Privacy Policy

1. Information We Collect

Depending on how you interact with EMS Platform, we collect the following categories of data:

• Resident & Household Profiles: Full names, primary phone numbers, email addresses, residential unit identifiers (e.g., Block 4, Flat 2), tenancy status (owner-occupier or tenant), and designated emergency contacts.
• Financial & Transaction Records: Unit reference codes (e.g. GE-A1), payment dates, bank transaction references and narrations, payment amounts, and levy categories. We do not store your personal debit card PAN numbers or online banking passwords.
• Visitor & Gate Access Logs: Visitor names, hosting resident unit number, date and timestamp of access code generation, gate check-in/check-out timestamps, and optional vehicle registration numbers recorded by gatehouse security guards.
• System Audit & Security Logs: IP addresses, login timestamps, device operating systems, and approval audit records for dual-signature financial disbursements.

2. Legal Basis for Processing

Under Section 25 of the Nigeria Data Protection Act 2023, we process personal data pursuant to the following lawful bases:

• Performance of a Contract: To manage resident onboarding, generate gate passes, record estate dues, and process approved estate payments.
• Legitimate Interests: To safeguard estate perimeter security, prevent payment fraud or counterfeit alerts, and provide AGM financial transparency.
• Legal & Statutory Obligations: To comply with financial reporting standards, tax requirements, and lawful directives from authorized law enforcement bodies.

3. How We Use Your Information

We use collected data solely for operating, securing, and improving community operations:

• Dispatching visitor access codes via WhatsApp and SMS gateways;
• Matching payments to households using the unit reference code quoted in the transfer, to issue digital receipts;
• Enabling dual-signature approval workflows between Estate Chairmen and Treasurers;
• Delivering essential community broadcast announcements, security advisories, and billing statements;
• Generating aggregated, anonymized AGM operational reports for estate general assemblies.

4. Data Sharing & Third-Party Processors

Acre Suites Limited maintains strict restrictions on data sharing. We only disclose personal information to vetted infrastructure providers essential for service delivery:

• Banking Partners & Payment Rails: Central Bank of Nigeria (CBN)-licensed commercial banks and payment switches, including our payment partner Bachs, which provides each estate's collection account and processes online payments, and Paystack, which processes payments when Bachs is unavailable.
• Telecommunication & Messaging Gateways: WhatsApp Cloud API and licensed Nigerian SMS providers strictly for transmitting one-time access codes and billing alerts.
• Authorized Estate Administrators: The elected EXCO or designated facility management company overseeing your specific estate has access to community rosters and payment records.

We will never sell, lease, or monetize your contact information or visitor data to advertisers, telemarketers, or unvetted third parties.

5. Data Security Measures

EMS Platform employs defense-in-depth security architecture:

• All web and mobile traffic is encrypted in transit using Transport Layer Security (TLS 1.3);
• Database tables containing resident and payment data are encrypted at rest using AES-256;
• Dual-signature controls are enforced at the database level for all treasury fund releases;
• Session tokens are signed with cryptographically secure JSON Web Tokens with strict expiration lifecycles.

6. Data Retention Period

Resident and household records are retained for the duration of the resident's occupancy in the registered estate. Financial transaction logs and audit records are retained for seven (7) years in accordance with Nigerian statutory accounting and tax regulations. Temporary visitor access logs are purged periodically in accordance with estate policy.

7. Your Rights under the NDPA 2023

As a data subject, you hold fundamental legal rights:

• Right of Access: Request copies of the personal data held about you in the estate portal;
• Right to Rectification: Request correction of inaccurate phone numbers, unit numbers, or resident names;
• Right to Erasure ("Right to be Forgotten"): Request deletion of your resident profile upon moving out of the estate (subject to statutory financial record retention);
• Right to Lodge a Complaint: Lodge a complaint with the Nigeria Data Protection Commission (NDPC) if you believe your data has been unlawfully handled.

8. Data Protection Officer (DPO) & Contact Information

If you have questions regarding this Privacy Policy, wish to exercise your data subject rights, or require data compliance documentation, please contact our Data Protection Officer: