Privacy Policy

1. SCOPE & LEGAL SHIELDS

This Privacy Policy governs the collection, usage, and protection of data by NEWCONDO Ltd ("NEWCONDO", "we", "our", or "us") across our platform. It applies to all user classes—Renters, Property Owners, Agents, and Visitors.

By accessing or using our platform, you agree to the following legally binding clauses:

• Binding Arbitration: All disputes shall be resolved via confidential individual arbitration in accordance with the Nigerian Arbitration and Conciliation Act. Venue shall be Owerri, Imo State.
• Class Action Waiver: You permanently waive your right to initiate or participate in any class or representative actions.
• Limitation of Liability: Our maximum liability is capped at six months' worth of your paid platform fees, regardless of the basis for the claim.
• Force Majeure: We assume no liability for data compromise or service unavailability resulting from cyber warfare, terrorism, natural disasters, nationwide strikes, or advanced zero-day vulnerabilities.

2. INFORMATION COLLECTION & ANONYMIZATION

Collected Data Matrix

Technical Safeguards

• Hashing: Personally identifiable information (PII) such as names and IDs are irreversibly converted into SHA-256 hash strings within 72 hours of collection.
• Tokenization: Bank details are replaced with obfuscated tokens (e.g., TXT-XXXX) post-transaction to prevent reuse or replay attacks.
• k-Anonymity (Geo): Location data is generalized to a 1-kilometer radius to prevent individual property tracing.
• Backup Scrubbing: Raw user data is erased from system backups within 30 days, validated by external auditors (PwC Nigeria).

3. VULNERABILITY PATCHES & RISK MITIGATION

4. DATA USAGE & SHARING

Permitted Uses

• Identity and property verification via authorized government APIs (e.g., e-GIS portals).
• Financial processing via secure PCI-DSS compliant payment providers (e.g., Flutterwave).
• Pattern-based fraud detection through event tracking and behavioral analytics.

Explicit Prohibitions

• No use of personal data for marketing without explicit opt-in.
• No sharing of data with marketplace service providers.

5. DATA RETENTION & DELETION POLICY

NOTE: All deletions follow NIST SP 800-88 Rev.1 data sanitization guidelines.

6. SECURITY FRAMEWORK & BREACH RESPONSE

• Encryption Protocols: AES-256 encryption for stored data and TLS 1.3 for all transmission channels.
• Access Management: Role-based access with periodic audits and automatic expiry of dormant privileges.
• Breach Notification Process:
  • Notify NDPC within 48 hours of verified breach.
  • Initiate forensic audit within 72 hours.
  • Affected users will be directly notified for high-risk incidents.

7. USER RIGHTS & SAFEGUARDS

Data Subject Rights

You may invoke the following rights under Nigeria Data Protection Act (NDPA):

• Right to Access, Correction, and Erasure of your data.
• Right to Object to non-essential data processing.
• Submit requests to: info@newcondo.homes (response within 30 days).

Anti-Abuse Measures

To protect platform integrity, users acknowledge the following penalty clause:

8. GOVERNANCE, AUDITS & POLICY UPDATES

• Third-Party Certifications: Annual SOC 2 Type II by KPMG
• ISO 27001: Implementation targeted for Q4 2026
• DPAs & Legal Assurance: Enforceable DPAs with all financial and hosting partners
• Policy Updates: All changes communicated at least 3 days in advance via platform banners or email. Continued use after update = automatic acceptance.
• Dispute Resolution: All user disputes shall be resolved via confidential arbitration seated in Owerri, Imo State.

9. USER ACKNOWLEDGMENTS (MANDATORY)

Upon account registration or usage, all users affirm the following declarations:

10. CONTACT INFORMATION

11. COPYRIGHT NOTICE & ENFORCEMENT