Privacy Policy

1. Who We Are

Dwella is a property intelligence and community review platform focused on residential rental properties in Lagos, Nigeria.

Dwella allows people to research properties, read occupant experiences and ratings, and share their own experiences about properties they have lived in.

For data-protection purposes, Dwella acts as a data controller where it determines the purposes and means of processing personal information.

Dwella processes personal information in accordance with applicable Nigerian data-protection law, including the Nigeria Data Protection Act 2023 (NDPA) and applicable guidance and requirements issued by the Nigeria Data Protection Commission (NDPC).

Privacy contact: hello@dwella.com.ng

2. Information We Collect

The information we collect depends on how you use Dwella.

Account Information

When you create or use a Dwella account, we may collect:

• your name
• your email address
• account credentials and authentication information
• profile information you choose to provide

Review and Rating Information

When you submit a review or rating, we may collect:

• your review
• ratings you provide
• information about your experience living at or otherwise experiencing a property
• your occupancy period or relevant experience period
• other information you provide as part of your review

Your published review may be associated with the full name or initials you choose to display.

Verification Information

If you choose to submit a verified review, Dwella may collect a utility bill as evidence of your connection to the property.

The utility bill must show the claimed residential property address and be dated within the previous 12 months.

Verification documents may contain personal or identifying information. Dwella collects and uses this information to assess the claimed property connection and determine whether the review qualifies for verified status.

Property and Search Activity

We may collect information relating to how you use property features, including:

• properties you search for
• properties you save
• properties you compare
• interactions with property information
• information associated with reviews, reports, or other actions you submit

Communications and Reports

We may collect:

• messages you send to Dwella
• notifications and notification-related information
• reports and complaints
• information provided when you contact Dwella about an account, review, property, privacy matter, or other issue

Technical and Security Information

We may automatically receive certain technical information when you use Dwella, including:

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

Dwella seeks to collect only personal 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

Dwella may use personal information to:

• create and manage user accounts
• authenticate users
• provide Dwella's features and services
• process reviews and ratings
• assess verification requests
• maintain the accuracy and usefulness of property information
• moderate reviews and other user-generated content
• investigate reports, complaints, fraud, abuse, or misuse
• send service notifications and important account communications
• maintain platform security
• detect and prevent unauthorised access and harmful activity
• improve the performance, usability, and functionality of Dwella
• understand how people use the platform
• maintain the integrity and reliability of Dwella's review system
• comply with legal and regulatory obligations
• establish, exercise, or defend legal rights
• protect users, Dwella, and other persons where necessary

Dwella will not use personal information for purposes that are incompatible with the purposes for which it was collected unless permitted or required by applicable law.

4. Reviews and Public Information

Dwella is a community platform, and some information submitted by users is intended to be publicly visible.

When a review is published, information that may be displayed publicly includes:

• the reviewer's chosen full name or initials
• the review
• ratings provided as part of the review
• the property associated with the review
• relevant information about the reviewer's property experience
• the applicable review verification status

Dwella does not provide anonymous reviews.

Users should not include unnecessary personal, confidential, or sensitive information about themselves or other people in publicly visible reviews.

Dwella may moderate, redact, restrict, or remove personal information from publicly displayed content where appropriate or where required by applicable law.

5. Verification Documents

Dwella may request a utility bill when a user chooses to submit a verified review.

Verification documents are used to:

• assess whether the document supports the claimed residential property connection
• determine whether the review qualifies for verified status
• reduce fraudulent or misleading reviews
• protect the integrity of the Dwella review system

Verification documents are not displayed publicly.

Access to verification documents is restricted to authorised personnel or systems that require access for verification, security, legal, or related legitimate purposes.

Verification documents are subject to stricter access controls than ordinary account and review information because of the personal information they may contain.

Dwella retains verification documents only for as long as reasonably necessary to complete the verification process and address legitimate questions or disputes concerning the verification decision. Subject to applicable legal or dispute-related requirements, verification documents are deleted or anonymised no later than 90 days after the verification decision.

Users should only submit documents they are legally entitled to provide and should avoid submitting information that is unrelated to verification.

6. Legal Bases for Processing

Dwella processes personal information only where there is a lawful basis for doing so under applicable Nigerian data-protection law.

Depending on the processing activity, Dwella may rely on:

• performance of a contract or taking steps at your request before entering into a contract
• compliance with a legal obligation
• your consent
• legitimate interests pursued by Dwella or another party, where those interests are not overridden by your rights and freedoms
• protection of vital interests where applicable
• another lawful basis recognised under applicable law

The applicable lawful basis depends on the particular processing activity.

Where Dwella relies on consent, you may withdraw your consent at any time by contacting hello@dwella.com.ng. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

7. Cookies and Similar Technologies

Dwella may use cookies and similar technologies to support:

• essential platform functionality
• authentication and security
• preferences
• performance and diagnostics
• analytics where applicable

Essential technologies may be necessary for the platform to function properly.

Where applicable law requires consent for non-essential cookies or similar technologies, Dwella will obtain that consent before using them.

You may also control certain cookies through your browser settings.

8. How We Share Information

Dwella may share personal information where reasonably necessary to operate the platform, provide services, protect users and Dwella, or comply with applicable law.

