain information about your visit.

The types of cookies we use include:

(a) Strictly Necessary Cookies: These cookies are essential for the operation of the Platform and enable you to navigate and use its features. They cannot be disabled without impairing the functionality of the Platform.

(b) Analytical and Performance Cookies: These cookies collect information about how you use the Platform, including pages visited, time spent, and error messages. This information is used to improve the performance and user experience of the Platform.

(c) Functionality Cookies: These cookies enable the Platform to remember your preferences (such as language, region, or login details) and provide enhanced, personalised features.

(d) Advertising and Targeting Cookies: These cookies are used to deliver advertisements relevant to your interests and to measure the effectiveness of advertising campaigns. They may be set by us or by Third Party advertising partners.

You may manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the Platform. For further information, please refer to our Cookie Policy.

10. YOUR DATA PROTECTION RIGHTS

Subject to applicable law, you have the following rights in relation to your Personal Data:

(a) Right of Access: You have the right to request confirmation of whether we process your Personal Data, and, where we do, to request access to the Personal Data and information about the processing, including the purposes, categories of data, recipients, and retention periods.

(b) Right to Rectification: You have the right to request the correction of inaccurate Personal Data and the completion of incomplete Personal Data.

(c) Right to Erasure: You have the right to request the deletion of your Personal Data in certain circumstances, including where the data is no longer necessary for the purposes for which it was collected, where you withdraw consent, or where the processing is unlawful. This right is subject to legal and regulatory retention obligations.

(d) Right to Restriction of Processing: You have the right to request the restriction of processing of your Personal Data in certain circumstances, including where the accuracy of the data is contested or where the processing is unlawful but you oppose erasure.

(e) Right to Data Portability: You have the right to receive your Personal Data in a structured, commonly used, and machine-readable format and to transmit that data to another controller, where technically feasible.

(f) Right to Object: You have the right to object to the processing of your Personal Data where the processing is based on legitimate interests or is carried out for direct marketing purposes. Where you object to processing for direct marketing purposes, we will cease such processing without delay.

(g) Right to Withdraw Consent: Where our processing of your Personal Data is based on your consent, you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out prior to the withdrawal.

To exercise any of these rights, please contact us using the contact details set out in Section 16 below. We will respond to your request within thirty (30) days of receipt. We may request additional information to verify your identity before processing your request. Where your request is manifestly unfounded or excessive, we reserve the right to charge a reasonable administrative fee or refuse to act on the request.

If you believe that your data protection rights have been violated, you have the right to lodge a complaint with the Nigeria Data Protection Commission (NDPC) or any other competent supervisory authority.

11. CHILDREN'S PRIVACY

The Platform is not intended for use by individuals under the age of eighteen (18) years. We do not knowingly collect, solicit, or process Personal Data from children under the age of 18. If we become aware that we have inadvertently collected Personal Data from a child under the age of 18, we will take immediate steps to delete such data from our records. If you are a parent or guardian and believe that your child has provided Personal Data to us, please contact us immediately using the contact details set out in Section 16 below.

By using the Platform, you represent and warrant that you are at least eighteen (18) years of age, or that you are using the Platform with the consent and under the supervision of a parent or legal guardian who is at least 18 years of age.

12. THIRD-PARTY LINKS AND SERVICES

The Platform may contain links to third-party websites, applications, or services that are not owned or controlled by Homesngr. This Privacy Policy does not apply to the practices of third parties. We are not responsible for the privacy practices, content, or security of any third-party websites or services. We encourage you to review the privacy policies of any third-party websites or services before providing them with your Personal Data.

Where we integrate third-party services into the Platform (such as payment processors, mapping services, or analytics providers), we ensure that appropriate data processing agreements are in place to protect your Personal Data.

13. DO-NOT-TRACK SIGNALS

Some web browsers and devices offer a "Do Not Track" ("DNT") feature that sends a signal to the websites you visit, indicating that you do not wish to be tracked. As there is currently no universally accepted standard for how companies should respond to DNT signals, the Platform does not currently respond to or honour DNT signals or similar mechanisms. We will review and update this practice if and when a uniform standard for responding to DNT signals is established.

14. DATA BREACH NOTIFICATION

In the event of a Personal Data breach that is likely to result in a risk to your rights and freedoms, we will notify the Nigeria Data Protection Commission (NDPC) without undue delay and, where feasible, within seventy-two (72) hours of becoming aware of the breach, in accordance with the requirements of the NDPA.

Where the breach is likely to result in a high risk to your rights and freedoms, we will also notify you directly without undue delay, providing you with information about the nature of the breach, the likely consequences, and the measures taken or proposed to be taken to address the breach and mitigate its effects. Notification will not be required where we have implemented appropriate technical and organisational protection measures that render the Personal Data unintelligible to any person who is not authorised to access it, or where subsequent measures have been taken to ensure that the high risk to your rights and freedoms is no longer likely to materialise.

15. CHANGES TO THIS PRIVACY POLICY

We reserve the right to update, amend, or modify this Privacy Policy at any time, in our sole discretion, to reflect changes in our data practices, legal requirements, or business operations. When we make material changes to this Policy, we will update the "Last Updated" date at the top of this page and, where required by applicable law, provide you with notice of the changes through the Platform, by email, or by other appropriate means.

Your continued use of the Platform after the posting of the revised Policy constitutes your acceptance of the changes. We encourage you to review this Policy periodically to stay informed about how we collect, use, and protect your Personal Data. If you do not agree with the revised Policy, you must discontinue your use of the Platform.

16. CONTACT INFORMATION

If you have any questions, concerns, or complaints about this Privacy Policy, our data processing practices, or if you wish to exercise any of your data protection rights, please contact us at:

We will endeavour to respond to all legitimate enquiries within thirty (30) days. If you are not satisfied with our response, you have the right to lodge a complaint with the Nigeria Data Protection Commission (NDPC) or any other competent data protection authority in your jurisdiction.

17. GOVERNING LAW AND DISPUTE RESOLUTION

This Privacy Policy shall be governed by and construed in accordance with the laws of the Federal Republic of Nigeria, including the Nigeria Data Protection Act 2023 (NDPA), the Nigeria Data Protection Regulation (NDPR), and any subsidiary legislation, guidelines, or directives issued by the Nigeria Data Protection Commission (NDPC).

Any dispute, controversy, or claim arising out of or in connection with this Privacy Policy, including the validity, interpretation, or breach thereof, shall be resolved exclusively by the competent courts located in the Federal Capital Territory (FCT), Abuja, Nigeria, and you hereby consent to the exclusive jurisdiction and venue of such courts.

18. SEVERABILITY

If any provision of this Privacy Policy is held to be invalid, illegal, or unenforceable by a court of competent jurisdiction, such provision shall be modified to the minimum extent necessary to make it valid, legal, and enforceable, and the remaining provisions of this Policy shall continue in full force and effect. The invalidity or unenforceability of any provision in one jurisdiction shall not affect the validity or enforceability of such provision in any other jurisdiction.

19. ENTIRE AGREEMENT

This Privacy Policy, together with our Terms of Service, Cookie Policy, and any other policies or notices referenced herein, constitutes the entire agreement between you and Homesngr with respect to the collection, use, and processing of your Personal Data through the Platform, and supersedes all prior or contemporaneous understandings, agreements, representations, and warranties, whether written or oral, with respect to the subject matter hereof.