Privacy Policy

1. Scope of This Policy

This Privacy Policy applies to personal data collected through:

• the Aceroyal Estates website;
• Aceroyal Estates mobile applications;
• customer and property portals;
• online enquiry and inspection forms;
• email, telephone and other official communication channels;
• property purchases, subscriptions and related transactions; and
• other services operated by or on behalf of Aceroyal Estates.

This Policy does not apply to third-party websites, applications or services that we do not control.

2. Personal Information We Collect

The information we collect depends on how you interact with us.

a. Identity and Contact Information

We may collect:

• full name;
• email address;
• telephone number;
• residential or correspondence address;
• date of birth where required;
• occupation or other identification information where relevant to a transaction; and
• government-issued identification details where required for property documentation, identity verification or regulatory purposes.

b. Account Information

Where you create an account on our digital platforms, we may collect:

• account username or identifier;
• encrypted authentication credentials;
• account preferences;
• account activity; and
• information necessary to authenticate and secure your account.

We do not store passwords in readable form.

c. Property and Transaction Information

We may collect information relating to:

• properties you enquire about or purchase;
• inspection bookings;
• reservations and allocations;
• payment plans;
• transaction history;
• invoices and receipts;
• payment references;
• property documentation;
• ownership or allocation records; and
• communications relating to your transaction.

d. Payment Information

Where payments are made through third-party payment processors or financial institutions, we may receive transaction references, payment status and other information necessary to reconcile your payment.

We do not intentionally store full payment-card information where payment processing is handled by an authorised third-party payment provider.

e. Communications

We may retain information you provide when you:

• contact customer support;
• submit an enquiry;
• make a complaint;
• send us an email;
• communicate with us by telephone or messaging platforms; or
• respond to surveys, promotions or marketing campaigns.

f. Technical and Usage Information

When you use our website, mobile application or other digital services, certain information may be collected automatically, including:

• IP address;
• browser type;
• device type;
• operating system;
• device identifiers;
• referring pages;
• pages or features viewed;
• date and time of access;
• session information;
• crash and diagnostic information; and
• general usage and interaction data.

3. How We Collect Personal Information

We may collect personal information:

• directly from you;
• when you create an account;
• when you submit an enquiry or inspection request;
• when you purchase or reserve a property;
• when you complete transaction documents;
• when you communicate with us;
• automatically through our websites and applications;
• through authorised agents or representatives;
• through payment providers and financial institutions; and
• from other lawful sources where necessary for a transaction or legal obligation.

4. Why We Process Your Personal Information

We may process personal data for the following purposes:

• responding to enquiries;
• arranging property inspections;
• providing information about available properties;
• creating and managing customer accounts;
• processing reservations and property transactions;
• processing and reconciling payments;
• preparing transaction and property documentation;
• verifying customer information;
• managing allocations and ownership records;
• providing customer support;
• sending transaction-related notifications;
• communicating important service updates;
• maintaining and improving our websites, mobile applications and digital services;
• preventing fraud, misuse and unauthorised access;
• maintaining security and business continuity;
• complying with legal, regulatory, tax and record-keeping obligations;
• resolving complaints and disputes;
• enforcing contractual rights; and
• sending marketing communications where permitted by law.

5. Lawful Bases for Processing

Depending on the circumstances, we process personal information on one or more lawful bases, including:

Consent

Where you have given us permission to process your information for a specific purpose, such as certain marketing communications. You may withdraw your consent at any time, although this will not affect processing that was lawful before your withdrawal.

Performance of a Contract

Where processing is necessary to:

• respond to steps you request before entering into a transaction;
• process a property purchase or reservation;
• administer your account;
• fulfil our obligations under an agreement; or
• provide requested services.

Legal Obligation

Where we are required to process or retain information to comply with applicable laws, court orders, regulatory requirements or lawful requests from authorities.

Legitimate Interests

Where processing is reasonably necessary for our legitimate business interests, provided those interests do not override your rights and freedoms. This may include:

• protecting our systems;
• preventing fraud;
• improving our services;
• maintaining business records;
• managing customer relationships; and
• analysing how our services are used.

Other lawful bases permitted by applicable data protection law may also apply where appropriate.

6. Mobile Application Permissions

Our mobile applications may request access to certain device features where necessary to provide specific functionality.

Depending on the features you use, this may include access to:

• notifications;
• camera or photo library for uploading documents or images;
• files or storage for downloading or uploading documents; or
• other device capabilities required by a feature.

We will request device permissions only where reasonably necessary.

You may manage or revoke permissions through your device settings, although doing so may affect the functionality of certain features.

We do not access your contacts, microphone, camera or other sensitive device features without an appropriate purpose and the permissions required by your device or applicable law.

7. Cookies and Similar Technologies

Our website and digital services may use cookies and similar technologies to:

• keep the website functioning;
• maintain sessions;
• remember preferences;
• understand website usage;
• identify technical issues;
• improve user experience; and
• measure the performance of our digital services.

Some cookies may be necessary for the website to operate, while others may relate to analytics, preferences or other optional functions.

Where consent is legally required for non-essential cookies or similar technologies, we will provide an appropriate choice before using them.

You may also manage cookies through your browser settings.

8. Marketing Communications

With your consent or where otherwise permitted by law, we may send you information about:

• new properties;
• investment opportunities;
• promotions;
• events;
• property launches;
• service updates; and
• other Aceroyal Estates offerings.

