Privacy Policy

1. Who We Are

Dwella is a property intelligence and community review platform.

Dwella helps people research properties and share experiences about places they have lived or otherwise experienced.

For privacy and data-protection purposes, Dwella may act as a data controller in relation to personal information it determines the purposes and means of processing.

Official Dwella legal/privacy contact: hello@dwella.com.ng

2. Information We Collect

Depending on how you use Dwella, we may collect different types of information.

This may include:

Account information:

• name or display name;
• email address;
• account credentials and authentication information;
• profile information you choose to provide.

Review and rating information:

• reviews;
• ratings;
• property experiences;
• occupancy period information;
• information you provide when submitting a review.

Verification information:

• supporting documents submitted to demonstrate occupancy or connection to a property;
• information contained within those documents;
• information necessary to assess whether a review qualifies for verification.

Property and search activity:

• properties you search for;
• properties you save;
• interactions with property information;
• information associated with reviews or reports you submit.

Communications:

• notifications;
• messages or communications you send to Dwella;
• reports and complaints;
• responses to reviews where applicable.

Technical information:

• IP address;
• browser and device information;
• operating system;
• general usage information;
• security and diagnostic information;
• information about how you interact with the platform.

Dwella will only collect information that is reasonably necessary for the purposes described in this Privacy Policy or otherwise permitted by applicable law.

3. How We Use Your Information

We may use personal information to:

• create and manage user accounts;
• authenticate users;
• provide access to Dwella features;
• process reviews and ratings;
• verify reviews where verification is requested;
• maintain and improve the accuracy and usefulness of property information;
• moderate reviews and other user-generated content;
• investigate reports, complaints, fraud, abuse, or misuse;
• send notifications and important service communications;
• maintain platform security;
• detect and prevent unauthorised access or other harmful activity;
• improve the performance, usability, and functionality of Dwella;
• understand how users interact with the platform;
• comply with legal and regulatory obligations;
• establish, exercise, or defend legal rights;
• protect users, Dwella, and other persons where necessary.

4. Reviews and Public Information

Some information submitted to Dwella may be displayed publicly.

Depending on the feature and your settings, this may include:

• your display name or contributor name;
• your review;
• your ratings;
• the property associated with your review;
• the general period or context of your property experience;
• verification status associated with a review.

Do not include personal information about yourself or another person in a public review unless you are comfortable with that information being publicly displayed.

Dwella may remove personal or sensitive information from publicly displayed content where appropriate.

5. Verification Documents

Dwella may request supporting documents when a user wants a review or property experience to be verified.

These documents may contain personal information.

Dwella uses verification information primarily to:

• assess whether the submitted information supports the claimed property connection;
• determine whether a review qualifies for a verification status;
• prevent fraudulent or misleading reviews;
• protect the integrity of the Dwella review system.

Verification documents are not intended to be publicly displayed as submitted.

Dwella may restrict access to verification documents to authorised personnel or systems that require access for legitimate operational, security, verification, or legal purposes.

Users should only submit documents they are legally entitled to provide.

Where possible, users should avoid submitting unnecessary personal information that is unrelated to verification.

6. Legal Bases for Processing

Where applicable, Dwella processes personal information on one or more lawful bases recognised under applicable data-protection law.

Depending on the circumstances, these may include:

• performance of a contract or taking steps at your request before entering into a contract;
• compliance with a legal obligation;
• consent;
• legitimate interests, where applicable and where those interests are not overridden by the rights and freedoms of the data subject;
• protection of vital interests where applicable;
• other lawful bases permitted by applicable law.

The specific legal basis may depend on the particular processing activity.

Where Dwella relies on consent, you may withdraw that consent where permitted by law.

7. Cookies and Similar Technologies

Dwella may use cookies and similar technologies to support essential platform functionality, security, preferences, analytics, and other legitimate platform purposes.

Where applicable, Dwella will provide appropriate information and choices regarding non-essential cookies.

A separate cookie notice or cookie-management mechanism may be introduced as the platform develops.

Do not implement a cookie banner or cookie-management system as part of this task unless one already exists.

8. How We Share Information

Dwella may share personal information where reasonably necessary for legitimate platform operations or as permitted or required by applicable law.

This may include sharing information with:

• service providers that help operate the platform;
• hosting and infrastructure providers;
• authentication and security providers;
• analytics or technical service providers;
• storage providers;
• professional advisers where necessary;
• regulators, law-enforcement authorities, courts, or other public bodies where legally required;
• parties involved in protecting Dwella's rights, users, security, or property.

