Section 1 — Introduction
C-Homes Technologies Ltd ("CHomes", "we", "our", "us") operates a digital property management platform (the "Platform") designed to support estate administrators, landlords, residents, and security personnel in managing residential properties and related services across Nigeria.
CHomes Technologies Ltd acts as the Data Controller for all personal data processed through the Platform. As Data Controller, we are responsible for ensuring that personal data is collected, processed, stored, and protected in accordance with the Nigeria Data Protection Act (NDPA) 2023 and all other applicable data protection regulations.
This Privacy Policy explains how we collect, use, store, share, and safeguard your personal data when you access or use the Platform. It applies to all users including residents, tenants, landlords, estate administrators, and security personnel.
If you do not agree with this Privacy Policy, you must not access or use the CHomes Platform.
Section 2 — Scope of This Policy
This Privacy Policy applies to:
- The CHomes mobile applications (iOS and Android)
- The CHomes web platform
- All services, features, and interactions provided through the Platform
By accessing or using the Platform, you acknowledge that you have read, understood, and agree to the terms of this Privacy Policy. This Policy should be read alongside our Terms of Service.
Section 3 — Information We Collect
We collect personal data through information you provide directly when creating an account or using the Platform, automated data collection through your use of the Platform, and interactions between users and system activity. We collect only the personal data necessary to provide and improve our services.
3.1 Personal Identification Information
- Full name
- Phone number
- Email address
- Residential address
3.2 Property & Residency Information
- Property unit details and estate affiliation
- Landlord–tenant relationships
- Occupancy and tenancy records
3.3 Financial & Transaction Data
- Payment records (rent, service charges, fees)
- Transaction confirmations and payment history
CHomes does not store debit or credit card details or bank account credentials. All payments are processed securely via Paystack. CHomes does not hold, control, or store user funds.
3.4 Access & Gate Activity Data
As a platform that manages physical estate access, CHomes collects and processes gate and access-related data, including:
- Gate entry and exit logs (timestamps and user identity)
- Visitor access records and approvals
- Security event logs
- Access permissions assigned to residents, staff, and visitors
Access and gate activity data is sensitive. It is retained only for the purposes of estate security management and is accessible only to authorised estate administrators and security personnel on a role-based basis.
3.5 Communication Data
- Messages between users (resident to landlord, resident to estate admin)
- Estate-wide announcements and notifications
- Customer support interactions
3.6 Technical & Usage Data
- IP address and device type
- Operating system and app version
- Log data including login times and activity history
- App usage behaviour and feature interactions
- Cookie and session data (web platform)
Section 4 — How We Use Your Information
We use your personal data strictly for the purpose of providing, maintaining, and improving the CHomes Platform and related services. Specifically, we use your information to:
- Provide, operate, and maintain the Platform and its features
- Manage property, tenancy, and estate relationships
- Facilitate and record payments processed via Paystack and other authorised service providers
- Manage and log gate and estate access events for security purposes
- Enable communication between users within the Platform
- Provide customer support and respond to inquiries
- Improve platform functionality, performance, and user experience
- Monitor usage, enforce platform rules, and detect fraudulent, abusive, or unauthorised activity
- Maintain the security, integrity, and reliability of the Platform
- Comply with applicable legal and regulatory obligations
Communication features are intended strictly for property-related interactions. CHomes may monitor, review, and take appropriate action where there is suspected misuse of the Platform, in accordance with applicable laws.
CHomes will not process personal data for purposes incompatible with those outlined in this Privacy Policy.
Section 5 — Legal Basis for Processing
CHomes processes personal data only where there is a lawful basis to do so under the Nigeria Data Protection Act (NDPA) 2023 and applicable data protection laws.
- Consent — Where you have provided clear, informed consent for specific processing activities, such as account creation and use of the Platform.
- Contractual Necessity — Where processing is necessary to provide the services you have requested, including managing property relationships and facilitating platform functionality.
- Legal Obligations — Where processing is required to comply with applicable Nigerian laws, regulations, or lawful requests from authorities.
- Legitimate Interests — Where processing is necessary for the operation, security, and improvement of the Platform, provided such interests do not override your fundamental rights and freedoms.
Section 6 — Data Sharing & Disclosure
CHomes shares personal data only where necessary to provide the Platform and in accordance with this Privacy Policy. All third-party data sharing is subject to appropriate contractual and confidentiality obligations.
CHomes does not sell, rent, or trade personal data to any third party under any circumstance.
6.1 Payment Processors
We share relevant transaction data with Paystack for the purpose of secure payment processing. Data shared is limited strictly to what is necessary to facilitate the transaction.
6.2 Cloud & Technical Service Providers
We work with third-party providers for cloud hosting, analytics, and technical infrastructure. These providers process data on our behalf and are contractually required to maintain appropriate data protection and security standards. They do not use your data for their own purposes.
6.3 Estate & Property Stakeholders
Data is shared with estate administrators and landlords on a strict role-based basis:
- Estate Administrator — Can access resident profiles, unit assignments, payment status, gate access logs, visitor records, and estate-wide communications. Cannot access individual payment credentials or private messages between residents and landlords.
- Landlord — Can access tenancy records, payment history for their units, and occupancy status. Cannot access gate access logs, visitor records, communications unrelated to their units, or other landlords' data.
- Security Personnel — Can access gate access logs, visitor approvals, and real-time access events for their estate. Cannot access payment data, financial records, or private communications.
