Privacy Policy

This Privacy Policy describes how GMS Estate Technologies Ltd. ("GMS Estate Technologies Ltd.," "we," "us," or "our") collects, uses, discloses, and protects personal information when you use the GMS Estate smart estate management platform, websites, mobile applications, APIs, and related services (collectively, the "Services").

We are committed to protecting your privacy and processing personal data in accordance with applicable laws, including the Nigeria Data Protection Act, 2023 (NDPA), the Nigeria Data Protection Regulation (NDPR) where applicable, and internationally recognized principles aligned with the EU General Data Protection Regulation (GDPR) where relevant to our users.

By accessing or using the Services, you acknowledge that you have read this Privacy Policy. If you do not agree, please do not use the Services.

1. Data controller

The data controller responsible for your personal information is:

• GMS Estate Technologies Ltd.
• Address: Plot 43, 441 Crescent, Citec Villas, Gwarinpa, Abuja, Nigeria
• Privacy contact: info@gms.estate

2. Information we collect

2.1 Information you provide

• Account data: name, email address, phone number, password (stored hashed), role, estate affiliation, and profile details.
• Estate & property data: addresses, unit identifiers, landlord and tenant records, lease information, and property metadata you or your organization uploads.
• Visitor access data: visitor names, phone numbers, vehicle plates, purpose of visit, expected arrival times, and access codes you generate for guests.
• Communications: messages sent through support channels, chatbot interactions (e.g., Vanae), and feedback you submit.
• Billing data: where applicable, billing contacts and transaction references (payment card data is processed by third-party payment providers, not stored by us).

2.2 Information collected automatically

• Device & log data: IP address, browser type, operating system, device identifiers, pages viewed, timestamps, and diagnostic logs.
• Authentication tokens: session identifiers and API tokens used to keep you signed in securely.
• Cookies & similar technologies: see Section 9 below.

2.3 Location and geolocation data

Because GMS Estate provides gate verification and visitor access control, we may collect and process precise geolocation data, including:

• GPS coordinates captured by security officers during gate verification;
• Property and estate latitude/longitude associated with tenant units;
• Location data embedded in visitor QR codes and access passes to identify the destination address;
• Geolocation logs used to validate that check-ins occur within authorized gate radii.

Location data is used solely for security, access control, audit, and fraud-prevention purposes unless you provide separate consent for other uses.

3. How we use personal information

We use personal information to:

1. Provide, operate, maintain, and improve the Services;
2. Authenticate users and enforce role-based access (admin, tenant, security, landlord);
3. Generate, validate, and revoke visitor access codes and QR passes;
4. Record gate check-ins, security events, and audit trails;
5. Send transactional notifications (access codes, check-in alerts, Telegram/webhook messages where configured);
6. Respond to support requests and communicate about the Services;
7. Detect, prevent, and address fraud, abuse, security incidents, and legal compliance obligations;
8. Comply with applicable law, regulation, court order, or lawful government request;
9. With your consent, for any other purpose disclosed at the time of collection.

4. Legal bases for processing (where applicable)

Depending on your jurisdiction, we rely on one or more of the following legal bases:

• Contract: processing necessary to perform our agreement with you or your estate management organization;
• Legitimate interests: securing estates, preventing unauthorized access, and improving platform safety, balanced against your rights;
• Legal obligation: compliance with NDPA, NDPR, tax, security, and law-enforcement requirements;
• Consent: where required for optional features, marketing, or non-essential cookies.

5. How we share information

We do not sell your personal information. We may share data with:

• Estate administrators & authorized users within your organization according to role permissions;
• Security personnel for gate verification and visitor management;
• Service providers who assist with hosting, email/SMS delivery, Telegram notifications, analytics, and customer support, under contractual confidentiality and data-processing terms;
• Professional advisers (lawyers, auditors) under duty of confidentiality;
• Authorities when required by law or to protect rights, safety, and property;
• Business transfers in connection with a merger, acquisition, or asset sale, with notice where required by law.

6. International transfers

Your data may be processed in Nigeria or other countries where we or our service providers operate. Where personal data is transferred outside Nigeria or the EEA, we implement appropriate safeguards such as standard contractual clauses, adequacy decisions, or other mechanisms recognized under applicable law.

7. Data retention

We retain personal information only as long as necessary for the purposes described in this Policy, including:

• Active account duration and a reasonable period thereafter;
• Visitor access logs and security audit records (typically up to 24 months unless a longer period is required for investigations or legal compliance);
• Legal, tax, and regulatory retention periods.

When data is no longer needed, we delete or anonymize it using commercially reasonable methods.

8. Security

We implement administrative, technical, and organizational measures designed to protect personal information, including encryption in transit (HTTPS/TLS), hashed passwords, access controls, audit logging, and role-based permissions. No method of transmission or storage is 100% secure; we cannot guarantee absolute security.

9. Cookies and tracking technologies

We use cookies and similar technologies to:

• Maintain login sessions and security;
• Remember preferences (e.g., cookie consent);
• Analyze usage to improve the Services.

You can control cookies through your browser settings. Disabling essential cookies may affect platform functionality. Where required by law, we obtain consent before placing non-essential cookies.

10. Your privacy rights

Subject to applicable law, you may have the right to:

• Access personal information we hold about you;
• Rectify inaccurate or incomplete data;
• Erase data where processing is no longer lawful or necessary;
• Restrict or object to certain processing;
• Data portability — receive a structured, machine-readable copy;
• Withdraw consent where processing is consent-based;
• Lodge a complaint with the Nigeria Data Protection Commission (NDPC) or your local supervisory authority.

To exercise these rights, contact info@gms.estate. We may verify your identity before responding. We aim to respond within 30 days.

11. Children's privacy

The Services are not directed to individuals under 18 (or the age of majority in your jurisdiction). We do not knowingly collect personal information from children. If you believe a child has provided us data, contact us and we will delete it promptly.

12. Third-party links and services

The Services may link to third-party websites (e.g., maps, messaging apps). We are not responsible for their privacy practices. Review their policies before providing personal information.

13. Automated decision-making

We do not use solely automated decision-making that produces legal or similarly significant effects without human oversight. GPS validation flags may assist security staff but do not alone deny legal rights without review.

14. Changes to this Privacy Policy

We may update this Policy from time to time. Material changes will be posted on this page with an updated effective date. Continued use after changes constitutes acceptance where permitted by law.

15. Contact us

For privacy inquiries, data subject requests, or complaints:

• Email: info@gms.estate
• Mail: GMS Estate Technologies Ltd., Plot 43, 441 Crescent, Citec Villas, Gwarinpa, Abuja, Nigeria