This may include sharing information with:

• hosting and infrastructure providers
• authentication providers
• storage providers
• security and technical service providers
• communications and email service providers
• analytics providers where applicable
• professional advisers
• regulators, courts, law-enforcement authorities, or other public bodies where legally required or permitted
• service providers or other parties involved in protecting Dwella's rights, users, systems, or property

Where a third party processes personal information on Dwella's behalf, Dwella takes reasonable steps to require appropriate privacy, confidentiality, and security protections and data-processing arrangements where required by law.

Dwella does not sell users' personal information.

9. User-Generated Content

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

Users are responsible for considering what information they include in content that may become publicly visible.

Dwella may moderate, restrict, redact, or remove content where it contains unnecessary personal information, violates Dwella's Community Guidelines, creates a privacy or safety concern, or otherwise requires action under applicable law.

Every review is subject to Dwella's moderation process before publication.

10. Data Security

Dwella implements reasonable technical and organisational measures designed to protect personal information against unauthorised access, disclosure, loss, misuse, alteration, or destruction.

Security measures are applied in proportion to the nature and sensitivity of the information involved. Verification documents, for example, are subject to stricter access controls than ordinary publicly available review information.

No internet-based service can guarantee absolute security.

If Dwella becomes aware of a personal-data breach, it will assess the breach and take appropriate steps required under applicable law, including notifying the Nigeria Data Protection Commission within the applicable statutory timeframe where the breach meets the relevant notification threshold.

Where required, Dwella will also notify affected individuals without undue delay and provide appropriate information about the incident and steps they may take to protect themselves.

Dwella maintains appropriate records of personal-data security incidents and the actions taken to address them.

11. Data Retention

Dwella retains personal information only for as long as reasonably necessary for the purpose for which it was collected, unless a longer retention period is required or permitted by applicable law.

Our retention practices include:

• Account information: retained while your account is active and deleted or anonymised following account deletion, subject to legal, security, fraud-prevention, or dispute-related retention requirements.
• Reviews and ratings: may be retained as part of Dwella's public review record where reasonably necessary for the operation and integrity of the platform, subject to applicable data-protection rights and legal requirements.
• Verification documents: deleted or anonymised no later than 90 days after the verification decision, unless longer retention is required for an active dispute or legal obligation.
• Technical and security logs: may be retained for up to 12 months where reasonably necessary for security, fraud prevention, troubleshooting, or investigation.
• Communications, reports, and complaints: may be retained for up to 24 months where reasonably necessary for investigation, resolution, accountability, security, or legal purposes.

When personal information is no longer required and there is no lawful reason to retain it, Dwella will securely delete, anonymise, or otherwise dispose of it.

12. Your Data-Protection Rights

Subject to applicable law and relevant exceptions, you may have rights concerning 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
• exercise applicable rights relating to automated decision-making or profiling
• lodge a complaint with the Nigeria Data Protection Commission

These rights are subject to the conditions and exceptions provided by applicable law.

A request to delete information does not automatically require Dwella to remove information where Dwella has a lawful basis or legal obligation to retain or continue processing it.

13. How to Exercise Your Rights

To exercise a data-protection right or make a privacy request, contact:

hello@dwella.com.ng

Dwella may request information necessary to verify your identity before responding to certain requests.

Dwella will handle valid requests within the timeframes required by applicable law.

If Dwella cannot fulfil a request, it will explain the reason where required by law.

14. Children's Privacy

Dwella is not directed at children.

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

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

15. International Data Transfers

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

Where personal information is transferred outside Nigeria, Dwella will take steps required under applicable Nigerian data-protection law to ensure that the transfer is lawful and that appropriate safeguards are in place.

Depending on the circumstances, these safeguards may include contractual protections, an adequate level of protection recognised under applicable law, or another lawful transfer mechanism.

16. Third-Party Services

Dwella uses third-party providers to support functions such as:

• authentication
• hosting and infrastructure
• database and storage services
• security
• email and communications
• notifications
• analytics and technical services where applicable

These providers may process personal information on Dwella's behalf.

Dwella takes reasonable steps to select providers that provide appropriate privacy and security protections and enters into appropriate data-processing arrangements where required.

Third-party services may have their own privacy policies and terms. Users should review those policies where relevant.

17. Privacy by Design and Data Minimisation

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

Privacy and security considerations are incorporated into the design and development of Dwella's features, particularly where personal information is collected, displayed publicly, or used for verification.

As Dwella develops, its privacy practices will be reviewed and updated to reflect new features, technologies, risks, and applicable legal or regulatory requirements.

18. Changes to This Privacy Policy

Dwella may update this Privacy Policy from time to time.

Where a change is material, Dwella will provide reasonable notice through the platform or another appropriate communication method where required.

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

19. Privacy Questions and Complaints

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

Privacy contact: hello@dwella.com.ng

Dwella will review privacy concerns and take reasonable steps to address them.

If you are not satisfied with how your concern has been handled, you may lodge a complaint with the Nigeria Data Protection Commission (NDPC).

20. Governing Law

This Privacy Policy is governed by applicable Nigerian data-protection and privacy law, including the Nigeria Data Protection Act 2023 and applicable regulations, directives, guidance, and other requirements issued by the Nigeria Data Protection Commission.

Nothing in this Privacy Policy is intended to remove, exclude, or restrict any right or protection that cannot lawfully be removed, excluded, or restricted.