Privacy Policy / Privacy Notice

The Privacy Notice applies to public browsing and to registered users acting as individuals, agents, developers, businesses, direct sellers, landlords or purchasers. Registration data includes email address, telephone number, user category, identity/authority material, advertisements, views, offers, administrative decisions, escrow/payment information, transaction status, fees, refunds, complaints and communications.

360 Propertii Realty operates 360 Propertii Realty, a Nigerian real-estate technology platform. This Notice explains how we collect, use, disclose, retain and protect personal data when you visit the website or application, create an account, list or enquire about property, submit verification material, communicate with another user, or use a payment-related feature.

This Notice is intended to operate under the Nigeria Data Protection Act 2023 and other applicable Nigerian privacy, consumer-protection, cybersecurity and electronic-transactions requirements. A transaction counterparty or licensed payment provider may be an independent data controller for its own processing.

• Account and contact data: name, email, telephone number, address, login and communication preferences.
• Identity and verification data: government-issued identification, photograph, business registration, professional credentials and authority documents.
• Property and listing data: address, location, title documents, photographs, plans, price, ownership or agency information and listing history.
• Transaction data: payment reference, amount, payer/payee details, refunds, disputes and settlement status. Full card credentials should be collected by the licensed payment provider, not stored by the Portal unless expressly stated.
• Technical and usage data: IP address, device identifiers, browser, cookies, access logs, approximate location and interaction records.
• Communications and complaint data, including enquiries, calls or messages where lawfully recorded, reports, evidence and support history.
• Public-source and third-party data received from registries, professional bodies, verification vendors, payment providers and counterparties.

• Provide accounts, listings, enquiries, verification, transaction coordination and customer support.
• Authenticate users; assess authority to list; prevent impersonation, fraud, money laundering, abuse and security incidents.
• Process or facilitate payments through a licensed provider; reconcile, refund, investigate and preserve transaction records.
• Moderate content; investigate complaints; enforce contracts and protect users, the Portal and the public.
• Comply with legal duties, lawful requests, court orders, tax, accounting and regulatory obligations.
• Send service communications and, only where permitted, marketing or property alerts.
• Improve accessibility, performance, security and user experience through proportionate analytics.

Depending on the activity, processing is based on performance of a contract or steps requested before contract, compliance with legal obligations, consent, protection of vital interests, performance of a task in the public interest where applicable, or legitimate interests assessed against the rights of the data subject. Consent may be withdrawn without affecting earlier lawful processing.

• Advertisers, buyers, tenants and transaction counterparties where the user initiates or authorises contact.
• Licensed payment, escrow or stakeholder providers, banks, identity-verification services and fraud-prevention vendors.
• Hosting, cloud, analytics, communications, CRM, security and professional advisers bound by appropriate duties.
• Government authorities, regulators, courts and law-enforcement agencies where required or lawfully justified.
• A successor in a merger, financing, reorganisation or asset transfer, subject to lawful safeguards.

Where personal data is transferred outside Nigeria, the Company will use a transfer basis and safeguards recognised by applicable law, assess the destination and recipient, and provide further information on request where legally required.

Data is retained only for the period reasonably required for the stated purposes, contractual limitation periods, fraud prevention, dispute resolution, tax/accounting and legal obligations. Verification and transaction records may be retained longer than ordinary marketing data. Data will then be securely deleted, anonymised or archived under restricted access.

• request access to and a copy of personal data;
• request correction, deletion or restriction where the legal conditions apply;
• object to certain processing and withdraw consent;
• request portability where applicable;
• object to or seek review of qualifying automated decisions; and
• complain to the Company or the Nigeria Data Protection Commission.

The Company uses organisational and technical measures proportionate to risk, including role-based access, secure configuration, encryption where appropriate, logging, backup, vendor controls and incident response. No system is completely secure; users must protect credentials and report suspected compromise promptly.

The service is intended for adults legally capable of property transactions. Material changes will be notified through the Portal or other appropriate means. Privacy requests should be sent to the Contact Us facility. Identity verification may be required before a request is actioned.

Public visitors may receive strictly necessary and consent-managed cookies. Account, offer and escrow functions may require authentication, security, fraud-prevention and session technologies. Non-essential analytics and advertising technologies should follow the published consent architecture.

This Policy explains how 360 Propertii Realty uses cookies, software development kits, pixels, local storage and similar technologies. It should be read with the Privacy Policy.

• Strictly necessary: authentication, security, load balancing, consent records and essential transaction functionality.
• Preferences: language, location, display and saved-search settings.
• Analytics: aggregated or pseudonymous measurement of traffic, errors and feature use.
• Advertising: audience measurement, campaign attribution, frequency control and interest-based advertising, only where lawfully activated.
• Third-party content: maps, video, chat or social features that may set their own technologies.

Non-essential technologies should not be activated until the user makes a valid choice where consent is required. The banner must offer clear accept, reject and manage-options controls. Users may revisit the preference centre at any time; browser controls may also be used, although blocking necessary cookies may impair the service.

This Policy may be updated when technologies or providers change. The effective date must be shown and material consent changes must be presented again. Questions may be sent to the Contact Us facility.