VITA NOVA LandBank

VITA NOVA Land Banking Limited ("VITA NOVA LandBank," "we," "us," or "our") is committed to protecting the privacy and security of your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website, use our mobile applications, or engage with our services (collectively, the "Platform").

This Privacy Policy is issued in compliance with the Nigeria Data Protection Regulation (NDPR) 2019, the Nigeria Data Protection Act (NDPA) 2023, and other applicable data protection laws. By accessing or using our Platform, you consent to the collection and use of your information as described in this Policy.

1. Information We Collect

We collect information that you provide directly to us, information collected automatically when you use the Platform, and information obtained from third-party sources. The categories of personal data we may collect include:

Information You Provide

Identity Data: Full name, date of birth, gender, nationality, passport photograph, and government-issued identification (such as National Identification Number, International Passport, Driver's Licence, or Voter's Card);
Contact Data: Email address, phone number, residential address, and postal address;
Financial Data: Bank account details, payment card information, Bank Verification Number (BVN), and transaction history;
Investment Data: Property purchase history, payment schedules, instalment records, and allocation details;
Communication Data: Records of correspondence with our team, including emails, chat transcripts, and call recordings (where applicable and with your consent);
Next-of-Kin Data: Name, relationship, phone number, and address of your designated next of kin, as may be required for property documentation.

Information Collected Automatically

Device Data: IP address, browser type and version, operating system, device type, and unique device identifiers;
Usage Data: Pages visited, time spent on pages, links clicked, search queries, and browsing patterns;
Location Data: Approximate geographic location derived from your IP address or, with your consent, precise location data from your mobile device.

Information from Third Parties

We may receive personal data about you from third parties, including identity verification services, credit reference bureaus, payment processors, and government databases, for the purposes of verifying your identity and complying with regulatory obligations, including Know Your Customer (KYC) and Anti-Money Laundering (AML) requirements.

2. How We Use Your Information

We process your personal data for the following purposes, each of which is supported by a lawful basis under the NDPR and NDPA:

Service Delivery: To create and manage your account, process transactions, facilitate property purchases, and provide customer support;
Identity Verification: To verify your identity in compliance with KYC and AML regulations, and to prevent fraud;
Communication: To send you transaction confirmations, payment reminders, account updates, and responses to your enquiries;
Marketing: To send you promotional communications about our properties, services, and events, where you have consented to receive such communications. You may opt out at any time;
Legal Compliance: To comply with applicable laws, regulations, legal processes, and governmental requests, including requirements of the Securities and Exchange Commission (SEC), the Corporate Affairs Commission (CAC), and other relevant regulatory bodies;
Platform Improvement: To analyze usage patterns, diagnose technical issues, and improve the functionality, security, and user experience of our Platform;
Risk Management: To detect, investigate, and prevent fraudulent transactions, unauthorized access, and other illegal activities.

We do not sell your personal data to third parties. However, we may share your information with the following categories of recipients, strictly on a need-to-know basis and in accordance with applicable law:

Service Providers: Third-party companies that provide services on our behalf, including payment processors, cloud hosting providers, email delivery services, and analytics platforms. These providers are contractually obligated to protect your data and use it only for the purposes we specify;
Legal and Professional Advisors: Solicitors, surveyors, and other professionals engaged in the processing of your property transactions;
Government Authorities: Land registries, the Federal Inland Revenue Service (FIRS), state internal revenue services, and other government agencies, as required for property registration, tax compliance, and regulatory purposes;
Regulatory Bodies: The Nigeria Data Protection Commission (NDPC), SEC, and other regulatory authorities, in response to lawful requests or as required to comply with applicable regulations;
Business Partners: Trusted partners involved in delivering specific aspects of our services, such as estate development partners and property management firms, subject to appropriate data protection agreements.

4. Data Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. These measures include:

Encryption of sensitive data in transit and at rest using industry-standard protocols;
Access controls and authentication mechanisms to restrict data access to authorized personnel only;
Regular security assessments, vulnerability testing, and penetration testing of our systems;
Employee training on data protection principles and secure data handling practices;
Incident response procedures to detect, report, and address data breaches promptly.

While we strive to use commercially acceptable means to protect your personal data, no method of electronic transmission or storage is 100% secure. We cannot guarantee the absolute security of your information, but we commit to notifying you and the Nigeria Data Protection Commission of any data breach that poses a risk to your rights and freedoms, in accordance with the NDPR and NDPA.

5. Your Rights

Under the NDPR and NDPA, you have the following rights in relation to your personal data:

Right of Access: You have the right to request a copy of the personal data we hold about you;
Right to Rectification: You have the right to request that we correct any inaccurate or incomplete personal data;
Right to Erasure: You have the right to request the deletion of your personal data, subject to legal and contractual retention obligations;
Right to Restrict Processing: You have the right to request that we limit the processing of your personal data in certain circumstances;
Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format;
Right to Object: You have the right to object to the processing of your personal data for marketing purposes or where processing is based on our legitimate interests;
Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

To exercise any of these rights, please contact our Data Protection Officer at legal@vitanovalandbank.com. We will respond to your request within thirty (30) days.

6. Cookies and Tracking Technologies

Our Platform uses cookies and similar tracking technologies to enhance your browsing experience, analyze site traffic, and personalize content. Cookies are small text files stored on your device when you visit our website. We use the following types of cookies:

Essential Cookies: Necessary for the basic functionality of the Platform, such as session management and security;
Analytics Cookies: Help us understand how visitors interact with the Platform by collecting information about pages visited, time spent, and navigation patterns;
Marketing Cookies: Used to deliver relevant advertisements and measure the effectiveness of our marketing campaigns.

You can control cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the Platform.

7. Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law. Specific retention periods include:

Account Data: Retained for the duration of your account and for a period of six (6) years after account closure, in compliance with tax and regulatory requirements;
Transaction Data: Retained for a minimum of six (6) years from the date of the transaction, as required by the Federal Inland Revenue Service and the Companies and Allied Matters Act;
Communication Records: Retained for a period of three (3) years from the date of the communication;
Marketing Preferences: Retained until you withdraw your consent or unsubscribe from marketing communications.

Upon expiry of the relevant retention period, your personal data will be securely deleted or anonymized in accordance with our data disposal procedures.

8. International Data Transfers

Your personal data is primarily stored and processed in Nigeria. In the event that we need to transfer your data to a country outside Nigeria, we will ensure that adequate safeguards are in place in accordance with the NDPR and NDPA, including the execution of standard contractual clauses and verification that the receiving country provides an adequate level of data protection.

9. Children's Privacy

Our Platform is not directed to individuals under the age of eighteen (18). We do not knowingly collect personal data from children. If you are a parent or guardian and believe that your child has provided us with personal data, please contact us at legal@vitanovalandbank.com, and we will take steps to delete such information from our systems.

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other factors. When we make material changes, we will notify you by posting the updated Policy on our Platform with a revised "Last Updated" date. We may also notify you via email or through a prominent notice on the Platform. We encourage you to review this Policy periodically to stay informed about how we are protecting your information.

11. Contact Us

If you have any questions, concerns, or complaints about this Privacy Policy or our data processing practices, please contact our Data Protection Officer:

Data Protection Officer
VITA NOVA Land Banking Limited
14B Admiralty Way, Lekki Phase 1,
Lagos, Nigeria.
Email: legal@vitanovalandbank.com
Phone: +234 (0) 1 700 0000

You also have the right to lodge a complaint with the Nigeria Data Protection Commission (NDPC) if you believe that your data protection rights have been violated. Information on how to contact the NDPC is available at ndpc.gov.ng.

Privacy Policy