Dwella does not sell users' personal information simply because they use the platform.

Where third-party service providers process personal information on Dwella's behalf, Dwella will take reasonable steps to require appropriate privacy and security protections.

9. Public Reviews and Landlord Responses

Dwella is a community review platform.

Reviews and ratings may be publicly visible because their purpose is to help other people make informed property decisions.

Where the platform allows a landlord, property manager, owner, or other relevant party to respond to a review, their response may also be publicly visible.

Users should therefore avoid including unnecessary private or sensitive information in reviews.

10. Data Security

Dwella takes reasonable technical and organisational measures to protect personal information against:

• unauthorised access;
• unauthorised disclosure;
• loss;
• misuse;
• alteration;
• destruction.

No internet-based service can guarantee absolute security.

If Dwella becomes aware of a data-security incident requiring notification under applicable law, Dwella will take appropriate steps in accordance with its legal obligations.

11. Data Retention

Dwella retains personal information only for as long as reasonably necessary for the purposes for which it was collected, to provide services, maintain legitimate business records, resolve disputes, enforce agreements, maintain security, or comply with legal obligations.

Different categories of information may therefore be retained for different periods.

Verification documents and other sensitive information may be subject to additional retention and deletion controls.

Where information is no longer required and there is no legal or legitimate reason to retain it, Dwella may securely delete, anonymise, or otherwise dispose of it.

12. Your Data-Protection Rights

Subject to applicable law, you may have rights relating to your personal information, including the right to:

• request access to personal information held about you;
• request correction of inaccurate or incomplete information;
• request deletion of personal information in appropriate circumstances;
• request restriction of processing in appropriate circumstances;
• object to certain processing;
• request portability of personal information where applicable;
• withdraw consent where processing is based on consent;
• object to certain forms of automated decision-making where applicable;
• lodge a complaint with the relevant data-protection authority.

These rights are subject to applicable legal conditions and exceptions.

13. How to Exercise Your Rights

To exercise a privacy or data-protection right, contact Dwella using: hello@dwella.com.ng

We may need to verify your identity before responding to certain requests.

Dwella will handle requests in accordance with applicable data-protection requirements.

14. Children's Privacy

Dwella is intended for people who are legally capable of using the service.

We do not knowingly seek to collect personal information from children where such collection is prohibited by applicable law.

If you believe a child has provided personal information to Dwella in circumstances where it should not have been collected, please contact us at: hello@dwella.com.ng

15. International Data Transfers

Some service providers used by Dwella may process information outside Nigeria.

Where personal information is transferred across borders, Dwella will take appropriate steps required by applicable law to protect that information.

16. Third-Party Services

Dwella may use third-party services for functions such as:

• authentication;
• hosting;
• database infrastructure;
• file storage;
• security;
• communications;
• analytics;
• notifications.

Third-party services may have their own privacy policies.

Dwella will take reasonable steps to work with service providers that provide appropriate privacy and security protections.

17. User-Generated Content

Reviews, ratings, comments, and other content submitted to Dwella may contain personal information.

Users are responsible for considering what personal information they choose to include in publicly visible content.

Dwella may moderate or remove content that contains unnecessary personal information, violates platform rules, or creates a privacy or safety concern.

18. Privacy by Design and Data Minimisation

Dwella aims to collect and process personal information only to the extent reasonably necessary for the platform's legitimate purposes.

We will seek to incorporate privacy and security considerations into the design and development of platform features.

As Dwella evolves, our privacy practices may also be updated to reflect new features, technologies, and legal requirements.

19. Changes to This Privacy Policy

Dwella may update this Privacy Policy from time to time.

When material changes are made, Dwella may provide reasonable notice through the platform or other appropriate means.

The updated version will be published on this page with a revised "Last updated" date.

20. Contact and Privacy Complaints

If you have a question, concern, privacy request, or complaint about how Dwella handles personal information, please contact:

Privacy contact: hello@dwella.com.ng

If you are not satisfied with how a privacy concern has been handled, you may have the right to raise the matter with the relevant data-protection authority in accordance with applicable law.

21. Governing Law

This Privacy Policy is intended to operate in accordance with applicable Nigerian data-protection and privacy law, including the Nigeria Data Protection Act 2023, as applicable.

Nothing in this Privacy Policy is intended to remove or restrict rights that cannot lawfully be removed or restricted.