Privacy Policy

Introduction

Tutela Africa Limited (Tutela) is committed to protecting the privacy and confidentiality of the personal information ("Personal Data") of individuals who use our estate management solutions, including guest access, utility payments, and issue reporting services ("Services"). This Privacy Policy explains how Tutela collects, uses, stores, and discloses Personal Data in compliance with the Nigeria Data Protection Regulation (NDPR) and other relevant data protection laws in Nigeria.

1. Data Collection

Tutela collects Personal Data from you in the following circumstances:

  • When you register for or use our services.
  • When you communicate with us by phone, email, or through our platforms.
  • When you create or maintain a profile with us.
  • When you submit issues, reports, or requests related to estate management.
  • When you make payments for utilities or other services through our platforms.

2. Types of Personal Data We Collect

The types of Personal Data Tutela may collect include, but are not limited to:

  • Personal identification details such as name, contact information, date of birth, and identification documents.
  • Service-related data such as issue reports, utility payments, and visitor access details.
  • Technical data related to your device, including IP address or addresses, browser type, and operating system.
  • Any additional information you voluntarily provide while using our services.

3. Legal Basis for Processing

Tutela has expressly been allowed to process your Personal Data under the NDPR based on the following legal grounds:

  • Consent: Your explicit consent for processing your Personal Data for specific purposes.
  • Contractual Necessity: Processing is necessary to perform our contract with you, such as providing estate management services.
  • Legal Obligation: We process your Personal Data to comply with legal obligations, including regulatory and tax reporting.
  • Legitimate Interest: We process Personal Data for legitimate business interests, such as improving our services and ensuring security, provided that such processing does not violate your fundamental rights and freedoms.

4. How We Use Personal Data

Tutela uses Personal Data to:

  • Provide, manage, and improve our estate management solutions.
  • Process payments for utilities and other services.
  • Communicate with you regarding service updates, issues, or requests.
  • Address and resolve issues or complaints you report.
  • Ensure compliance with legal, regulatory, and security obligations.
  • Customize your experience and enhance the quality of our services.

5. Data Sharing and Disclosure

Tutela can only share Personal Data with:

  • Service Providers: Trusted third parties that assist us in providing our services (e.g., IT providers, payment processors), who are also bound by the NDPR to protect your data.
  • Law Enforcement Authorities: When required by applicable law, to comply with a legal obligation or government request.
  • Business Partners: Where necessary, for fulfilling specific service requests.
  • Other Legitimate Reasons: We may disclose your Personal Data to third parties in connection with corporate restructuring, mergers, or acquisitions, provided such parties are bound to protect your data in accordance with applicable laws.

We will never sell, rent, or trade your Personal Data with third parties for marketing purposes.

6. Data Retention

Tutela has the right to retain Personal Data for the duration of the services provided to you and afterwards, as long as it is legally necessary for business, regulatory, or audit purposes. Upon the expiration of retention periods, we will securely delete or anonymize your data, in line with the NDPR.

7. Data Security

Tutela implements appropriate technical and organizational measures to protect your Personal Data against unauthorized access, alteration, disclosure, or destruction. This includes encryption, firewalls, and access control mechanisms. However, please note that no system is completely secure, and we cannot guarantee the absolute security of Personal Data.

8. Your Rights Under the NDPR

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

  • Right to Access: You may request access to the Personal Data we hold about you.
  • Right to Rectification: You have the right to request the correction of inaccurate Personal Data.
  • Right to Erasure: You may request that we delete your Personal Data in certain circumstances.
  • Right to Object: You can object to the processing of your Personal Data where we rely on legitimate interests.
  • Right to Data Portability: You have the right to request that your data be transferred to another data controller, where technically feasible.
  • Right to Withdraw Consent: You may withdraw your consent for data processing at any time without affecting the lawfulness of processing prior to withdrawal.

To exercise any of these rights, please contact us at datacontroller@tutela.com.ng

9. International Data Transfers

If Tutela has to transfer your Personal Data outside Nigeria, Tutela will ensure that appropriate safeguards are in place in accordance with the NDPR to protect your data. These measures include ensuring the recipient country provides an adequate level of data protection or that we have implemented legally recognized mechanisms such as standard contractual clauses.

10. Data Breach Notification

In the event of a data breach that may pose a risk to your rights and freedoms, Tutela will promptly notify you and the National Information Technology Development Agency (NITDA) as required under the NDPR and take appropriate measures to mitigate the impact.

11. Cookies and Tracking Technologies

Tutela uses cookies and similar tracking technologies to improve your experience on our website and mobile app. Cookies help us track user activity, store preferences, and provide customized content. You can manage cookie preferences through your browser settings.

12. Changes to this Privacy Policy

Tutela may update this Privacy Policy from time to time in response to local and international compliance developments. Tutela reserves the rights to inform you of any changes by posting the updated Privacy Policy on our website and platforms. Continued use of our services after such updates constitutes your acceptance of the revised policy.

13. Contact Us

If you have any questions about this Privacy Policy or wish to exercise your data protection rights, please contact us at: