STOW

Privacy Policy

WHO WE ARE

We are OCTO5 HOLDINGS LIMITED, a full-service technological real estate company with our address at Plot 3B Block 12, Frajend Street, Osborne Foreshore Estate, Ikoyi, Lagos State, Nigeria. We can be reached via our email address at info@octo5.co.

As a Data Controller, providing real estate services to various data subjects and operating the STOW Application, we hereby set out our privacy policy in full compliance with the relevant data protection legislation and in a clear indication of our transparency and regulatory compliance.

WHAT PERSONAL DATA DO WE COLLECT

The personal data we collect from you (may) include:

your names, email addresses, telephone numbers, and location (where applicable);
your images (as processed by the video conferencing apps) or at live events, your voice, views, opinions, etc;
and all other personal data that you expose to us in the course of your dealings with us.


WHY WE NEED YOUR DATA

We collect information through our website, interviews, briefings, video conferences, live events, forms, email correspondences, telephone conversations, documents given to us, etc.:

to meet your real estate demands;
to facilitate the dissemination of information about industry news, our association, and other events;
to improve analytics, research, etc;
for record keeping and accountability;
for the purpose of registration and participation in our online and offline events;
to provide up-to-date information on your chosen property, etc;
provide you with information about other services we may render in the future;
gather feedback to improve our services, for example, our email alerts;
respond to any feedback you send us if you’ve asked us to;
monitor participation at our events.


OUR LEGAL BASIS FOR PROCESSING YOUR DATA

The legal basis for processing your personal data is your consent and our legitimate interest of meeting our objective of providing top-notch services to you through our STOW Application.

WHAT CONSTITUTES CONSENT

How do you give your consent? Your consent is given when you voluntarily surrender your documents or information to us to facilitate the provision of legal and other services to you.

You are also consenting to our processing of your personal data when you sign up to use the STOW Application, sign up for our webinars or other events, or subscribe to our newsletters or email alerts, or when you provide us with your personal data to enable you to participate at our events, receive information from us, or take advantage of the services we are rendering through our online platform.

If we ask for your personal information for a secondary reason, like marketing, we will either ask you directly for your express consent or provide you with an opportunity to say no.

HOW TO WITHDRAW CONSENT

It is deemed that you have attained the legal age requirement of the laws of the Federal Republic of Nigeria after you opt in. When you change your mind, you may withdraw your consent for us to contact you, for the continued collection, use, disclosure, or otherwise processing of your information, at any time, by contacting us at info@octo5.co

Please note that such withdrawal of consent shall not affect the lawfulness of processing based on consent before the withdrawal.

WHAT WE DO WITH YOUR DATA

The data we collect may be shared with our employees or legal team, or Data Protection Officer. It may also be shared with our technology suppliers, for example, our hosting provider(s). We may also share your personal data with third parties when the same is processed in the course of our provision of services to you.

We will NOT:

sell or rent your data to third parties;
share your data with third parties for marketing purposes;
expose your data to unauthorized persons in our organization.
We will share your data if we are required to do so by law – for example, by court order, or to prevent fraud or other crime.

HOW LONG WE KEEP YOUR DATA

We will only retain your personal data:

for as long as the law requires us to;
if it is needed for the purposes set out in this policy or our contract with you;
except you exercise your right to request the deletion of personal data.


WHERE YOUR DATA IS PROCESSED AND STORED

We design and run our systems to make sure that your data is as safe as possible at all stages, both while it’s processed and when it’s stored. All personal data are stored in our data cloud and computer hardware, except the ones stored via conferencing and other apps we use.

TRACKING COOKIES DATA

We use cookies and similar tracking technologies to track the activity on our Service and we hold certain information.

Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. We use these to collect and track information and to improve and analyze our Service.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

HOW WE PROTECT YOUR DATA AND KEEP IT SECURE

We are committed to doing all that we can, to keep your data secure. We have set up systems and processes to prevent unauthorized access or disclosure of your data.

We also make sure that any third parties that we deal with keep all personal data they process on our behalf secure.

YOUR RIGHTS

You have the following rights under the data protection legislation:

information on how your personal data is processed
right of access to your personal data
right to withdraw consent at any time
right to object to the processing of your data
right to rectification of your data
right to request us to transfer your data to another entity electronically
right to lodge a complaint to the supervisory authority, National Information Technology Development Agency (NITDA)
raise an objection about how your personal data is processed
request that your personal data be erased if there is no longer a justification for it
ask that the processing of your personal data is restricted in certain circumstances
If you have any of these requests, get in contact with our Data Protection Officer via info@octo5.co

REMEDIES

We will address any complaint or any violation of your privacy rights in accordance with the Nigeria Data Protection Regulation (NDPR) 2019. You are also at liberty to file an action in court for redress or lodge a complaint with NITDA.

TIME FRAME FOR REMEDIES

This shall be determined by a court of competent jurisdiction or the regulator as the case may be.

LINKS TO OTHER WEBSITES

This privacy policy only applies to our activities and does not cover other third-party links, services or transactions that we connect to. These services or sites have their own terms and conditions and privacy policies.

FOLLOWING A LINK TO ANOTHER WEBSITE

If a link takes you to a 3rd party website or application from the STOW Application, read the privacy policy on that website or application to understand its privacy policy and what it does with your information.

GOVERNING PRINCIPLES OF OUR DATA PROCESSING

We guarantee that your personal data shall be:

collected and processed in accordance with specific, legitimate, and lawful purpose consented to by you; provided that further processing may be done only for archiving, scientific research, historical research, or statistical purposes for the public interest;
restricted to you and shall not be transferred to any person or entity except when required by law;
adequate, accurate, and without prejudice to the dignity of the human person;
stored only for the period within which it is reasonably needed, and
secured against all foreseeable hazards and breaches such as theft, cyber-attack, viral attack, dissemination, manipulations of any kind, damage by rain, fire or exposure to other natural elements.
Not used for any automated decision-making or profiling etc.

COPYRIGHT

The Application STOW, its logo, and its brand are all copyright property of OCTO5 Holdings Limited. You acknowledge that OCTO5 Holdings Limited has exclusive copyright over any translation of any and all sales literature, promotional, descriptive, or marketing materials on the STOW Application, including video, photographs, written text, and graphic representations.

CONTACT US OR MAKE A COMPLAINT

Contact our Data Protection Officer (DPO) if you:

wish to register a data compliance issue with us
have a question about anything in this privacy notice
think that your personal data has been misused or mishandled


DATA PROTECTION OFFICER (DPO)

The DPO provides independent advice and monitoring of our use of personal information.

You can also make a complaint to NITDA which is an independent regulator.

CHANGES TO THIS POLICY

We may change this privacy policy. In that case, the ‘last updated date at the bottom of this page will also change. Any changes to this privacy policy will apply to you and your data immediately.

If these changes affect how your personal data is processed, we will take reasonable steps to let you know.

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Last updated August 26, 2020