🔒 The short version
This is a summary, not a substitute for the full policy below. But if you read only this much, these are the points that actually affect you.
- When you enquire about a property, we pass your details to the agent, landlord or owner. From that moment they decide what to do with your data, not us. See clause 7.2.
- Anything you put in a listing is published. Addresses, photographs and contact details in a listing are visible to everyone, including search engines. See clause 3.3.
- If you register as an agent, your name, area and partial contact details appear in our public directory. See clause 3.4.
- We never ask you to send purchase money to us. We do not hold client funds. Anyone asking you to is committing fraud. See clause 3.6.
- Your data may be sent to Ghana, because the company operating this platform is incorporated there. We explain the legal basis at clause 8.
- You can ask for a copy of your data, correct it, delete it, or object — free, and normally within 30 days. See clause 11.
- You can complain to the Nigeria Data Protection Commission at any time, whether or not you complain to us first. See clause 17.
This policy is written to meet the Nigeria Data Protection Act 2023 and the NDPC's General Application and Implementation Directive 2025. Where the law gives you a right, nothing here removes it.
1. Who we are
1.1 Apartments.ng is operated by Apartments Global Limited, registration number CS172462019, registered office 2nd Floor, 10 Abafun Crescent, Labone, Accra. For the purposes of the Nigeria Data Protection Act 2023 ("the Act"), we are the data controller for the personal data described here.
1.2 The regulator is the Nigeria Data Protection Commission (NDPC).
2. When this policy applies
2.1 This policy covers personal data we process through apartments.ng, through our services, and when you contact us.
2.2 The Act applies to us whether or not we are incorporated in Nigeria. It reaches any organisation processing the personal data of people located in Nigeria, and of Nigerian citizens and residents wherever they are. We do not rely on our place of incorporation to avoid it.
2.3 Our Ghanaian platform at apartments.com.gh has its own privacy notice under Ghana's Data Protection Act 2012 (Act 843). This policy covers apartments.ng only.
3. The data we collect
3.1 If you create an account
Your name, email address, telephone number, password (stored encrypted, never in readable form), the role you select — such as tenant, landlord, agent or developer — and, where relevant, your company name.
3.2 If you enquire about a property or a service
Your contact details, the property or service concerned, your budget and requirements, your location, and anything you choose to tell us in a message or form — including, on some forms, your reason for selling or your financing position.
3.3 If you list a property
Listings are public
The address, description, price, photographs and contact details you put in a listing are published on the open internet and can be indexed by search engines, copied and cached. Do not include anything in a listing you would not want publicly visible — including documents, identity numbers, or photographs showing occupants or their possessions.
3.4 If you register as an agent or service provider
In addition to account data: your business or trading name, business address, service areas, and a profile photograph if you upload one. These appear in our public agent directory, with your telephone number shown in partially masked form. Where you apply for verification we also process identity documents, CAC registration details, professional registration numbers and references.
3.5 If you engage a paid service
Identity and address verification data, property and title documents, correspondence, and records of the work carried out. Where the Money Laundering (Prevention and Prohibition) Act 2022 applies, we also process source-of-funds information.
3.6 Payments
We do not hold client money and we do not store card details
Fees are handled by regulated payment providers who process card and bank details directly. We never ask you to send purchase money, deposits or rent to us. If anyone claiming to represent us asks you to transfer property funds — to us or to a personal account — that is fraud. Report it to us immediately.
3.7 Automatically, when you use the site
IP address, device and browser type, pages visited, referring page, and approximate location derived from your IP. See clause 13.
3.8 Reviews and messages
Reviews you write are published publicly with your display name and the date. Messages you send through the platform are stored and may be reviewed where we investigate a complaint or suspected fraud.
4. How we collect it
4.1 Directly from you — when you register, enquire, list, review, engage a service, or contact us.
4.2 Automatically — through cookies and server logs when you use the site.
4.3 From others — from an agent or landlord who passes on your enquiry, from public registers when we carry out verification or title work you have asked for, from payment providers confirming a transaction, and from referees you nominate when applying for verification.
