PRIVACY POLICY

1. INTRODUCTION

House Number Five Ltd ("the Company", "we", "us" or "our") is a duly incorporated company with its headquarters and primary operational base in the Federal Republic of Nigeria, engaged in premium real estate development, smart city construction, infrastructure delivery, property design, interior solutions, and allied services across Nigeria and other jurisdictions within Africa. Our business activities are not limited to the foregoing description and may evolve in line with corporate objectives, regulatory developments, and market needs.

We recognise the importance of privacy, data protection, and informational autonomy, and we are committed to safeguarding the personal data of individuals with whom we interact, including but not limited to clients, investors, partners, contractors, consultants, employees, prospective purchasers, tenants, visitors to our digital platforms, and members of the public.

This Privacy Policy sets out how we collect, use, store, disclose, protect, and process personal data, in accordance with Nigeria's data protection and privacy jurisprudence, including but not limited to:

• The Constitution of the Federal Republic of Nigeria, 1999 (as amended);
• The Nigeria Data Protection Act, 2023 (NDPA);
• The Nigeria Data Protection Regulation (NDPR) 2019 and its subsidiary instruments;
• Guidelines, directives, and enforcement frameworks issued by the Nigeria Data Protection Commission (NDPC);
• Applicable common law principles and equitable doctrines; and
• Any other applicable data protection laws where our operations extend.

2. SCOPE AND APPLICATION

This Privacy Policy applies to:

• All personal data processed by House Number Five Ltd in the course of its business operations;
• Data collected through our websites, digital platforms, mobile applications, social media channels, smart city technologies, customer relationship systems, and physical interactions;
• Data relating to individuals located within Nigeria and, where applicable, outside Nigeria, subject to conflict-of-law rules and extraterritorial applicability of relevant data protection regimes.

3. CONSTITUTIONAL AND LEGAL FOUNDATION

Pursuant to Section 37 of the Constitution of the Federal Republic of Nigeria, 1999 (as amended), the privacy of citizens, their homes, correspondence, telephone conversations, and telegraphic communications is guaranteed and protected.

House Number Five Ltd acknowledges that data privacy is both a constitutional right and a statutory obligation, and we process personal data in a manner that is lawful, fair, transparent, proportionate, and accountable.

4. DEFINITIONS

For the purposes of this Privacy Policy:

• "Personal Data" means any information relating to an identified or identifiable natural person.
• "Data Subject" means an individual whose personal data is processed by the Company.
• "Processing" includes collection, recording, storage, adaptation, retrieval, use, disclosure, transmission, dissemination, restriction, erasure, or destruction of personal data.
• "Sensitive Personal Data" includes data relating to health, biometrics, financial information, religious beliefs, or any category designated under Nigerian law.
• "Data Controller" refers to House Number Five Ltd.

5. CATEGORIES OF PERSONAL DATA WE COLLECT

We may collect and process the following categories of data:

5.1 Identification and Contact Data

• Full name, title, date of birth
• Residential and correspondence addresses
• Email address and telephone numbers

5.2 Financial and Transactional Data

• Bank account details (where required)
• Payment records and transaction history
• Investment-related information

5.3 Property and Contractual Data

• Property preferences
• Purchase, lease, or development agreements
• Due diligence and compliance records

5.4 Technical and Digital Data

• IP address, browser type, device identifiers
• Website usage analytics and cookies
• Smart city platform interaction data

5.5 Employment and Professional Data

• Curriculum vitae, qualifications
• Employment records and references

6. LAWFUL BASIS FOR PROCESSING

We process personal data on one or more of the following lawful bases:

• Consent of the data subject;
• Performance of a contract or pre-contractual measures;
• Compliance with legal obligations under Nigerian law;
• Legitimate interests of the Company, provided such interests do not override the rights of the data subject;
• Protection of vital interests;
• Public interest or regulatory compliance.

7. PURPOSES OF PROCESSING

Personal data is processed for purposes including but not limited to:

• Real estate development, sales, leasing, and property management;
• Smart city planning, infrastructure delivery, and technology integration;
• Client onboarding, due diligence, and compliance checks;
• Financial management and accounting;
• Legal, regulatory, and statutory compliance;
• Marketing, communication, and relationship management;
• Security, fraud prevention, and risk management.

8. DATA SHARING AND DISCLOSURE

We may disclose personal data to:

• Regulatory and governmental authorities where required by law;
• Professional advisers including lawyers, auditors, and consultants;
• Financial institutions and payment processors;
• Contractors, vendors, and service providers under strict confidentiality obligations;
• Affiliated or subsidiary entities within the House Number Five corporate structure.

We do not sell personal data.

9. INTERNATIONAL DATA TRANSFERS

Where personal data is transferred outside Nigeria, we ensure:

• Adequate data protection safeguards;
• Compliance with NDPA cross-border transfer requirements;
• Contractual protections and data transfer agreements where necessary.

10. DATA SECURITY MEASURES

We implement appropriate technical, administrative, and organisational measures to protect personal data against unauthorised access, loss, misuse, alteration, or disclosure, including:

• Access controls and authentication systems;
• Encryption and secure storage;
• Staff confidentiality obligations;
• Periodic audits and risk assessments.

11. DATA RETENTION

Personal data is retained only for as long as is necessary to fulfil the purposes for which it was collected, or as required by law, after which it is securely deleted or anonymised.

12. RIGHTS OF DATA SUBJECTS

Data subjects are entitled to:

• Access their personal data;
• Rectification of inaccurate data;
• Erasure (right to be forgotten);
• Restriction or objection to processing;
• Data portability;
• Withdrawal of consent;
• Lodging complaints with the Nigeria Data Protection Commission.

13. COOKIES AND DIGITAL TECHNOLOGIES

Our digital platforms may use cookies and similar technologies to enhance user experience. Users may manage cookie preferences through browser settings.

14. CHILDREN'S DATA

We do not knowingly collect or process personal data of minors without appropriate parental or guardian consent, in compliance with Nigerian law.

15. AMENDMENTS AND UPDATES

This Privacy Policy may be updated periodically to reflect legal, regulatory, or operational changes. Updates will be communicated through appropriate channels.

16. GOVERNING LAW AND JURISDICTION

This Privacy Policy is governed by and construed in accordance with the laws of the Federal Republic of Nigeria, and any disputes arising herefrom shall be subject to the exclusive jurisdiction of Nigerian courts.

17. CONTACT INFORMATION

For questions, requests, or complaints regarding this Privacy Policy or data protection practices, please contact: