Introduction

Sylogate Ltd. ("Sylogate," "we," "us," or "our") is committed to protecting the privacy and personal information of our users. Our services are primarily designed for Estate Associations who rely on our platform to secure their properties, residential estates, and facilities ("Estates"). However, to provide our services to Estate Associations, we require the Personal Data of individuals (including residents, visitors, workers) who need to access the Protected Communities. We have therefore provided this Privacy Notice for the benefit of individuals who interact with our platforms. This Privacy Policy describes how we collect, use, disclose, and safeguard your information when you use our platforms, including the Sylogate Estate Portal, Sylogate Residents Portal, Sylogate Staff Portal, and Sylogate Admin Portal (collectively, "theServices"). By accessing or using the Services, you consent to the practices described in this Privacy Policy.

1. Definitions

• " Personal Data" means any information relating to an identified or identifiable natural person.
• "Processing" means any operation or set of operations performed on Personal Data.
• "User," "you," or "your" refers to any person accessing or using our Services.
• "NDPA" refers to the Nigeria Data Protection Act 2023
• "NDPR" refers to the Nigeria Data Protection Regulation, 2019.

2. Information We Collect

We may collect and process the following types of information:

2.1 Personal Data

• Account Information: When you create an account, we collect Personal Data such as your name, email address, phone number, residential address, and estate details.
• Identification Data: We may collect identification documents or details for verification purposes.
• Access Credentials: We may collect information related to your use of access passes, such as QR codes and NFC tags.

2.2 Usage Data

• Log Information: We automatically collect information when you access the Services, including IP addresses, browser types, operating systems, device information, access times, and pages viewed.
• Interaction Data: : Information about your interactions with the Services, such as features used and links clicked.

2.3 Cookies and Similar Technologies

• We use cookies, web beacons, and similar tracking technologies to collect information about your use of the Services and to provide features to you.

3. Legal Basis for Processing

We process your Personal Data based on the following legal grounds:

• Consent: Where you have given explicit consent for specific purposes.
• Contract Performance: To perform our contractual obligations to you.
• Legal Obligations: To comply with legal and regulatory requirements.
• Legitimate Interests: For our legitimate interests, such as improving our Services, provided that such processing does not override your rights and freedoms.

4. How We Use Your Information

We may use the information we collect for various purposes, including:

• Providing Services: To facilitate access control, manage visitor permissions, and provide the functionalities of the Services.
• Communication: To communicate with you about your account, transactions, security updates, and service-related announcements.
• Improvement and Development: To analyze usage and improve the Services, develop new features, and enhance user experience.
• Security and Fraud Prevention: To monitor and protect the security of our Services, detect and prevent fraudulent activities, and enforce our Terms of Service.
• Legal Compliance: To comply with applicable laws, regulations, and legal processes.

5. Sharing and Disclosure of Information

We may share your information in the following circumstances:

5.1 Service Providers

We engage third-party service providers to perform functions on our behalf, such as:

• Hosting and cloud services
• Analytics services
• Customer support

These service providers have access to Personal Data as needed to perform their functions and are obligated to maintain confidentiality.

5.2 Estate Administrators

Information regarding resident or visitor access may be shared with estate administrators to facilitate estate management and security.

5.3 Legal Obligations

We may disclose your information if required to do so by law or in response to valid requests by public authorities, including:

• To comply with legal obligations
• To protect and defend our rights or property
• To prevent or investigate possible wrongdoing
• To protect the personal safety of users or the public

5.4 Payment - Processing Services

We may share your data with the payment processing service provider to enable processing of any payment for the Service.

5.5 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of assets, your Personal Data may be transferred as part of the transaction.

6. International Data Transfers

Your information may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different from those of your country.

We ensure that appropriate safeguards are in place to protect your Personal Data when transferred internationally, in compliance with the Nigeria Data Protection Act, the Nigeria Data Protection Regulation (NDPR), and other applicable laws.

7. Security of Your Information

We implement reasonable administrative, technical, and physical security measures to protect your Personal Data against unauthorized access, loss, misuse, or alteration. These measures include:

• Encryption of sensitive data
• Access controls to Personal Data
• Regular security assessments

However, no method of transmission over the internet or electronic storage is completely secure. We cannot guarantee absolute security.

8. Data Retention

We retain your Personal Data only for as long as necessary to fulfill the purposes for which it was collected, including:

• As required by law or regulation
• For as long as you maintain an account with us
• To resolve disputes and enforce agreements

Upon the expiration of the retention period, we will securely delete or anonymize your Personal Data.

9. Your Rights and Choices

Under the Nigeria Data Protection Regulation (NDPR), you have the following rights regarding your Personal Data:

9.1 Access and Correction

• Right to Access: You may request confirmation whether we are processing your Personal Data and access to such data.
• Right to Correction: You may request the correction of inaccurate or incomplete Personal Data.

9.2 Erasure

• Right to Deletion: You may request the deletion of your Personal Data under certain circumstances, such as when it is no longer necessary for the purposes collected.

9.3 Objection and Restriction

• Right to Object: You may object to the processing of your Personal Data based on legitimate interests.
• Right to Restrict Processing: You may request that we restrict the processing of your Personal Data under certain conditions.

9.4 Data Portability

• Right to Data Portability: You have the right to receive your Personal Data in a structured, commonly used, and machine-readable format and to transmit it to another data controller.

9.5 Withdrawal of Consent

• Right to Withdraw Consent: If processing is based on consent, you may withdraw your consent at any time. Withdrawal does not affect the lawfulness of processing before withdrawal.

9.6 How to Exercise Your Rights

• You can exercise your rights by accessing your account settings or by contacting us at support@sylogate.com.

10. Cookies and Tracking Technologies

10.1 Use of Cookies

We may use cookies and similar technologies to:

• Authenticate Users: To verify your account and maintain your session.
• Personalize Content: To remember your preferences and settings.
• Analytics: To understand how you use our Services and improve them.
• Security: To protect against fraudulent activities.

10.2 Types of Cookies

• Essential Cookies: Necessary for the operation of the Services.
• Analytical/Performance Cookies: Allow us to recognize and count the number of visitors.
• Functionality Cookies: Used to recognize you when you return to our Services.

10.3 Managing Cookies

You can manage cookies through your browser settings. However, disabling cookies may affect the functionality of the Services.

11. Children's Privacy

Our Services are not intended for individuals under the age of 18 ("Children"). We do not knowingly collect Personal Data from Children. If you become aware that a Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from Children without verification of parental consent, we will take steps to remove that information.

12. Third-Party Links and Services

Our Services may contain links to third-party websites or services not operated by us. We are not responsible for the privacy practices of such third parties. We encourage you to review the privacy policies of any third-party sites or services before providing them with your Personal Data.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal obligations. We will notify you of any material changes by:

• Posting the updated policy on our Services with a new effective date.
• Providing notice through email or in-app notifications.

Your continued use of the Services after the effective date constitutes your acceptance of the updated Privacy Policy.

14. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:

• Email: support@sylogate.com
• Phone: +234 903 294 2619

15. Complaints

If you believe that we have violated your privacy rights, you have the right to lodge a complaint with the relevant supervisory authority, such as the Nigeria Data Protection Commission (NDPC).

Disclaimer: This Privacy Policy is provided for informational purposes only and does not constitute legal advice. We recommend consulting with a qualified attorney to ensure that your Privacy Policy complies with all applicable laws and regulations.