1.1   This Privacy Policy describes how Housing101 Proptech Solutions Limited ("Housing101", "we", "us", "our") collects, uses, discloses, retains, and protects personal data of Users of the eFRINO platform ("Platform"). It applies to Tenants, Landlords, Principal Agents, and any other person whose personal data we process in connection with the Platform.

1.2   This Policy is issued in compliance with the Nigeria Data Protection Act 2023 ("NDPA") and the regulations and guidance issued by the Nigeria Data Protection Commission ("NDPC").

Housing101 Proptech Solutions Limited is the Data Controller. Registered office: 5 Fameshe Kehinde Street, Ilasan, Lekki, Lagos State. RC 8597579. Data Protection Officer: [email protected].

3.1   Identity data

Legal name, date of birth, gender, photo identification, BVN, NIN, contact telephone, email address, residential address, and signature.

3.2   Financial data

Bank account details, payment card information tokenised through licensed payment processors, transaction history on the Platform, income and employment information for Tenants, property ownership and valuation information for Landlords, and Caution Deposit balances and settlement records.

3.3   Verification data

Credit reports, KYC results, employment confirmation letters, payslips, bank statement analysis, prior tenancy history for Tenants, property documentation for Landlords, and agency licensing and power of attorney documentation for Principal Agents.

3.4   Usage data

App and website interactions, search queries, listings viewed, applications made, messages sent through the Platform, dispute submissions, and customer service interactions.

3.5   Device and technical data

Device identifiers, operating system, IP address, app version, network information, and language and timezone settings.

3.6   Location data

Geolocation data with explicit User permission, used only for property search and listing features.

3.7   Property content

Photographs, descriptions, pricing, and other content uploaded by Landlords or Principal Agents in connection with listings.

3.8   Execution and audit data

Where a tenancy agreement is executed on the Platform, we record the signature applied by each party, the identity verification method used, one-time password verification, the signing timestamp, the originating IP address and device identifier, and a cryptographic hash of the executed document. This data evidences valid execution and is retained as set out in Section 10.

• Directly from you when you sign up, complete your profile, list a Property, apply for a tenancy, send a message, contact support, or otherwise use the Platform.
• From third parties who help us verify your identity and assess credit, including FirstCentral Credit Bureau Limited, QoreID, VerifyMe, Mono, and similar licensed providers.
• From other Users, for example a Landlord receiving a Tenant’s verification summary during an application.
• Automatically as you interact with the Platform, through cookies, log files, and analytics technologies.

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

• Consent, where you have provided clear, affirmative consent for a specific purpose.
• Contract performance, where processing is necessary to deliver the platform services you have engaged us to provide, including the assessment of tenancy applications, Default Recovery Infrastructure as the consideration for flexible payment cadences, and Caution Deposit administration through the Trustee.
• Legal obligation, where processing is required by Nigerian law, including credit reporting obligations, anti-money-laundering rules, trustee-related regulatory obligations, and tax reporting.
• Legitimate interest, where processing is necessary for our legitimate interests in operating the Platform, preventing fraud, and improving our services, balanced against your rights.
• Public interest or vital interest, in narrowly defined circumstances such as responding to legitimate regulator requests or court orders.

• Identity, employment, affordability, and credit verification of Users.
• Matching Tenants with Properties, enabling Landlords to assess tenancy applications, and facilitating tenancy execution.
• Rent collection, Caution Deposit administration through the Trustee, and dispute resolution.
• Default Recovery Infrastructure, being credit bureau reporting and employer notification on sustained default.
• Insurance enrolment and administration, including tenant insurance funded by Housing101 for the first twelve months and any optional renewal elected by the Tenant, term life insurance on monthly Tenants, and third-party liability insurance funded by Housing101 on qualifying Properties.
• Customer service, in-app messaging, and User support.
• Fraud detection, security monitoring, and Platform integrity.
• Compliance with applicable laws, regulator requests, and court orders.
• Marketing and Platform improvement, where consent or legitimate interest applies.

7.1   We share personal data only as necessary for the purposes described in this Policy and only with parties bound by appropriate contractual or legal protections.

