Privacy Policy

1. Who is responsible for your data

SleekHomes Limited (RC-8924343), of Central Business District, FCT-Abuja 900108, Nigeria, is the data controller. In this policy “we”, “us” and “SleekHomes” mean that company. You can reach us about privacy at info@sleekhomesltd.com.

Legal reference. This policy is issued under the Nigeria Data Protection Act 2023 (NDPA) and, where still applicable, the Nigeria Data Protection Regulation 2019. Where we qualify as a data controller of major importance, we register with the Nigeria Data Protection Commission (NDPC) and designate a data protection officer as the NDPA requires.

2. What personal data we collect

Data you give us. When you make a booking, send an enquiry, apply to partner with us, apply for a job, or subscribe to updates, we collect your name, email address, phone number, the content of your message or request, booking details (property, dates, guest count, special requests), and, for partners, business and bank settlement details and verification documents.

Payment data. Card and bank details are entered on Paystack’s or NOWPayments’ secure checkout, not on our servers. We receive a payment reference, the amount, the status, and limited information such as the card type or the paying bank.

Data collected automatically. When you use the Site we collect your IP address, device and browser type, pages viewed, referring page, and similar analytics data, and we set cookies and similar technologies as described in our Cookie Policy.

Data from others. We may receive information from a Partner about a booking you made with them, from Paystack about a payment or a dispute, and from our bot-protection and fraud-screening providers.

We do not deliberately collect sensitive personal data through the Site. Please do not send us health, religious, or similar information in a free-text field.

3. Why we use your data and our lawful bases

Where we rely on legitimate interests, we have weighed them against your rights and interests. You can object to that processing (see your rights below).

4. Who we share your data with

We share personal data only as needed, with:

• Partners, so they can deliver a stay or service you booked with them;
• Paystack (card, bank, and USSD payments; refunds; partner payouts);
• NOWPayments (cryptocurrency payments), where you choose that method;
• Google Analytics (usage analytics), configured to deny advertising storage;
• Our email provider (Resend), to send confirmations and notifications;
• Our hosting and database providers (Vercel and Neon) and Cloudflare (bot protection), who process data on our instructions;
• Professional advisers, and regulators, courts, or law enforcement, where the law requires or permits it, or to establish or defend legal claims;
• a buyer or successor if the business is reorganised or sold, under confidentiality.

Each processor acts under a written agreement that limits use of the data to our purposes. We do not sell personal data or share it for third-party advertising.

5. International data transfers

Some of our providers (including Google, Resend, Vercel, and Cloudflare) store or process data outside Nigeria, mainly in the United States and the European Union. Where we transfer personal data abroad we rely on one of the bases the NDPA allows: an adequacy decision by the NDPC, contractual and technical safeguards with the recipient, or, where necessary, the performance of your contract. You can ask us which applies to a given transfer.

Legal reference. Cross-border transfers are made under sections 41 to 43 of the NDPA 2023, which permit a transfer where the destination provides an adequate level of protection or where an appropriate safeguard or a specified derogation applies.

6. How long we keep your data

We keep enquiry and support records for up to 24 months after our last contact. We keep booking, payment, and partner records for at least 6 years to meet accounting and tax rules, and longer where a dispute or legal claim is live. Analytics data is retained for up to 14 months. Marketing contact details are kept until you unsubscribe. When a retention period ends we delete or irreversibly anonymise the data.

7. How we protect your data, and breaches

We use encryption in transit, access controls, hosting on reputable infrastructure, and least-privilege access for staff. No system is perfectly secure, but we take reasonable and appropriate measures as the NDPA requires. If a breach occurs that is likely to put your rights at risk, we will notify the NDPC, and you where the risk is high, without undue delay.

Legal reference. Security and breach-notification obligations are set by the NDPA 2023. A reportable breach is notified to the NDPC within 72 hours where feasible, and to affected data subjects where it is likely to result in a high risk to their rights and freedoms.

8. Your rights

Under the NDPA 2023 you have the right to:

• be told how your data is used (this policy);
• ask for a copy of the personal data we hold about you;
• have inaccurate data corrected and incomplete data completed;
• ask us to delete your data, or restrict how we use it, where a legal ground applies;
• receive certain data in a portable format, or have it sent to another controller;
• object to processing based on legitimate interests, and to direct marketing at any time;
• withdraw consent where we rely on it, without affecting earlier processing;
• not be subject to a decision with legal or similarly significant effect based solely on automated processing. We do not make such decisions about you.

To exercise a right, email info@sleekhomesltd.com. We may need to verify your identity, and we will respond within the time the NDPA allows, normally one month. Using your rights is free unless a request is manifestly unfounded or excessive.

Legal reference. These rights are given by Part VI of the NDPA 2023 (sections 34 to 38). Section 46 gives you the right to lodge a complaint with the Nigeria Data Protection Commission.

9. Children

The Site is intended for adults. We do not knowingly collect data from anyone under 18. If you believe a child has given us personal data, contact us and we will delete it.

10. Complaints

If you are unhappy with how we have handled your data, tell us first at info@sleekhomesltd.com so we can put it right. You also have the right to complain to the Nigeria Data Protection Commission (NDPC), whose contact details are published at ndpc.gov.ng.

11. Changes to this policy

We may update this policy as our service or the law changes. The “last updated” date above shows the current version, and we will flag material changes on the Site.

12. Contact

Data controller: SleekHomes Limited (RC-8924343), Central Business District, FCT-Abuja 900108, Nigeria. Privacy contact: info@sleekhomesltd.com.