PRIVACY POLICY

Introduction:

This privacy policy applies generally to the business of Broll Nigeria, including offline and online interactions you have with us and the personal data that we hold about you.
 
Persons accessing the Broll Nigeria web site, subject themselves to and agree to Broll Nigeria’s privacy policy, as set out below. 
 
Broll Property Services respects your privacy and is committed to keeping your information confidential.

Broll Nigeria is a controller and processor for the Personal data that it collects and uses about you. We respect your privacy and we are committed to ensuring that your information is kept confidential in accordance with applicable data protection legislation. Our use of your personal data will be governed by this Privacy policy.

This Privacy Policy describes your privacy rights regarding our collection, use, storage, sharing and protection of your Personal data. We may amend this Privacy Policy at any time by posting a revised version on our website.

Generally, you can visit our Web Site without having to divulge any Personal data about yourself. However, while using this Web Site you may provide information about yourself. Any and all information provided at this site will be kept strictly confidential and will not be sold, loaned, reused or otherwise disclosed to any organization.

We will only disclose or report Personal data if and when required to do so by law or any regulatory authority and to our employees who require such information to carry out their duties.

This Privacy policy explains;
  • What Personal data is
  • The types of Personal data we collect
  • How we collect your personal data
  • The legal basis for processing your Personal data
  • How your Personal data is kept secure
  • How long we keep your Personal data
  • Your rights in relation to your Personal data
  • Transferring your personal data outside Nigeria
  • How we use your personal data and the purpose for which it is collected
  • Who we share your personal data with

What is Personal data

Personal data is any information that can be used in identifying a natural individual. This could include information such as name, contact details such as telephone number, date of birth, address or any information about your needs or circumstances which would allow us to identify you.
Your Personal data is used as is appropriate in the normal course of our business with you to provide the products and services you have requested. With your consent, we will only retain any information for purposes of ongoing business relationships or to communicate directly with you.

The types of Personal data we collect

We may sometimes collect your name and contact details (such as phone number and email address) from you whenever you contact us to enable us to provide our services. Depending on the service that we provide to you (or on your behalf) we may also collect additional Personal data as detailed below;

Buy, Sell, Let, Rent
a) If you are selling or letting a property through us;
  • We will collect a contact telephone number to get in touch with you about organizing viewings and updating you on any offers received or rental applications for your property.
  • Where you are not the legal owner of the property we will request details from you as to your ability to sell or let the property such as a Power of Attorney.
b) If you wish to purchase a property we are listing for sale, we will collect Personal data relating to any specific requirements you may have in relation to a property so that we can find a property that is suitable for your needs. We will also collect Personal data required to source a property for you and, where required, negotiate the purchase of a property on your behalf.

Facilities Management
c) Where we are managing property on your behalf we may need to pass your Personal data on to third party contractors whom we have engaged to carry out maintenance on your properties.

Regulatory compliance
d) To comply with certain regulatory requirements, we will collect information required to identify you to meet anti-money laundering and counter terrorist financing requirements. We will collect information relating to your identity, which will include at least one form of photographic identification (such as a passport, a driving licence or an identification card) and one form of documentation with proof of your place of residence (such as a recent utility bill).

e) If you are an entity such as a company, trust or charity, we may need to collect Personal data about the controllers and the beneficiaries of the entity.

Other
f) If you subscribe to receive research, news or other market updates from us, then in addition to the above we will collect details such as email address and the type of content that you would like to receive.
 
g) We collect personal details such as images and video recordings through CCTV where you are present in our facilities and in facilities we manage for our clients.
 
h) We maintain a list of e-mail addresses to which Broll Nigeria Newsletter is sent. Individuals must affirmatively request to join this list by using the subscribe form on the subscriptions page. Any members of this list may choose to unsubscribe at any time by using the same form. Our list server has been configured in such a way that the e-mail addresses can only be accessed by authorized Broll Nigeria staff. We will only record your e-mail address if you send us a message. It will only be used for the purpose for which you provide it and will not be added to a mailing list unless you request that this be done. We will not disclose it without your consent.
 
i) We may also collect the following:
  • Account or profile information when you connect with us on our social media platforms;
  • Other publicly available personal data, including any which you have shared via a public platform (such as a LinkedIn, Twitter feed or public Facebook page);
  • Job application personal data when you apply for any of our vacancies advertised including contact details, work history, employment needs and interests and anything relevant to the job for which you are applying; and
  • Information about your computer, including where available your IP address, operating system and browser type. This is statistical data about our users' browsing actions and patterns, and does not identify any individual.
Our website is not intended for children and we do not knowingly collect data relating to children.