7.2   Categories of recipients

• Other Users. Tenants and Landlords share verified identity and contact information with each other during the tenancy execution process. Disclosure of a Tenant’s verification summary to a Landlord assessing an application is governed by Section 8.
• The Trustee. STL Trustees Limited, as trustee for the Tenant Caution Escrow Fund, receives Tenant identity, tenancy details, Caution Deposit balances and movements, dispute records, and Housing101 settlement instructions. Its processing is governed by the Trust Deed and subject to its own NDPA and SEC compliance obligations.
• Credit bureaus. FirstCentral and other licensed Nigerian credit bureaus, for both inbound verification and outbound reporting.
• Payment processors. Monnify, Paystack, and other licensed Nigerian payment infrastructure providers.
• Verification and KYC partners. QoreID, VerifyMe, Mono, and similar providers operating under data processor agreements.
• Insurance partners. Licensed Nigerian insurers, for the administration of insurance products.
• Tenants’ employers of record, in cases of sustained default, factual notification only.
• Regulators and authorities, including the NDPC, NAICOM, SEC, CBN, FIRS, courts, and law enforcement, where legally required.
• Professional advisers, including legal counsel and auditors, bound by confidentiality obligations.
• Successors, in the event of corporate transactions, subject to equivalent privacy protections.

7.3   We do not sell personal data.

8.1   When a Tenant applies for a tenancy, the Landlord for that Property, and any Principal Agent instructed on that Property, is given access to a verification summary for that Tenant. The purpose is to allow the Landlord to make an informed decision on the application.

8.2   What is disclosed

The verification summary comprises:

• The Tenant’s legal name and contact details.
• Identity verification status, being confirmation that identity has been verified through BVN or NIN, without disclosing the identifier itself.
• Employment verification status, and the employer of record.
• An affordability assessment, being the outcome of comparing the Tenant’s verified income against the rent for the Property, expressed as an affordability outcome or band.
• A credit standing outcome derived from the credit bureau check, expressed as an outcome or band.
• Prior tenancy conduct on the Platform, where the Tenant has held a tenancy through eFRINO.

8.3   What is not disclosed

The following are never disclosed to a Landlord or Principal Agent:

• The underlying credit report or its contents.
• Payslips, bank statements, or the raw output of bank statement analysis.
• BVN, NIN, or any government identification number.
• Bank account details or payment card information.
• The Tenant’s search activity, other applications, or messages with other Users.
• Any special category data.

8.4   Purpose limitation

The verification summary is disclosed for the sole purpose of assessing that specific application for that specific Property. It may not be used for any other purpose.

8.5   Restrictions on the Landlord

A Landlord or Principal Agent granted access to a verification summary shall not:

• Use the data for any purpose other than deciding the application to which it relates.
• Copy, export, photograph, screenshot, download, or otherwise remove the data from the Platform.
• Disclose the data to any third party, except to a professional adviser bound by confidentiality where necessary to decide the application.
• Retain the data after the application has been decided, other than the record retained within the Platform.
• Use the data for marketing, profiling, or building any list or database.
• Use the data to make a decision on any ground that is unlawful or discriminatory under Nigerian law.

8.6   Access

A verification summary is made available to a Landlord only where the Tenant has submitted an application for that Property, and is presented within the Platform. Every access to a verification summary is logged.

8.7   Transparency to the Tenant

This Policy constitutes notice to Tenants of the categories of information disclosed to a Landlord under this Section, and of the purpose for which they are disclosed. A Tenant who wishes to know what has been disclosed in relation to a particular application, including which Landlords have accessed their verification summary, may exercise the right of access at Section 11.

8.8   Lawful basis

Disclosure under this Section is made on the basis of contract performance, being necessary to deliver the tenancy application service the Tenant has engaged us to provide, and on the basis of the legitimate interest of the Landlord in assessing the suitability of an applicant for their Property, balanced against the Tenant’s rights through the minimisation and purpose limitation set out above.

8.9   Status and consequences of misuse

A Landlord or Principal Agent who receives a verification summary acts as an independent Data Controller in respect of their own decision, and is bound by the restrictions in this Section as a term of their use of the Platform. Misuse is a material breach of the Terms and Conditions and may result in suspension or termination of the account, in addition to any liability the Landlord or Principal Agent may incur under the NDPA in their own right.

Personal data is primarily processed within Nigeria. Where data is transferred outside Nigeria, we ensure appropriate safeguards are in place, including standard contractual clauses, adequate-jurisdiction transfers, or other mechanisms approved by the NDPC.