You may unsubscribe from promotional communications at any time using the unsubscribe option provided in the communication or by contacting us.

Service-related or transaction-related communications may still be sent where necessary to provide services you have requested.

9. How We Share Personal Information

We do not sell or rent personal information.

We may disclose personal information where reasonably necessary to:

Service Providers

We may use trusted third parties to provide services such as:

• website and cloud hosting;
• payment processing;
• email delivery;
• communications;
• analytics;
• cybersecurity;
• document management;
• customer support;
• professional services; and
• information technology support.

Such providers are permitted to process personal data only for authorised purposes and are expected to protect it appropriately.

Professional Advisers

We may share information with lawyers, auditors, accountants, consultants, surveyors or other professional advisers where reasonably necessary.

Financial Institutions and Payment Providers

Where necessary to process, confirm or reconcile transactions.

Government and Regulatory Authorities

We may disclose personal information where required by law, regulation, court order or other lawful authority.

Business Transactions

Where Aceroyal Estates undergoes a merger, acquisition, restructuring, financing, sale of assets or similar corporate transaction, relevant information may be disclosed subject to appropriate confidentiality and data-protection safeguards.

With Your Authorisation

We may share personal data with another party where you have specifically authorised us to do so.

10. International Transfers

Some of our technology providers or service providers may store or process information outside Nigeria.

Where personal data is transferred outside Nigeria, Aceroyal Estates will take appropriate steps required under applicable data protection law to ensure that the information receives an adequate level of protection.

These measures may include appropriate contractual, organisational or other lawful safeguards.

11. Data Security

We implement reasonable technical and organisational measures designed to protect personal information against:

• unauthorised access;
• unlawful processing;
• accidental loss;
• alteration;
• disclosure;
• destruction; and
• misuse.

These measures may include:

• encrypted communication;
• access controls;
• authentication mechanisms;
• restricted administrative access;
• secure hosting;
• system monitoring;
• regular software updates;
• security reviews; and
• internal data-handling procedures.

While we take reasonable steps to protect your information, no internet-based system or electronic storage method can be guaranteed to be completely secure.

12. Data Retention

We retain personal information only for as long as reasonably necessary for the purpose for which it was collected or as required by applicable law.

Retention periods may vary depending on:

• the nature of the information;
• whether you have an active account;
• the duration of a property transaction;
• contractual requirements;
• legal or regulatory obligations;
• tax and accounting requirements;
• dispute-resolution requirements; and
• legitimate business record-keeping needs.

When personal information is no longer required, we will take reasonable steps to securely delete, anonymise or otherwise dispose of it.

13. Your Data Protection Rights

Subject to applicable law and any lawful exceptions, you may have the right to:

• request confirmation of whether we process your personal data;
• request access to personal data we hold about you;
• request correction of inaccurate or incomplete information;
• request deletion of personal information in appropriate circumstances;
• object to certain processing;
• request restriction of processing;
• withdraw consent where processing is based on consent;
• request data portability where applicable;
• object to certain direct-marketing activities; and
• lodge a complaint regarding our handling of your personal information.

A request to delete information may not always result in immediate deletion where we are required or permitted to retain the information for legal, contractual, regulatory, security or legitimate record-keeping purposes.

We may request reasonable information to verify your identity before responding to a data-rights request.

14. Account Deletion

Where our mobile application or customer platform provides user accounts, you may request deletion of your account through the available account-deletion feature or by contacting us.

Deleting an account does not necessarily require us to delete information that we are legally required to retain, including information relating to completed property transactions, financial records or regulatory obligations.

15. Children and Minors

Our property services are primarily intended for adults who have the legal capacity to enter into property transactions.

We do not knowingly collect personal information directly from children for ordinary marketing, account-registration or property-purchase purposes.

Where information relating to a minor is legitimately required in connection with property ownership, inheritance, guardianship or another lawful transaction, we will process such information only where appropriate legal authority, consent or other lawful basis exists.

If you believe that a child's personal information has been provided to us improperly, please contact us so that we can take appropriate action.

16. Third-Party Websites and Services

Our websites and applications may contain links to third-party websites, platforms or services.

Aceroyal Estates is not responsible for the privacy practices, security or content of third parties that we do not control.

We encourage you to review the privacy policies of any third-party service before providing personal information.

17. Automated Decision-Making

Aceroyal Estates does not ordinarily make significant decisions about customers solely through automated processing.

If we introduce automated decision-making that produces legal or similarly significant effects, we will provide appropriate information and safeguards as required by applicable law.

18. Data Breaches

If a personal-data breach occurs, we will take reasonable steps to:

• contain and investigate the incident;
• reduce potential harm;
• secure affected systems; and
• notify affected individuals or relevant authorities where required by applicable law.

19. Complaints

If you have a concern about how Aceroyal Estates processes your personal information, we encourage you to contact us first so we can investigate and respond.

You also have the right, where applicable, to lodge a complaint with the Nigeria Data Protection Commission or another competent regulatory authority.

20. Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect:

• changes to our services;
• changes to our technology;
• operational developments; or
• changes in legal or regulatory requirements.

When we update this Policy, we will revise the “Last updated” date.

Where an update materially changes how we process personal information, we will take reasonable steps to provide additional notice where required.