How we collect your personal data

We use different methods to collect data from and about you. Our legal channels of information collection are itemized below:


1. Direct interactions: We collect your data through direct provision of data in the course of your use of our services with your consent. We collect information about your use of our website and services through our analytics tracking system in order to carry out our legitimate interests in monitoring and improving our website and services.

You may give us your data by filling in forms or by corresponding with us by post, phone, email or otherwise.


​2. Use of technology and automated interactions: We collect your data through direct provision of data in the course of your use of our services with your consent. As you interact with our website, we will automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.

Cookies are small files placed on your computer’s hard drive that enables the website to identify your computer as you view different pages. Cookies allow websites and applications to store your preferences in order to present contents, options or functions that are specific to you. Like most interactive websites, our website uses cookies to enable the tracking of your activity for the duration of a session. Our website uses only encrypted session cookies which are erased either after a predefined timeout period or once the user logs out of the platform and closes the browser. Session cookies do not collect information from the user’s computer. They will typically store information in the form of a session identification that does not personally identify the user.

We may collect your personal data such as recorded images from technology we use in our offices and facilities we manage, such as security cameras (CCTV) and visitor management systems. We operate cameras for security and operational purposes.

3. Third Parties: We may also receive your personal data from third parties to whom you have legally provided such information to, and we may use such information in accordance with our policies.
To the extent that such data is disclosed by third parties, whether our clients, service providers, advertisers or other sites throughout the Internet, different rules may apply to their use or disclosure of your information. We do not control how they use or share your data and we cannot make any representations or warranties as to these.

Web pages on our website may contain cookies or related technology to support your experience and enable our systems to recognize your browser or device. These cookies are text files placed in your computer's internet browser to store your preferences.


The legal basis for processing your personal data

Under data protection legislation we are only permitted to use your Personal data if we have a legal basis for doing so. We rely on the following legal bases to use your information;
  • Where we have received consent from you
  • Where we need information to perform the contract we have entered into with you
  • Where we need to comply with a legal obligation
  • Where we need to protect your interests (or someone else's interests); and/or
  • Where it is needed in the public interest or for official purposes
We may process special categories of Personal data and criminal conviction information in the following limited circumstances:
  • With your explicit consent, in which case we will explain the purpose for which the information will be used at the point where we ask for your consent.

What constitutes consent

  • Consent of the data subject means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
  • You have the right to withdraw your consent at any time.

How we keep your information secure

The security of information is very important to us and we have measures in place (physical, technical and administrative security measures) which are designed to reduce the risk of loss, misuse, disclosure and unauthorized access of your Personal data including but not limited to:
  • Use of firewalls and data encryption.
  • Storage of files on our secure systems. Access is restricted on our client systems to those within the business who are required to have access to your information.
  • Hard copy documentation is stored in locked cabinets.

We ensure access to Personal data is restricted to Broll employees and workers or other persons working within the Broll Group on a need to know basis. Training on data protection is provided to any of those Broll employees and workers who need access to Personal data.

How long we keep your Personal data

Whenever we collect or process your personal data, we’ll only keep it for as long as is necessary for the purpose for which it was collected. At the end of the necessary period, we will either delete your data completely or anonymize your data so that it can be used in a non-identifiable way for statistical analysis and business planning. You may request information on whether your data has been deleted or anonymized.
 
In some cases, we may hold your data longer where we have statutory or regulatory obligations to retain Personal data for a longer period, or where we may need to retain the information in case of a legal claim.


