11. INTRODUCTION
Eden ("Eden", "we", "us", "our" or "the Company") is a technology platform designed to facilitate property discovery, property listings, communication between property owners/landlords and prospective tenants, identity verification, payments, escrow protection, and other related property services.
This Privacy Policy explains how Eden collects, uses, stores, protects, discloses, and otherwise processes personal data when you download, register for, access, or use the Eden mobile application, website, or related services (collectively, the "Services").
Eden is committed to protecting the privacy and personal-data rights of its users and intends to process personal data in accordance with the Nigeria Data Protection Act 2023 (NDP Act), applicable regulations, directives and guidance issued by the Nigeria Data Protection Commission (NDPC), and other applicable laws of the Federal Republic of Nigeria.
The NDP Act establishes the NDPC as Nigeria's data-protection authority and applies to organizations operating in Nigeria and to processing of personal data relating to individuals in Nigeria.
22. OUR DATA-PROTECTION PRINCIPLES
Eden will process personal data according to the statutory principles applicable under the Nigeria Data Protection Act (NDP Act). These include:
Personal data will be processed fairly, lawfully, and transparently.
Data will be collected solely for specified, explicit, and legitimate purposes.
Eden collects information that is adequate, relevant, and reasonably necessary.
Reasonable steps are taken to ensure personal data is accurate and kept up to date.
Personal data will not be retained longer than reasonably necessary.
Appropriate technical and organizational measures are used to protect data.
Eden maintains appropriate policies, procedures, and records to demonstrate compliance.
33. PERSONAL DATA WE COLLECT
3.1 Identity Information
We may collect:
- First name, middle name & surname
- Date of birth & gender
- Telephone number & email address
- Residential & contact address
- State & Local Government Area (LGA)
- Profile photograph / biometric selfie
- National Identification Number (NIN)
- Government-issued ID documents
- Identity-verification compliance status
Eden may require users to provide their National Identification Number (NIN) or information derived from a lawful NIN-verification process to prevent and tackle fraudulent acts and enhance transparency.
Zero-Public Display: Eden will apply data minimization and will NOT publicly display a user's NIN on a profile, property listing, search result, chat, or public section. NIN information is accessible only to authorized personnel or licensed verification providers with a legitimate lawful purpose.
44. PROPERTY AND LANDLORD INFORMATION
If you list or manage a property through Eden, we collect:
Property address, location (State/LGA), property category (Residential/Commercial/Land), rent price, caution/security deposit, agency fee percentage, property description, number of bedrooms/bathrooms/toilets, amenities, photographs, video tours, ownership proof / title authorization, and transaction settlement records.
Users must not upload another person's personal information or property documentation without lawful authority.
55. TENANT INFORMATION
Where you use Eden as a prospective tenant or renter, we process:
Full name, verified phone number, employment status, employer name, monthly income range, next of kin contact information, move-in preferences, digital tenancy agreement signatures, and rental application messages.
66. PAYMENT AND FINANCIAL INFORMATION
Eden processes transaction references, payment status, transaction amounts (in Nigerian Naira ₦ with exact 2 decimal digits), rent escrow deposits, Eden 5% platform service fees, ₦1,000 flat escrow protection fees, caution security deposits, and Paystack payout transfer codes.
Payment Card Security: All card details are securely tokenized and handled directly by our PCI-DSS certified payment partner (Paystack). Eden does not store raw credit/debit card numbers or CVV codes on its servers.
77. COMMUNICATIONS AND USER CONTENT
Eden collects customer-support messages, complaint requests, ratings, reviews, dispute submissions, and uploaded repair photographs. Communications are retained for resolving disputes, system optimization, and user safety. Eden does not monitor private communications for unrelated commercial marketing.
88. PURPOSES FOR PROCESSING PERSONAL DATA
Eden processes personal data to:
- Create and manage user accounts for Tenants, Landlords, Agents, and Technical Artisans;
- Authenticate identity and prevent property fraud, impersonation, or fake listings;
- Facilitate property searches, tenancy agreements, inspection bookings, and escrow payments;
- Provide dedicated customer support and enforce 48-hour inspection countdown windows;
- Maintain platform security, detect unauthorized access, and prevent financial leakage;
- Comply with Nigerian statutory obligations and respond to lawful regulatory requests under the NDP Act.
