1. Who this notice concerns
This draft explains the intended handling of personal information in GidaVault. The service is software, not a property manager, letting agent or rent-collection service. Launch is planned first in Nigeria; other markets require a separate applicability review.
The legal name, registered address and privacy contact of the company operating GidaVault have not yet been supplied and must be published before this notice becomes effective.
2. Who decides how information is used
GidaVault generally acts as a controller for its own account administration, service security and business operations. For tenant information entered or requested by a landlord for tenancy administration, the landlord will generally be the controller and GidaVault the processor acting on documented instructions. The actual role depends on the activity, not merely the contract label.
A landlord must have a lawful reason to collect tenant information and must explain that use to the tenant. Creating an account or accepting an invitation is not blanket consent to unrelated processing.
3. Information used by the software
Account profiles also include a required date of birth and a separate, optional birthday-email preference. The date of birth is used for birthday greetings when enabled, is not shown in tenancy applications, and is restricted to the account holder and authorised service administrators. The necessity of making it compulsory solely for greetings requires review before launch.
Depending on the features used, records may include account names and email addresses; property locations and ownership or occupancy descriptions; tenant invitations, names, contact details, household size, requested move-in dates and application notes; property documents, check-in evidence and dated activity records; and amounts, references or due dates entered for recordkeeping.
Document uploads and free-text notes can contain personal information. Do not upload identity documents, financial statements, health information or children’s details merely because there is an upload field. Extra or sensitive information needs a specific necessary purpose, appropriate lawful basis and safeguards. The service does not receive or hold rent.
4. Purposes and lawful grounds
Intended purposes are providing requested software, administering invitations and applications, maintaining property records, supporting account security and meeting applicable legal obligations. Before launch, each purpose must be mapped to an appropriate lawful basis, such as contract, a legal obligation or assessed legitimate interests; consent is used only where appropriate and must be specific and withdrawable.
Landlord-directed tenant processing must be covered by documented instructions and a data processing agreement. Information must not be repurposed for advertising, tenant blacklists or unrelated profiling.
Birthday greetings are optional relationship emails, not a condition of using property tools. The preference starts off, can be withdrawn in Birthday emails, and the greeting includes an unsubscribe link. Scheduling uses Nigeria time and does not include the recipient’s age. Date of birth remains personal data and must be included in the final account-retention and deletion schedule.
5. Access, providers and overseas processing
Access must be limited to the relevant account or workspace and authorised personnel with a necessary purpose. The intended recipients include the relevant landlord and service providers needed to host and operate the software. The actual provider list, support access and processing locations must be verified before launch.
Where information is processed outside Nigeria, the applicable cross-border transfer requirements and contractual safeguards must be assessed. This draft does not claim that information stays in Nigeria or that overseas transfers have already been approved.
6. Retention when a tenant leaves
Moving out does not automatically require deletion of every record, and it does not justify keeping everything forever. The proposed approach is to remove ongoing access no longer needed, identify the continuing purpose for each record and erase or irreversibly anonymise personal data once that purpose and any lawful retention period end.
A limited former-tenancy record may be retained for a justified legal, accounting or dispute purpose. Retaining a former tenant’s name or contact details is still personal-data processing. A genuinely anonymous occupancy history is different. No universal retention period is adopted in this draft.
A final schedule must distinguish unsuccessful applications, expired invitations, active tenancy records, ended tenancies, uploaded evidence, activity records, backups and legal holds. Automated end-of-tenancy deletion, anonymisation and backup expiry are not established by this notice.
7. Rights, requests and complaints
Subject to applicable law and exceptions, individuals may request information, access, correction, erasure, restriction or portability, and may object or withdraw consent where it is the applicable basis. Erasure is not absolute where a lawful obligation or a necessary legal claim requires limited retention.
Tenants should generally address tenancy-record requests to their landlord as controller; the software provider must assist as required by law and contract. Requests concerning the provider’s own account processing go to the provider. A working privacy contact, identity-verification process and escalation procedure must be established before real-data onboarding.
Individuals in Nigeria may complain to the Nigeria Data Protection Commission. No NDPC registration or approval is claimed by this draft.
8. Security and browser storage
Required operational safeguards include appropriate access controls, confidentiality, secure handling of documents, incident response and controls on exports and support access. These must be reviewed in practice; a privacy notice alone cannot provide security.
The software saves some form drafts in browser storage. On shared devices, avoid leaving sensitive draft information behind. Any visitor analytics, session recording or non-essential tracking and its consent requirements must be inventoried and described accurately before launch.