Your rights in relation to your Personal data

You have a number of rights in relation to your Personal data, these include the right to:

  • Be informed about how we use your Personal data.
  • Obtain access to your Personal data that we hold.
  • Request that your Personal data is corrected if you believe it is incorrect, incomplete or inaccurate.
  • Request that we erase your Personal data in the following circumstances:
    • If Broll is continuing to process Personal data beyond the period when it is necessary to do so for the purpose for which it was originally collected.
    • If Broll is relying on consent as the legal basis for processing and you withdraw consent.
    • If the Personal data has been processed unlawfully (i.e. in breach of the requirements of the data protection legislation).
    • If it is necessary to delete the Personal data to comply with a legal obligation.
  • Ask us to restrict our data processing activities where you consider that:
    • Personal data is inaccurate.
    • Our processing of your Personal data is unlawful.
    • Where we no longer need the Personal data but you require us to keep it to enable you to establish, exercise or defend a legal claim.
    • Where you have raised an objection to our use of your Personal data.
  • Request a copy of certain Personal data that you have provided to us in a commonly used electronic format. This right relates to Personal data that you have provided to us that we need in order to perform our agreement with you and Personal data where we are relying on consent to process your Personal data.
  • to be informed of wholly automated decision-making, the logic behind it and the resultant effect it could have on you.
If you would like to exercise any of your rights you may submit your request via our Subject Access Request form saved on our website and sending the form to eabebe@broll.com.ng.
Upon a request made, we will provide you with details of the Personal data we hold about you. Should you believe that any information we hold about you is incorrect, please inform us at the above email address and we will correct it.
 
Please note that we will keep a record of the fact that you have made a request to exercise your rights, and our response to your request, in order to demonstrate compliance with our data protection obligations and so that we can handle any queries, complaints or claims in relation to your request. This record will be kept in accordance with our retention policies as explained above.


Please note that, while all attempts are made to secure information transmitted to this Web Site, if you are submitting personal details or other information over the Internet which you wish to remain private, there is a possibility that information you submit could be observed by a third party while in transit.

Transferring your personal data outside of Nigeria:

We store and process your Personal data on our computers in Nigeria however we may sometimes share your personal data with our parent company based in South Africa via our online software over the course of our operational activities in providing our services to you. We may also share your personal data with affiliated entities located in other countries where it is necessary for the provision of our services to you. Where we need to transfer your data to another country, we will always ensure that such country must have an adequate data protection law.

How we use your personal data

With your consent, we use your personal data to fulfil requests to receive information or materials from us, to carry out services for your benefit and to process applications and requests from you.
Specifically, we use your personal information for the purposes of fulfilling our obligations to you to let or sell your property or, if you are a buyer or tenant, for the purposes of arranging a contract for sale or a lease for you.
 
We do not use your information for any other purpose than for the purposes listed out in this privacy policy and we do not sell, lend or rent any personal information about you to any third parties outside of Broll Nigeria.

How we share your personal data

We may share your personal data in the following ways:
  • With Governmental bodies, regulators, law enforcement agencies, courts/tribunals and insurers, where we are required to do so
  • In order to comply with our regulatory and legal obligations;
  • In order to exercise our legal rights (for example in court cases);
  • In order to do so for the prevention, detection, investigation of crime or prosecution of offenders;
  • For the protection of our employees and customers; and
  • In the case of employees, with any companies or third parties responsible for payment of salary, employee benefits or where we have a legal duty to do so.
  • With third party contractors whom we have engaged to carry out maintenance on your properties.
  • If you are purchasing a property for which we are acting as agents, or for the sale of a property through us, we will share your personal information with your appointed solicitors and the solicitors acting for the other side of the deal as is necessary to facilitate the sale or purchase.
  • Where we are managing property on your behalf we may need to pass your personal information from time to time on to third party contractors whom we have engaged to carry out maintenance on your properties.
  • If we sell any part of our business and/or integrate it with another organisation your details may be disclosed to our advisers and to prospective purchasers or joint venture partners and their advisers. If this occurs the new owners of the business will only be permitted to use your information in the same or similar way as set out in this privacy policy.
Where we share your information, we will ensure to communicate our data protection policy to the party receiving your information and endeavour to inform them of their obligations with respect to your information. We cannot, however, be responsible for how they use your information and we disclaim any liabilities for their use of your information.
 
We will never share our customer data to other organizations for their own marketing purposes.

Governing law

This Privacy Policy is made pursuant to the Nigeria Data Protection Regulation (2019) and other relevant Nigerian laws, regulations or international conventions applicable to Nigeria. Where any provision of this Policy is deemed inconsistent with a law, regulation or convention, such provision shall be subject to the overriding law, regulation or convention.

You can exercise the above rights by contacting us using the contact details set out below:
Email us at eabebe@broll.com.ng
Telephone us on +234 1 270 1892
Should you wish to obtain any further information please contact us using the details above.