Introduction
HomeLands is operated by HomeLands Sourcing Nigeria Limited, a company registered in the Federal Republic of Nigeria with its registered office at 3B Obudu Street, Off Udi Hills, Aso Drive, Abuja, FCT, Nigeria. We are the data controller for the personal data described in this policy.
HomeLands ("we", "our", "us") respects your privacy. This policy explains what information we collect when you use the HomeLands mobile application and website, how we use it, the lawful basis on which we use it, who we share it with, how long we keep it, and the rights you have.
For any privacy question or request, including to exercise the rights set out below, contact our data protection contact at [email protected].
Information we collect
Information you provide
- Account details: your name, email address, phone number, and role (client, owner, or legal reviewer).
- Profile information such as a display name or photo, if you add one.
- Identity verification data: to list a property you must verify your identity. Verification is performed by a licensed Nigerian identity verification provider, which collects your government identification and, depending on the check, a live photograph of you. We receive and store the verification reference and its outcome. Where you complete verification by submitting your National Identification Number and full name to us directly, we store those in order to complete and evidence the check.
- Listing content if you are an owner: property photos, descriptions, price, and the address and map location you select.
- Ownership documents you upload, for example a Certificate of Occupancy, right of occupancy, deed of assignment, survey plan, letter of allocation, development control approval, or company registration (CAC) documents.
- Agreements: the Listing Representation Agreement you sign in the app, including the signature you draw, and the date, network address, and device information recorded at the moment of signing as evidence that you signed it.
- Payout details if you are an owner: your bank, account number, and the account holder name confirmed by your bank.
- Service requests: if you ask us to send a media team to photograph a property, the contact phone number, location, coordinates, property description, and preferred time you give us.
- Communications: booking requests, messages, reviews, and any emails you send to support.
Information collected automatically
- Activity: which listings you view, which you save, and the bookings and viewings you create.
- Device and technical data: a push notification token, device model, operating system, app version, IP address, and an approximate region derived from it.
- On the website, essential local storage needed for the site to function. We do not use advertising or cross-site tracking cookies, and we do not run third-party analytics.
Payment information
Payments are processed by our payment provider, Paystack. Card and bank details are entered with Paystack and are not stored on our servers. We receive the transaction reference, amount, and status so we can confirm a payment and settle the owner.
How we use your information, and our lawful basis
Nigerian data protection law requires us to have a lawful basis for each purpose. Ours are as follows.
- To perform our contract with you: to run the marketplace, show relevant listings, connect clients and owners, enable viewing calls, process payments, settle owners, and provide support.
- To comply with a legal obligation: to verify identity, to verify that a listed property genuinely belongs to the person listing it, to keep transaction and verification records, to meet anti-money laundering and tax obligations, and to respond to lawful requests from authorities.
- For our legitimate interests: to detect, prevent, and investigate fraud and abuse, to keep the service secure, to resolve disputes between users, and to improve the product. We balance these against your interests and rights.
- With your consent: to send the notifications you opted into, and to access your camera, microphone, photos, or location where a feature needs them. You can withdraw consent at any time in Settings, Notifications, or in your device permissions, without affecting processing carried out before you withdrew it.
Automated checks
Identity verification involves automated checks, which may include validating your government identification and comparing a live photograph against it. If a check does not pass, you are told why and you can try again, and you can ask us to review the result by contacting support. We do not make decisions about you by automated means alone that produce legal effects without a route to human review.
Who we share data with
We share data only with the service providers we rely on to operate HomeLands, and only as needed for them to perform their function:
- Google Cloud Platform: storage of images, documents, and signed contracts, and hosting of our backend (primary region Europe West).
- MongoDB Atlas: our primary application database.
- Firebase: authentication and delivery of push notifications. If you choose to sign in with Google, Google processes that sign in.
- Our identity verification provider: government identification checks, liveness detection, and photograph matching, for users who verify to list a property.
- Google Maps Platform: address search, map selection, and Street View previews for listing locations.
- Agora: the technology that powers viewing calls. We do not record calls.
- Paystack: payment processing, bank account verification, and owner payouts.
- Email delivery through our workspace email provider.
- Our authorised legal reviewers, who see a listing and its ownership documents solely to verify it before it goes live.
- Law enforcement, regulators, or courts where we are legally required to do so, and professional advisers where we need advice on a matter affecting you.
We do not sell your personal data and we do not use it for third-party advertising.
International transfers
Some of the providers above store or process data on servers outside Nigeria, including in the European Union and the United Kingdom. Where data is transferred internationally we do so under the contractual safeguards in our agreements with those providers, which require them to protect the data to a standard consistent with Nigerian data protection law, and we transfer only what the provider needs to perform its function.
How long we keep data
We keep your personal data while your account is active. When you delete your account we remove your profile and content as described on our Account and Data Deletion page. Some records outlive the account because we are required to keep them:
- Identity verification records and payout account details: retained for the minimum period required by Nigerian anti-money laundering law, currently five years after the end of our relationship with you.
- Transaction records, invoices, and signed agreements: retained for the minimum period required by Nigerian tax and company record-keeping law, currently six years.
- Records relating to a dispute, complaint, or investigation: retained until the matter is resolved and any period for challenging the outcome has passed.
Once a retention period ends, the records are deleted or anonymised. Residual copies in encrypted backups are removed on a rolling cycle within 90 days.
How we protect data
Data is encrypted in transit using HTTPS. Documents and images are held in private storage and served only through short-lived signed links. Access to personal data is restricted to the people and services that need it. No method of transmission or storage is completely secure, but we work to protect your information and to address issues promptly.
If there is a data breach
If a breach of personal data occurs that is likely to result in a risk to your rights, we will report it to the Nigeria Data Protection Commission within the time required by law, currently 72 hours of becoming aware of it, and we will tell affected users without undue delay where the risk to them is high. We keep an internal record of breaches and what we did about them.
Your rights
- Access: request a copy of the personal data we hold about you.
- Correction: ask us to fix data that is inaccurate or incomplete.
- Deletion: ask us to delete your account and data. See the Account and Data Deletion page for how to do this in the app or by email.
- Portability: ask us for a copy of the data you gave us in a structured, commonly used, machine-readable format, or ask us to send it to another provider where that is technically feasible.
- Restriction: ask us to limit how we use your data while a question about its accuracy or our use of it is being resolved.
- Objection and withdrawal: object to processing we carry out for our legitimate interests, or withdraw a consent you gave, including opting out of notifications.
- Complaint: lodge a complaint with the Nigeria Data Protection Commission if you believe your rights have been breached.
To exercise any of these, email [email protected] from the address on your account. We respond within 30 days. We may ask you to confirm a detail before we act, so that we do not disclose your data to someone else. Some rights are limited where we are required by law to keep a record, and we will tell you when that applies.
Children
HomeLands is intended for adults. The service is not directed to anyone under 18 and you must be at least 18 to create an account. If we learn that we hold data about a child, we delete it.
Changes to this policy
We will update this policy from time to time. When we do, we will change the "last updated" date above and, for material changes, notify you in the app.
Contact us
For any privacy question or request, contact us at [email protected]. For anything else, contact [email protected].
HomeLands Sourcing Nigeria Limited
3B Obudu Street, Off Udi Hills, Aso Drive, Abuja, FCT, Nigeria