5. Why we use it, and our lawful basis
5.1 Section 25 of the Act sets out six lawful bases for processing. We rely on the following, purpose by purpose.
| What we do | Why | Lawful basis |
|---|---|---|
| Run your account | Create, secure and maintain your account and let you sign in | Contract |
| Publish your listing | Display the property you asked us to advertise | Contract |
| Pass on your enquiry | Connect you with the agent, landlord or owner you contacted | Contract |
| Deliver a paid service | Carry out verification, inspection, legal, management or sale work you engaged | Contract |
| Verify agents | Check identity, CAC and professional registration before awarding a badge | Legitimate interests |
| Prevent fraud | Detect fake listings, impersonation and payment fraud, and protect users | Legitimate interests |
| Improve the platform | Understand how the site is used and fix what does not work | Legitimate interests |
| Respond to you | Answer questions, handle complaints, keep records of what was said | Legitimate interests |
| Send marketing | Newsletters and property alerts you asked for | Consent |
| Non-essential cookies | Analytics and measurement | Consent |
| Anti-money-laundering | Identity and source-of-funds checks on qualifying transactions | Legal obligation |
| Keep financial records | Tax, accounting and audit requirements | Legal obligation |
| Respond to authorities | Comply with a court order, a regulator or a lawful police request | Legal obligation |
| Defend claims | Establish, exercise or defend a legal claim | Legitimate interests |
5.2 Where we rely on legitimate interests, we have considered whether our interest is outweighed by your rights. You may object at any time — see clause 11.
5.3 Where we rely on consent, you may withdraw it at any time. Withdrawing does not affect processing already carried out, and we will not stop providing a service you have paid for because you unsubscribed from marketing.
6. Sensitive personal data
6.1 We do not seek sensitive personal data — such as data revealing health, religion, ethnicity, political opinions or biometric data — and you should not send it to us.
6.2 It can nonetheless reach us: a probate or inheritance matter may involve a death certificate or medical evidence; an accessibility requirement may reveal a health condition; a Sharia inheritance question reveals religion. Where that happens we process it only so far as necessary for the matter, restrict access to those who need it, and delete it when the matter closes.
7. Who we share it with
7.1 We do not sell your personal data. We share it in the following circumstances only.
7.2 Agents, landlords and owners — the most important one
When you enquire about a property, we pass your name, contact details and message to the person advertising it. That is the point of the enquiry, and it is unavoidable.
From that moment they are an independent data controller. They decide how they use your details and for how long, and we do not control that and cannot delete data from their systems. If they misuse your details, tell us — we will act on credible reports, including removing agents — but your rights against them are exercised against them, and you may complain to the NDPC about their conduct.
7.3 Service providers acting on our instructions — hosting, email delivery, payment processing, customer support and analytics. They act as data processors under written terms, may only process data as instructed, and must apply appropriate security.
7.4 Professionals delivering a service you engaged — lawyers, valuers, surveyors, inspectors and contractors. Where you engage them directly on our introduction, they are independent controllers.
7.5 Within our group — including our Ghanaian operation, for administration and support. See clause 8.
7.6 Where the law requires it — courts, regulators, the police, and under anti-money-laundering obligations.
7.7 On a business sale — a buyer of the business would receive user data, subject to the same protections.
7.8 Advertisers — we do not give advertisers your personal data. Advertising on the platform is labelled, and it is not personalised using your account information.
8. Sending data outside Nigeria
8.1 Your data may be processed outside Nigeria. This matters more here than on most platforms, so we set it out plainly: the company operating apartments.ng is incorporated in Ghana, and our administration, support and some technical operations sit there.
8.2 The Act permits transfer where the destination provides an adequate level of protection, which can be established through a law in the receiving country meeting the Act's standards, binding corporate rules, contractual clauses, an approved code of conduct, a certification mechanism, or your explicit consent. We are required to document which basis applies, and we do.
8.3 For transfers to Ghana we rely on Ghana's Data Protection Act 2012 (Act 843), which establishes a data protection regime and an independent Data Protection Commission, supported by written intra-group terms imposing standards equivalent to the Act.
8.4 Where a hosting or software provider processes data elsewhere, we rely on contractual clauses imposing equivalent protection. You may ask us which countries are involved and on what basis — see clause 19.
9. How long we keep it
9.1 We keep personal data only as long as we need it. In practice:
| Data | Kept for | Why |
|---|---|---|
| Account data | While active, then 24 months | To let you reopen an account and to investigate disputes |
| Property listings | While live, then 12 months | Dispute resolution and market records |
| Enquiries | 24 months | To handle follow-up and complaints |
| Service engagement records | 7 years after completion | Professional records, limitation periods and tax |
| Verification and legal reports | 7 years | You may need them years later; a title report has long-term value |
| Anti-money-laundering records | 5 years after the relationship ends | Money Laundering (Prevention and Prohibition) Act 2022 |
| Financial and tax records | 7 years | Accounting and tax obligations |
| Marketing consent | Until withdrawn, then 12 months | To evidence that consent existed and was withdrawn |
| Analytics data | 26 months | Trend analysis |
| Breach records | 5 years | Regulatory accountability |
9.2 Where we must keep data for a legal reason we retain it even if you ask us to delete it, and we tell you why. Published listings and reviews may persist in search engine caches and archives after removal, which is outside our control.
