LEGAL & PRIVACY

PRIVACY POLICY

Effective date: 14 September 2026

Enugu Properties respects your privacy and is committed to protecting personal information entrusted to us.

This Privacy Policy explains how MAGENCY ONLINE SOLUTIONS LTD., operating as Enugu Properties, collects, uses, stores, discloses, protects and otherwise processes personal data.

Website: https://enuguproperties.com

Company: MAGENCY ONLINE SOLUTIONS LTD. RC Number: 8229228 Company Type: Private Company Limited by Shares

Registered Address

House 10 34V Terraces Estate Road No. 2 Off Orchid Road Lekki 106104 Lagos Nigeria

Support: support@enuguproperties.com Diaspora: diaspora@enuguproperties.com WhatsApp: +234 903 366 0763

1. SCOPE

This Privacy Policy applies to personal data concerning:

visitors;
account holders;
Buyers;
Sellers;
Property Owners;
Agents;
developers;
company representatives;
inspectors;
Professional Providers;
diaspora customers;
support contacts;
people reporting suspicious Property activity.

2. APPLICABLE LAW

Our processing is principally governed by the Nigeria Data Protection Act 2023 and applicable regulations, directives and guidance of the Nigeria Data Protection Commission.

The Nigerian framework recognises rights including access, correction, objection, restriction, portability and erasure in qualifying circumstances, together with protections relating to automated decision-making.

3. OUR PRIVACY PRINCIPLES

We aim to process personal data:

lawfully;
fairly;
transparently;
for defined purposes;
proportionately;
accurately where necessary;
securely;
for no longer than reasonably necessary.

We do not intentionally collect highly sensitive information merely because it might become useful later.

4. SOFT-LAUNCH SERVICES

Enugu Properties may make Services available progressively.

If a Service is disabled, we do not intentionally collect information through that disabled functionality.

For example, if online payments or video uploads are disabled, the Platform should not invite users to submit related information through those unavailable Services.

5. ACCOUNT INFORMATION

When you register, we may process:

first name;
last name;
display name;
email;
telephone;
WhatsApp;
country;
Account type;
preferences;
authentication information.

Passwords should be processed in protected form and are not intended to be readable by ordinary staff.

6. SELLER INFORMATION

Sellers may provide:

identity;
contact details;
Seller type;
organisation;
relationship to Property;
authority information;
Listing history;
Property details;
asking price;
photographs;
documents;
inspection information.

7. PROPERTY DOCUMENTS

Depending on the Property, Sellers may submit documents such as:

Certificate of Occupancy;
Right of Occupancy;
Deed of Assignment;
Deed of Conveyance;
Allocation Letter;
Survey Plan;
Power of Attorney;
probate documents;
company records;
authority-to-market evidence.

These may contain information about people other than the user uploading them.

Private Property documents are not intended to become publicly accessible merely because they are uploaded.

8. IDENTITY INFORMATION

Where legitimately required, we may process information such as:

legal name;
address;
date of birth;
photograph;
government identification;
identification reference;
company information.

We aim to collect enhanced identity information only when justified by the relevant Service, transaction or legal requirement.

9. NATIONAL IDENTIFICATION INFORMATION

We do not require highly sensitive national identification information from ordinary website visitors.

Where such information becomes legitimately necessary for verification or legal compliance, we aim to:

collect only what is justified;
restrict access;
protect it;
avoid public disclosure;
apply appropriate retention controls.

Do not send national identification information through ordinary contact forms unless specifically requested through an approved secure process.

10. PROPERTY LOCATION

We may process:

State;
LGA;
town;
area;
estate;
address;
latitude;
longitude.

Exact coordinates may be stored privately while only an approximate area is shown publicly.

11. INSPECTION INFORMATION

Property inspections may generate:

date;
time;
Property reference;
inspector;
photographs;
video where enabled;
location confirmation;
GPS;
notes;
observations;
representative present.

Inspection evidence is generally restricted unless specific information is deliberately approved for public display.

12. BUYER INFORMATION

Buyer information may include:

name;
email;
telephone;
WhatsApp;
country;
enquiries;
saved Properties;
inspection requests;
offers;
transaction communications.

13. DIASPORA INFORMATION

Where you contact us from outside Nigeria, we may process:

country of residence;
contact details;
Property interests;
remote-inspection needs;
communication preferences.