6.4 Legal & Regulatory Authorities
We may disclose personal data where required to comply with applicable Nigerian laws, regulations, legal processes, or lawful requests from governmental or regulatory authorities. CHomes will take reasonable steps to notify affected users of such disclosures where legally permitted to do so.
Section 7 — Data Retention
CHomes retains personal data only for as long as necessary to fulfil the purposes outlined in this Privacy Policy, provide our services, and comply with legal and regulatory obligations.
- Active account data — Retained for the duration of active account use.
- Inactive account data — Retained for up to 24 months from last activity, then deleted or anonymised.
- Financial & transaction records — Retained for 6 years from date of transaction, in accordance with Nigerian tax and financial regulatory requirements.
- Gate & access activity logs — Retained for 12 months from date of event, then deleted.
- Communication data — Retained for the duration of the account, then deleted or anonymised on closure.
- Technical & usage data — Retained for up to 12 months from collection.
Where a user requests account deletion, CHomes will take reasonable steps to delete or anonymise personal data within 30 days, except where retention is required for legal, regulatory, or legitimate business purposes.
Section 8 — Data Security
CHomes implements industry-standard technical and organisational safeguards to protect personal data against unauthorised access, disclosure, alteration, or destruction. Our security measures include:
- Encryption of sensitive data in transit and at rest
- Secure authentication mechanisms including two-factor authentication for administrative accounts
- Role-based access control ensuring users can only access data relevant to their role
- Restricted administrative access to production systems and databases
- Continuous monitoring, logging, and audit trails for system activity
- Regular security reviews and updates to our infrastructure and practices
While we take reasonable steps to protect your data, no method of transmission over the internet or electronic storage is completely secure. CHomes cannot guarantee absolute security of personal data.
Users are responsible for maintaining the confidentiality of their login credentials and for all activities conducted under their accounts. Users must promptly notify CHomes of any suspected unauthorised access or security breach via the contact details in Section 16.
Section 9 — Cookies & Tracking Technologies
The CHomes web platform uses cookies and similar tracking technologies to support the functionality, security, and performance of the Platform.
- Session management — to keep you logged in during your session
- Security — to detect and prevent fraudulent or unauthorised activity
- Performance monitoring — to understand how the Platform is used and improve functionality
- Preferences — to remember your settings and choices
You may configure your browser to refuse cookies or to alert you when cookies are being set. Please note that disabling certain cookies may affect the functionality of the Platform. CHomes does not use cookies to serve third-party advertising.
Section 10 — Cross-Border Data Transfers
CHomes may process or store personal data on servers located outside Nigeria through the use of third-party cloud infrastructure and technical service providers.
By using the Platform, you acknowledge and consent to the transfer, storage, and processing of your data outside Nigeria where necessary for the operation of our services.
CHomes takes reasonable steps to ensure that all cross-border data transfers are conducted in compliance with the Nigeria Data Protection Act (NDPA) 2023, including implementing appropriate contractual safeguards with our service providers.
Section 11 — Your Rights
Under the Nigeria Data Protection Act (NDPA) 2023, you have the following rights regarding your personal data:
- Right of Access — You may request a copy of the personal data we hold about you.
- Right to Rectification — You may request correction of inaccurate or incomplete personal data.
- Right to Erasure — You may request deletion of your personal data, subject to legal and regulatory retention requirements.
- Right to Withdraw Consent — Where processing is based on consent, you may withdraw it at any time.
- Right to Object — You may object to certain types of data processing, including processing based on legitimate interests.
- Right to Lodge a Complaint — You have the right to lodge a complaint with the Nigeria Data Protection Commission (NDPC) or other relevant regulatory authority.
To exercise any of the above rights, contact us using the details in Section 16. CHomes will acknowledge your request within 72 hours and resolve it within 30 days, in accordance with the NDPA 2023.
Section 12 — Third-Party Services
CHomes integrates with third-party service providers to support the functionality of the Platform, including payment processing, cloud hosting, analytics, and other technical services. These providers operate independently and are governed by their own privacy policies.
The Platform may also contain links to external services or websites. CHomes is not responsible for the privacy practices or content of such external services.
Section 13 — Children's Privacy
The CHomes Platform is not intended for individuals under the age of 18. CHomes does not knowingly collect or process personal data from minors. If we become aware that personal data has been collected from an individual under the age of 18 without appropriate authorisation, we will take steps to delete such data promptly.
Section 14 — Data Breach Notification
In the event of a data breach that may compromise the security, confidentiality, or integrity of personal data, CHomes will:
- Take immediate steps to investigate, contain, and mitigate the impact of the breach
- Notify the Nigeria Data Protection Commission (NDPC) within 72 hours of becoming aware of the breach where required under the NDPA 2023
- Notify affected users without undue delay where the breach poses a high risk to their rights and freedoms
- Maintain a formal record of all data breaches, their effects, and the remedial actions taken
Section 15 — Changes to This Privacy Policy
CHomes may update or modify this Privacy Policy from time to time to reflect changes in our practices, services, or legal obligations. Any updates will be reflected by revising the "Last Updated" date at the top of this Policy. Continued use of the Platform after any updates constitutes acceptance of the revised Privacy Policy.
Section 16 — Contact Information
For questions, requests, complaints, or to exercise your data rights under this Privacy Policy, please contact CHomes using the details below:
- Company: C-Homes Technologies Ltd
- Privacy Email: support@chomes.ng
- Address: 15, Trans-Amadi Industrial Layout Road, Port Harcourt, Rivers State, Nigeria
- Response Timeframe: Acknowledgement within 72 hours · Resolution within 30 days