10. How we protect it
10.1 Section 39 of the Act requires appropriate technical and organisational measures. Ours include encryption in transit, hashed password storage, access restricted to staff who need it, logging of access to service files, written terms with processors, and staff training on data protection.
10.2 No system is completely secure. Protect your own account: use a unique password, do not share your login, and tell us at once if you suspect unauthorised access.
11. Your rights
11.1 Under the Act you have the following rights.
11.2 How to exercise them. Email us at the address in clause 19 saying what you want. There is no charge. We will respond within 30 days, and will tell you if a complex request needs longer.
11.3 We may ask you to confirm your identity before releasing data, to prevent disclosure to the wrong person.
11.4 Where we cannot do what you ask — usually because a legal obligation requires us to keep something — we will explain which obligation and for how long.
12. Automated decisions
12.1 We do not make decisions with legal or similarly significant effects about you by solely automated means.
12.2 Calculators and eligibility checkers on the site — for mortgages, yields, tax or exit readiness — produce indicative illustrations based on figures you enter. They do not decide anything, they are not stored against your account unless you ask us to save them, and no lending, pricing or service decision is made by them.
12.3 Fraud prevention may flag activity automatically, but a person reviews before any account is suspended.
13. Cookies and tracking
13.1 Essential cookies keep you signed in, remember your search and currency preference, and protect against cross-site request forgery. These are necessary for the site to work and do not require consent.
13.2 Analytics cookies help us understand how the site is used. These are set only with your consent, and you can withdraw it at any time through your browser or our cookie settings.
13.3 Blocking essential cookies will stop parts of the site working, including sign-in.
14. Third-party content on our pages
14.1 Some pages display advertising and content served from other companies' domains. When your browser loads such an item, it contacts that company's server directly, which means your IP address, browser type and the page you are viewing are visible to them, whether or not you click.
14.2 We label advertising, and we do not pass advertisers your account data. But we cannot control what a third party does with a request your browser makes to it, and their privacy notices govern that.
14.3 The WhatsApp buttons on our pages open WhatsApp with a pre-filled message. Using them shares your phone number and message with Meta under its own terms. If you would rather not, email us instead.
15. Children
15.1 The platform is for adults. You must be at least 18 to create an account, and we do not knowingly collect data from children.
15.2 If you believe a child has given us personal data, tell us and we will delete it.
15.3 Do not include photographs identifying children in listings.
16. If something goes wrong
Our breach obligations, stated plainly
If a breach occurs that is likely to risk your rights and freedoms, we must notify the NDPC within 72 hours of becoming aware of it, under section 40 of the Act.
Where a breach is likely to place you at high risk, we must also tell you — promptly, in plain language, explaining what happened, the likely consequences, what we are doing, and what you should do. Where contacting everyone individually is not practical, we may publish a public notice instead.
16.1 We keep a record of breaches, including those we are not required to report.
17. Complaints
17.1 Tell us first if you can — we would rather fix it. Write to the address in clause 19. We aim to acknowledge within 5 working days and respond within 30 days.
17.2 You may complain to the Nigeria Data Protection Commission at any time, and you do not have to come to us first.
Nigeria Data Protection Commission (NDPC)
Website: ndpc.gov.ng
Portal: services.ndpc.gov.ng
17.3 You may also pursue a remedy through the Nigerian courts. Nothing in this policy or our Terms of Service limits that.
18. Changes to this policy
18.1 The version in force is the one published here, with its effective date. We keep previous versions and will provide one on request.
18.2 Where a change materially affects how we use your data, we will tell you by email or on-site notice before it takes effect, and where the change requires consent we will ask for it rather than assume it.
19. Contact us
Apartments Global Limited
Registration number CS172462019 · TIN C0029163927
Registered office: 2nd Floor, 10 Abafun Crescent, Labone, Accra
Data protection enquiries and rights requests
Email: privacy@apartments.ng
General: hello@apartments.ng
Data Protection Officer
[Name and contact details to be inserted once appointed — see clause 1.2]
Nigeria contact address and telephone
[To be inserted]