Diaspora enquiries may be handled through:

[diaspora@enuguproperties.com](mailto:diaspora@enuguproperties.com)

We currently do not represent that we maintain a UK office unless UK contact details are later expressly published.

14. OFFERS AND TRANSACTIONS

Where these features are enabled, we may process:

offer amount;
parties;
Property;
conditions;
acceptance or rejection;
milestones;
due-diligence status;
transaction records;
commission information.

15. PAYMENT INFORMATION

Where payment functionality is enabled, we may process:

customer;
amount;
currency;
purpose;
payment reference;
payment status;
refund information.

Payment providers such as Paystack may process card or bank information directly.

Enugu Properties does not intend to store complete card numbers or card security codes in its normal application database.

16. PROPERTY PURCHASE MONEY

Our ordinary payment system is intended for Enugu Properties Services, not general Property purchase funds.

We do not currently operate a general Property escrow service.

17. SUPPORT AND COMMUNICATIONS

We may process communications made through:

contact forms;
email;
telephone;
WhatsApp;
support requests;
Property enquiries;
reports.

Relevant communications may be retained for support, fraud prevention, transaction administration and dispute resolution.

18. TECHNICAL INFORMATION

When you use the Platform, we may receive:

IP address;
browser;
device;
operating system;
session identifiers;
page requests;
timestamps;
security events;
error information;
approximate network location.

19. AUDIT LOGS

We may record important events including:

registration;
authentication;
Property changes;
moderation;
document access;
verification;
payment events;
inspection activity;
staff actions.

These logs help establish accountability and protect users.

20. HOW WE RECEIVE INFORMATION

Information may come:

directly from you;
from an Owner or Agent;
from organisations;
from Professional Providers;
from official sources;
from another user making a report;
automatically through use of the Platform.

21. PURPOSES OF PROCESSING

We process information for purposes such as:

creating Accounts;
authenticating users;
publishing Property;
moderation;
verification;
Property inspections;
buyer enquiries;
offers;
transaction support;
payments;
customer support;
fraud prevention;
security;
record keeping;
legal compliance;
Platform improvement.

22. LAWFUL BASES

Depending on the activity, we may rely on:

Contract

Where processing is needed to provide an agreed Service.

Steps Before Contract

Where you ask us to take steps before entering into an arrangement.

Legal Obligation

Where processing is required by applicable law.

Legitimate Interests

Including:

fraud prevention;
marketplace safety;
moderation;
cybersecurity;
record keeping;
protecting Buyers and Sellers.

Consent

Where consent is appropriate, such as certain optional marketing or non-essential technologies.

Consent is not used artificially where another legal basis properly applies.

23. FRAUD PREVENTION

We may use information to identify possible:

duplicate Properties;
conflicting Sellers;
repeated rejected Listings;
unusual Account activity;
payment abuse;
suspicious document patterns.

A risk indicator does not automatically mean fraud occurred.

Where significant action is contemplated, appropriate human review should be used.

24. AUTOMATED SYSTEMS

Automated processes may assist with:

bot detection;
rate limiting;
file validation;
duplicate detection;
queue prioritisation;
technical security.

We do not intend to determine legal ownership of Property solely through an automated algorithm.

25. RECIPIENTS OF INFORMATION

Personal data may be shared where reasonably necessary with:

Buyers;
Sellers;
authorised staff;
inspectors;
Professional Providers;
payment processors;
email providers;
infrastructure providers;
regulators;
law enforcement where lawfully required.

We aim to share only information reasonably necessary for the purpose.

26. TECHNOLOGY PROVIDERS

We currently use or may use providers including:

Cloudflare

For website infrastructure, security, bot protection and object storage.

Neon

For database and related application infrastructure.

Resend

For transactional email where enabled.

Paystack

For online payment processing where enabled.

Mapping providers

Where map functionality is enabled.

Provider usage may change as the Platform develops.

27. PUBLIC INFORMATION

Approved Listing information may become publicly visible, including:

Property title;
general location;
asking price;
description;
Property features;
photographs;
public video where enabled;
public verification status.

28. INFORMATION NOT PUBLIC BY DEFAULT

We do not ordinarily publish:

government IDs;
NIN;
private title documents;
private Seller address;
internal risk flags;
private verification evidence;
moderator notes;
payment information;
hidden GPS coordinates.

29. PRIVATE FILE STORAGE

Confidential evidence is intended to use restricted storage and authorised access.

