ETenant is committed to fair, lawful and transparent personal-data processing. This policy is designed around the Nigeria Data Protection Act 2023 and other applicable privacy obligations.
1 Scope and roles
This policy applies to visitors, landlords, property owners, property managers, staff, tenants, applicants, accountants, service providers and other users of ETenant.
Depending on the service, ETenant may act as a data controller for account, security, subscription and platform-administration data, or as a processor/service provider for data managed by an organization using ETenant.
2 Personal data we collect
- Identity and account data: name, user code, date of birth, nationality, identification details, profile image, role and account status.
- Contact data: email address, phone number, address and emergency contacts.
- Organization and property data: organization, branch, department, properties, units, ownership, leases and occupancy records.
- Tenant and application data: preferences, employment, income-related details, references, applications, screening information and KYC records.
- Financial data: invoices, rent, service charges, deposits, payment references, methods, gateway responses, refunds and reconciliation records.
- Maintenance data: requests, descriptions, photos, access permission, schedules, assigned providers and resolution records.
- Communications: notifications, support enquiries and platform messages.
- Technical and security data: IP address, user agent, device name, session hashes, login activity, audit events, system logs and security alerts.
- Documents: lease agreements, receipts, identity documents, inspection records and other uploaded files.
3 How we use personal data
- Create, authenticate, secure and administer accounts.
- Provide property, lease, tenant, rent, payment, maintenance, document and communication services.
- Verify identity, prevent fraud and meet KYC or compliance requirements.
- Process subscriptions, invoices, rent payments, refunds and financial reconciliation.
- Send transactional notices, reminders, security alerts and service communications.
- Provide customer support, diagnose technical problems and maintain audit trails.
- Measure service performance, improve usability and develop platform functionality.
- Comply with legal obligations, lawful requests, dispute resolution and enforcement.
4 Lawful bases
Depending on the processing activity, ETenant relies on one or more lawful bases, including:
- Performance of a contract or steps requested before entering a contract.
- Consent, where consent is appropriate and can be withdrawn.
- Compliance with legal obligations.
- Legitimate interests such as platform security, fraud prevention, service improvement and business administration, balanced against user rights.
- Protection of vital interests where urgent safety matters arise.
- Other bases permitted by applicable law.
5 How data is shared
Personal data may be shared only where reasonably necessary with:
- The organization, landlord, property manager, tenant, owner, accountant or staff connected to the relevant tenancy or workspace.
- Service providers and maintenance vendors assigned to legitimate work, limited to the information needed for the assignment.
- Payment gateways, banks and financial-service providers for transaction processing and verification.
- Hosting, email, messaging, analytics, security, backup and technical-support providers.
- Professional advisers, auditors, insurers and regulators.
- Law-enforcement or public authorities where disclosure is legally required.
- A purchaser, investor or successor in a lawful corporate transaction, subject to appropriate safeguards.
ETenant does not sell personal data as a standalone product. Access within an organization is controlled through roles, permissions and tenancy relationships.
6 Payments and financial information
Payment transactions may be processed by third-party gateways. ETenant may store transaction references, status, amount, currency, channel, payer details and gateway responses, but should not store full payment-card credentials unless specifically designed and certified to do so.
Payment providers process information under their own privacy policies and regulatory obligations.
7 Cookies and similar technology
ETenant may use essential cookies or local storage for login sessions, security, preferences, navigation and service continuity. Optional analytics or preference technologies should be used only where permitted and, where required, after obtaining consent.
You can manage cookies through browser settings, although disabling essential cookies may prevent account access or normal platform operation.
8 Data security
ETenant uses administrative, technical and organizational safeguards designed to protect personal data, including access controls, password hashing, session management, encryption where appropriate, audit logs, backups, monitoring and least-privilege permissions.
No system is completely secure. Users must protect credentials, devices and authentication codes and must promptly report suspected compromise.
9 Retention and deletion
Personal data is retained only for as long as reasonably necessary for the purposes described in this policy, contractual obligations, dispute handling, audit, fraud prevention, accounting, tax, legal compliance and legitimate business needs.
Deletion requests may not result in immediate removal where retention is required by law, necessary for legal claims, needed to protect other users or preserved in secure backups until normal deletion cycles complete.
10 Your data-protection rights
Subject to applicable law and relevant exceptions, you may request:
- Information about how your personal data is processed.
- Access to personal data held about you.
- Correction of inaccurate or incomplete data.
- Deletion of data where there is no lawful reason to retain it.
- Restriction or objection to certain processing.
- Withdrawal of consent without affecting earlier lawful processing.
- Data portability where applicable.
- Review of certain automated decisions where applicable.
- Complaint handling and remediation.
ETenant may verify your identity before processing a request and may coordinate with the relevant organization where that organization controls the data.
11 International transfers
Where personal data is transferred outside Nigeria, ETenant will use lawful transfer mechanisms and appropriate safeguards, considering the destination, recipient, contractual protections, security measures and applicable data-protection requirements.
12 Children and dependent occupants
ETenant is not intended for independent use by children who cannot lawfully consent or contract. Information about minor occupants should be provided only by an authorized parent, guardian, landlord or organization and only where necessary for legitimate tenancy administration.
13 Personal-data incidents
ETenant will investigate suspected personal-data breaches and take proportionate containment, remediation, documentation and notification steps in accordance with applicable law and risk.
14 Changes to this policy
This policy may be updated to reflect changes in law, technology, security or platform services. Material changes may be communicated through the platform, email or another reasonable method.