• Active account data is retained while your account is open.
• After account closure, transaction records, tenancy agreements, payment records, Caution Deposit settlement records, and dispute logs are retained for a minimum of seven (7) years.
• Execution and audit data under Section 3.8, including signatures, verification records and document hashes, is retained for seven (7) years from the end of the tenancy.
• Logs of Landlord access to Tenant verification summaries under Section 8 are retained for seven (7) years.
• Trust Fund records held by the Trustee are retained per its regulatory retention obligations under SEC rules.
• Credit bureau submissions are retained as required by FirstCentral and Nigerian credit reporting regulations.
• Marketing data, where based on consent, is retained until consent is withdrawn or for a maximum of three (3) years from your last interaction.
• Audit logs of consent events, dispute review decisions, and Caution Deposit settlements are retained for a minimum of seven (7) years.

Under the NDPA, you have the following rights:

• Right of access.
• Right of correction.
• Right of erasure, subject to legal and regulatory retention.
• Right of portability.
• Right to object to certain processing.
• Right to withdraw consent, where processing is based on consent.
• Right to lodge a complaint with us at [email protected] or with the NDPC.

Requests are responded to within thirty (30) days unless an extension is justified.

12.1   Tenants authorise Housing101’s Default Recovery Infrastructure as a unified mandatory consent at signup. This authorisation is granted on the basis of contract performance under NDPA Section 25(c).

12.2   Default Recovery Infrastructure includes credit bureau reporting and employer notification, both mandatory under the unified authorisation, with bounded scope and procedural protections.

12.3   Bounded scope of employer notification: factual default notification only, no credit reports or financial details, sent only to the employer of record after the notice protocol and thirty (30) day cure period, with twenty-four (24) hours’ advance notice to the Tenant.

12.4   Tenants on monthly tenancies further acknowledge that Housing101 maintains a term life insurance policy on the Tenant’s life with Housing101 as beneficiary, funded from Housing101 operating revenue.

13.1   Caution Deposit balances are held in trust by STL Trustees Limited. Housing101 shares with the Trustee the personal data necessary to administer the Trust Fund, including Tenant identity, tenancy details, Caution Deposit balances and movements, dispute records, and settlement instructions.

13.2   The Trustee processes such data as a separate Data Controller subject to its own NDPA registration and SEC compliance obligations. The relationship between Housing101 and the Trustee on data matters is governed by a Data Sharing Agreement forming part of the Trust Deed.

13.3   The Trustee’s second-level review of disputed Caution Deposit decisions requires access to dispute records, supporting evidence, and Housing101’s reasoning. This processing is necessary for the performance of the trust arrangement and is on the contract performance basis.

• Landlords authorise Housing101 to verify property ownership through public records and approved third-party providers.
• Property listing content uploaded by Landlords is published on the Platform and may be visible to all Platform Users.
• Landlords are responsible for ensuring property content does not include personal data of third parties without lawful basis.
• Landlords who receive Tenant verification summaries are bound by Section 8, and are responsible for their own compliance with the NDPA in respect of any decision they make using that data.
• Third-party liability insurance funded by Housing101 on a Landlord’s qualifying Property is administered with licensed Nigerian insurers, and the Landlord is the named beneficiary on the policy.

• Principal Agents authorise Housing101 to verify their agency authority through the power of attorney or exclusive instruction documentation provided.
• Where Principal Agents process Landlord and Tenant data on the Platform on behalf of represented Landlords, they do so within the scope of agency and subject to NDPA obligations.
• Principal Agents granted access to Tenant verification summaries are bound by Section 8 on the same terms as Landlords.

The Platform uses cookies and similar technologies for authentication, security, performance analytics, and, where you consent, personalisation and marketing. You can manage cookie preferences through your device or app settings. The full Cookie Notice is available at housing101.ng/cookies.

The Platform is not intended for use by anyone under eighteen (18) years of age. We do not knowingly collect personal data from minors.

• We implement appropriate technical and organisational measures to protect personal data, including encryption in transit and at rest, role-based access controls, audit logging, and regular security reviews.
• In the event of a personal data breach likely to result in risk to Users, we will notify the NDPC within seventy-two (72) hours of becoming aware of the breach and notify affected Users without undue delay.

We may update this Privacy Policy from time to time. Material changes will be notified to Users through the Platform and by email, with affirmative re-consent required where new lawful bases or new processing activities are introduced.

Questions, requests, or complaints may be directed to the Data Protection Officer at [email protected], or by post to the Data Protection Officer, Housing101 Proptech Solutions Limited, 5 Fameshe Kehinde Street, Ilasan, Lekki, Lagos State, Nigeria.

General platform enquiries may be directed to [email protected].

You may also lodge a complaint with the Nigeria Data Protection Commission at any time. Details at ndpc.gov.ng.

Read our Terms & Conditions  |  Read our Per-Listing Agreement