Controls may include:

private object storage;
authentication;
role-based access;
temporary signed links;
access logging;
quarantine;
malware/security review.

30. FILE SECURITY

Uploaded files may be:

validated;
quarantined;
scanned where the relevant system is available;
manually reviewed;
rejected.

A file should not be represented as security-cleared unless the applicable review has actually occurred.

31. SECURITY MEASURES

Measures may include:

encryption in transit;
restricted access;
row-level database controls;
private storage;
temporary access links;
audit logs;
multi-factor authentication;
rate limiting;
bot protection;
CSRF controls;
backups;
monitoring.

No system can guarantee absolute security.

32. STAFF ACCESS

Staff access should be based on legitimate role and need.

Having an administrator account does not necessarily entitle a person to view every sensitive record.

33. INTERNATIONAL PROCESSING

Some infrastructure providers may process information outside Nigeria.

Where required, we seek to use appropriate lawful safeguards for international processing.

A diaspora customer should expect that information submitted outside Nigeria may be processed by our team in Nigeria and by infrastructure providers operating internationally.

34. DATA RETENTION

We retain personal data only for as long as reasonably necessary, taking account of:

Service provision;
transaction records;
fraud prevention;
disputes;
accounting;
legal requirements;
security.

Different categories may have different retention periods.

35. ACCOUNT CLOSURE

Closing an Account does not automatically require immediate deletion of every record.

Information may remain where legitimately needed for:

completed transactions;
financial records;
disputes;
fraud prevention;
legal obligations.

36. PROPERTY HISTORY

Expired, sold, withdrawn or rejected Listings may be retained internally where reasonably necessary for:

transaction history;
Seller history;
fraud prevention;
dispute records;
audit purposes.

37. PRIVATE DOCUMENT RETENTION

We aim not to retain sensitive Property or identity documents indefinitely without justification.

Retention decisions should take account of:

active Property status;
transaction status;
verification;
disputes;
applicable law.

38. BACKUPS

Information may remain temporarily in protected backups following deletion until normal backup-retention periods expire.

39. YOUR RIGHTS

Subject to applicable law, you may have rights to:

be informed;
access personal data;
correct inaccurate information;
request erasure;
request restriction;
object to certain processing;
obtain certain data in portable form;
withdraw consent where consent is the applicable basis;
seek appropriate review of significant automated decisions;
complain to the competent regulator.

40. PRIVACY REQUESTS

Send privacy requests to:

[support@enuguproperties.com](mailto:support@enuguproperties.com)

Use the subject:

Privacy Request

where possible.

We may verify your identity before fulfilling sensitive requests.

41. ERASURE IS NOT ABSOLUTE

We may retain information where legitimately necessary for:

legal obligations;
accounting;
fraud prevention;
legal claims;
transaction records;
security.

Where appropriate, information may instead be anonymised or restricted.

42. MARKETING

Optional marketing communications may be unsubscribed from.

Necessary transactional or security communications may still be sent, including:

password resets;
Listing moderation;
payment notifications;
inspection updates;
security alerts.

43. COOKIES

We may use cookies or similar technologies for:

login;
security;
preferences;
fraud prevention;
Platform operation;
analytics where enabled.

Non-essential technologies will be handled in accordance with applicable consent requirements.

44. TURNSTILE AND BOT PROTECTION

Where enabled, Cloudflare Turnstile or similar technology may process limited device/network information to protect forms and Accounts from automated abuse.

45. CHILDREN

The Platform is intended for adults.

Transactional users should normally be at least 18.

We do not knowingly design the Platform to collect children's data for Property transactions.

46. DATA BREACHES

We maintain procedures for investigating suspected personal-data breaches.

Where applicable law requires it, we will notify the Nigeria Data Protection Commission and/or affected individuals.

Nigeria's framework includes a 72-hour Commission notification obligation for breaches likely to create relevant risk to individuals.

47. THIRD-PARTY PROFESSIONALS

Independent solicitors, surveyors or other Professional Providers may act as separate data controllers for information they process in delivering their own professional services.

Their privacy terms may separately apply.

48. CHANGES TO THIS POLICY

We may update this Privacy Policy as:

Services change;
providers change;
laws change;
our operational model develops.

Material changes may be communicated through the Platform or by email.

49. COMPLAINTS

Privacy concerns should first be sent to: