Everything Online Apartments

1. Data Controller

EverythingApartments Ltd ("we," "our," or "us") is the data controller responsible for your personal data collected through this Platform.

EverythingApartments Ltd

Data Protection Contact: privacy@everythingonlineapartments.com

2. NDPR Compliance Statement

This Privacy Policy is prepared in compliance with the Nigeria Data Protection Regulation (NDPR) 2019 issued by the National Information Technology Development Agency (NITDA). We are committed to protecting your personal data and processing it lawfully, fairly, and transparently.

3. Categories of Personal Data Collected

3.1 Information You Provide Directly

Category	Data Types
Identity Data	Full name, date of birth, nationality, government-issued ID (for verification)
Contact Data	Email address, phone number, mailing address
Financial Data	Bank account details, payment card information (processed by third-party providers)
Business Data	Company name, CAC registration details, business address (for Property Managers)
Property Data	Property listings, photos, descriptions, pricing, availability

3.2 Automatically Collected Data

Device Data: IP address, browser type, operating system, device identifiers
Usage Data: Pages visited, features used, search queries, click patterns
Location Data: General location based on IP address (precise location only with consent)
Cookie Data: Session cookies, preference cookies, analytics cookies

4. Legal Basis for Processing

In accordance with NDPR, we process your personal data based on the following legal grounds:

Purpose	Legal Basis
Account registration and management	Contract performance
Processing reservations and payments	Contract performance
Identity verification and fraud prevention	Legitimate interest / Legal obligation
Customer support and communications	Contract performance / Legitimate interest
Marketing communications	Consent
Analytics and service improvement	Legitimate interest
Legal compliance and dispute resolution	Legal obligation

5. Third-Party Sharing

We share your personal data with the following categories of third parties:

5.1 Service Providers

Payment Processors: Paystack, Flutterwave (for transaction processing)
Email Service Providers: For transactional and marketing emails
Cloud Hosting: For secure data storage and Platform operation
Analytics Services: For understanding Platform usage

5.2 Other Users

Property Managers see Guest contact details for confirmed reservations
Guests see Property Manager contact details and property information

5.3 Legal and Regulatory

We may disclose data when required by Nigerian law, court order, or regulatory authority, including:

Nigeria Police Force
Economic and Financial Crimes Commission (EFCC)
Federal Inland Revenue Service (FIRS)
National Information Technology Development Agency (NITDA)

6. Cross-Border Data Transfers

Some of our service providers may be located outside Nigeria. In such cases, we ensure that:

Transfers comply with NDPR requirements
Adequate data protection safeguards are in place
Recipients are bound by appropriate contractual obligations
Data protection standards equivalent to NDPR are maintained

7. Data Retention

We retain your personal data for the following periods:

Data Category	Retention Period
Account data	Duration of account + 3 years after closure
Reservation and transaction records	7 years (as required for tax and financial records)
Communications	3 years
Analytics data	2 years (anonymized after)
Marketing consent records	Duration of consent + 2 years

8. Data Subject Rights

Under NDPR, you have the following rights regarding your personal data:

Right of Access: Request a copy of your personal data held by us
Right to Rectification: Request correction of inaccurate or incomplete data
Right to Erasure: Request deletion of your data (subject to legal retention requirements)
Right to Restriction: Request limitation of processing in certain circumstances
Right to Data Portability: Receive your data in a structured, machine-readable format
Right to Object: Object to processing based on legitimate interests or for marketing
Right to Withdraw Consent: Withdraw consent at any time (where processing is based on consent)

8.1 How to Exercise Your Rights

To exercise any of these rights, contact us at:

Email: privacy@everythingonlineapartments.com

We will respond to your request within 30 days.

8.2 Right to Complain

If you believe we have violated your data protection rights, you have the right to lodge a complaint with:

National Information Technology Development Agency (NITDA)

Website: nitda.gov.ng

9. Cookies Policy

We use cookies and similar tracking technologies to enhance your experience:

9.1 Types of Cookies

Essential Cookies: Required for Platform operation (authentication, security)
Preference Cookies: Remember your settings and preferences
Analytics Cookies: Help us understand how you use the Platform
Marketing Cookies: Used to deliver relevant advertisements (with consent)

9.2 Managing Cookies

You can control cookies through your browser settings. Note that disabling certain cookies may affect Platform functionality.

10. Data Security

We implement appropriate technical and organizational measures to protect your personal data, including:

Encryption of data in transit (TLS/SSL) and at rest
Secure access controls and authentication
Regular security assessments and updates
Employee training on data protection
Incident response procedures

11. Children's Privacy

Our Platform is not intended for individuals under 18 years of age. We do not knowingly collect personal data from children. If we become aware of data collection from a minor, we will delete it promptly.

12. Changes to This Policy

We may update this Privacy Policy periodically
Material changes will be notified via email and Platform notification
The "Last updated" date indicates the most recent revision
Continued use after changes constitutes acceptance

13. Contact Information

For questions, concerns, or requests regarding this Privacy Policy or your personal data:

EverythingApartments Ltd - Data Protection