99. LAWFUL BASIS FOR PROCESSING
Under Section 25 of the Nigeria Data Protection Act 2023, Eden processes personal data under the lawful bases of Consent, Contractual Performance (servicing lease agreements and escrow settlements), Legal Obligation (taxation and anti-fraud regulations), and Legitimate Interests (securing system integrity).
1010. SHARING OF PERSONAL DATA
Eden does not sell your personal data. We share data only with:
- Transaction Counterparties: Connecting prospective tenants with verified landlords upon approved applications;
- Accredited Service Providers: Identity verification partners, Paystack payment processing, and SMS/push notification gateways;
- Law Enforcement & Regulators: When legally compelled under Nigerian law or court order to prevent financial crime.
1111. THIRD-PARTY DATA PROCESSORS
All third-party processors engaged by Eden operate under strict written data-processing agreements ensuring technical and organizational security standards compliant with NDPC requirements.
1212. DATA SECURITY & STORAGE
Eden employs enterprise-grade cryptographic controls including TLS 1.3 encryption in transit, AES-256 encryption at rest, Row Level Security (RLS) policies, immutable financial double-entry ledgers, and strict role-based access control for administrative staff.
1313. DATA BREACHES & INCIDENT MANAGEMENT
In the event of a confirmed personal data breach likely to result in a risk to rights and freedoms, Eden will notify the Nigeria Data Protection Commission (NDPC) within 72 hours and inform affected data subjects without undue delay as required by the NDP Act 2023.
1414. DATA RETENTION POLICY
Personal data is retained only for the duration necessary to deliver the Services, satisfy financial audit requirements, and resolve tenancy escrow disputes. When no longer required, data is securely erased or anonymized.
1515. DATA SUBJECT RIGHTS
Under Nigerian data-protection law, you possess the right to:
1616. HOW TO EXERCISE YOUR RIGHTS
To submit a formal data subject request, email our Data Protection Desk at: edenhelpdesk@shalomdatatech.com
1717. CHILDREN AND MINORS
Eden Services are intended solely for individuals of legal age (18 years and above). We do not knowingly collect personal data from minors.
1818. MARKETING, COOKIES & ANALYTICS
Users can opt out of promotional messages at any time. Essential service, security, and escrow notification messages cannot be disabled as they are required for transaction fulfillment.
1919. ACCOUNT DELETION
Users may request complete account deletion directly in the Eden Mobile App under Profile > Account Settings > Delete Account or by contacting support. Records tied to active financial escrow contracts or tax compliance will be archived securely in accordance with Nigerian law.
Web deletion channel: You can also request account and data deletion without the app by emailing support@shalomdatatech.com with the subject line "Account Deletion" from the email or phone number registered to your Eden account. We verify your identity and complete verified deletion requests within 30 days, and we confirm completion by email or SMS. Deletion removes your profile, listings, applications, and personal data; transaction and escrow records required by law are retained in anonymised form only.
2020. DATA PROTECTION GOVERNANCE
Eden maintains internal data protection officers (DPO), privacy impact assessments, and rigorous security audit frameworks to ensure all user information is protected.
2121. DATA PROTECTION IMPACT ASSESSMENT (DPIA)
Eden conducts periodic Data Protection Impact Assessments for biometric verification modules and payment gateway workflows to identify and mitigate privacy risks proactively.
2222. CHANGES TO THIS PRIVACY POLICY
Material revisions to this Privacy Policy will be notified through the mobile application, website banners, or email. The date of the latest update is always reflected at the top of this notice.
2323. COMPLAINTS & REGULATORY RIGHTS
If you believe your personal data has been handled contrary to the NDP Act 2023, you may contact our privacy team or submit a complaint directly to the Nigeria Data Protection Commission (NDPC) at ndpc.gov.ng .
2424. CONTACT INFORMATION & CORPORATE REGISTRY
Shalom Datatech Ltd (Eden)
CAC Registration Number: 9394286