HOWSEY Privacy Policy

1. Introduction

HOWSEY (“HOWSEY”, “we”, “our” or “us”) provides a property management software platform that helps property owners, landlords, property managers and property management companies manage properties, buildings, units, tenants, rental records, payments, maintenance requests, communications and related administrative activities.

We recognise that information entrusted to us must be handled responsibly. This Privacy Policy explains how personal information is collected, used, stored, disclosed and protected when you visit our website, create an account, access a company workspace or use the HOWSEY platform.

This policy applies to:

• Visitors to the HOWSEY website.
• Company administrators.
• Landlords and property managers.
• Employees and other authorised company users.
• Tenants who access a company-specific portal.
• Individuals whose information is entered into HOWSEY by an authorised customer.

Our privacy practices are intended to comply with applicable data protection laws, including the Nigeria Data Protection Act 2023 and applicable regulations and directives.

2. Who Is Responsible for Your Personal Data?

For this policy, the relevant data controller or data processor depends on the activity being performed.

2.1 HOWSEY as a data controller

HOWSEY may act as a data controller when determining the purposes and means of processing information relating to:

• Website visitors.
• Company registration and account administration.
• Account security and authentication.
• Customer support and enquiries.
• Platform security and service administration.
• Our own legal and regulatory obligations.

2.2 HOWSEY as a data processor

A property management company or other customer using HOWSEY may determine why tenant, landlord, employee and property-related personal information is collected and how it is used.

Where HOWSEY processes that information on behalf of the customer and according to its instructions, HOWSEY generally acts as a data processor.

In those circumstances, the relevant customer is ordinarily responsible for determining the lawful purpose of the processing, providing appropriate privacy notices and responding to data subjects, subject to the applicable law and the parties’ contractual arrangements.

HOWSEY will handle such information in accordance with applicable law and its agreement with the customer.

3. Information We May Collect

The information collected depends on how you interact with HOWSEY and the permissions associated with your account.

3.1 Account and registration information

When a company or authorised user registers, we may collect:

• Full name.
• Email address.
• Telephone number, where provided.
• Company or organisation name.
• Business contact information.
• Login credentials in securely managed form.
• Account and registration details.

3.2 Property and tenancy information

Depending on the customer’s use of the platform, information entered may include:

• Tenant names and contact details.
• Property addresses.
• Building and unit information.
• Tenancy commencement and expiry dates.
• Rental amounts and payment schedules.
• Lease and rental agreement records.
• Maintenance requests.
• Communications and administrative notes.

3.3 Financial and payment records

HOWSEY may store financial records entered or generated through the platform, including:

• Rent obligations.
• Recorded payments.
• Payment dates and amounts.
• Payment references.
• Payment claims and verification records.
• Payment account information supplied by a customer.
• Receipts and financial statements.
• Outstanding balances and expense records.

The availability of payment recording functionality does not mean that HOWSEY itself processes or holds funds. Online payment processing and third-party payment integrations are subject to their actual activation and separate terms.

Do not submit complete card numbers, PINs, passwords or other highly sensitive payment credentials in ordinary forms or notes.

3.4 Technical and usage information

When you access the platform, technical information may be processed, such as:

• IP address.
• Browser type.
• Device and operating system information.
• Access timestamps.
• Authentication and session events.
• Security logs.
• Pages and functions accessed.
• Error and diagnostic information.

The exact information collected depends on the platform configuration and hosting environment.

3.5 Communications

If you contact us or communicate through the platform, we may process the information contained in those communications, including your name, contact details, enquiry and related correspondence.

4. How We Use Personal Information

Subject to applicable law and the relevant lawful basis, information may be processed to:

1. Create and administer company workspaces.
2. Authenticate users and manage account access.
3. Provide property-management functionality.
4. Maintain property, unit and tenancy records.
5. Record rent obligations and payment information.
6. Generate receipts, statements and reports.
7. Manage maintenance requests.
8. Facilitate authorised communications.
9. Send service-related notifications.
10. Protect accounts and investigate suspected misuse.
11. Maintain system reliability and troubleshoot technical issues.
12. Respond to customer support enquiries.
13. Comply with applicable legal obligations.
14. Establish, exercise or defend legal claims where necessary.

We do not intend to use personal information for purposes incompatible with the purpose for which it was collected without an appropriate lawful basis.

5. Lawful Bases for Processing

Where HOWSEY acts as a data controller, processing will be based on an applicable lawful basis recognised under Nigerian data protection law.

Depending on the activity, this may include:

• Contractual necessity: To provide requested services or take steps at your request before entering into a contract.
• Legal obligation: To comply with applicable legal or regulatory requirements.
• Legitimate interests: To maintain platform security, prevent misuse, administer services and protect legitimate business interests, where those interests are not overridden by your rights.
• Consent: Where consent is legally required or is the appropriate basis for a particular activity.

Where a company customer acts as the controller of tenant or employee information, that customer is responsible for identifying and documenting the appropriate lawful basis for its processing.

Where processing relies on consent, consent may be withdrawn, subject to applicable legal requirements and the consequences of withdrawal.

6. How We Share Personal Information

We do not sell personal information as a business model.

Information may be shared in the following circumstances:

6.1 With the relevant company workspace

Information entered into a company’s workspace may be accessible to authorised administrators, property managers, staff members or other users according to the company’s configuration and permissions.

Tenants should understand that their property management company may access relevant tenancy, rent, payment and maintenance records.

6.2 With service providers

We may use service providers to support the operation of HOWSEY, including providers of:

• Website and application hosting.
• Cloud or file storage.
• Email delivery.
• Security and infrastructure services.
• Technical maintenance.
• Backup services.

These providers may process information only as necessary to perform their services, subject to applicable contractual and legal safeguards.

The actual providers and their processing locations should be disclosed where required.

6.3 For legal and security reasons

We may disclose information where reasonably necessary to:

• Comply with applicable law.
• Respond to lawful requests from competent authorities.
• Protect users and the public.
• Investigate suspected fraud or security incidents.
• Establish, exercise or defend legal claims.

6.4 Business transfers

If HOWSEY is involved in a merger, acquisition, restructuring or transfer of business assets, relevant information may be transferred subject to appropriate confidentiality and legal safeguards.

7. International Data Transfers

Our hosting or service providers may process information in locations outside Nigeria.

Where personal data is transferred outside Nigeria, we will take steps required by applicable data protection law, including assessing the transfer conditions and implementing appropriate safeguards where necessary.

Information about relevant processing locations and transfer safeguards may be requested through our privacy contact.

8. Data Retention

We retain personal information only for as long as reasonably necessary for the purpose for which it was collected, subject to applicable legal obligations and legitimate business requirements.

Retention periods may depend on:

• The status of an account.
• The nature of the information.
• Contractual requirements.
• Financial and accounting obligations.
• Legal claims or disputes.
• Security and audit requirements.
• Backup and disaster recovery cycles.

When information is no longer required, we will take appropriate steps to delete, anonymise or securely dispose of it, subject to applicable law.

Where a company customer controls tenant information stored within its workspace, that customer should determine and communicate appropriate retention instructions to HOWSEY in accordance with the applicable service agreement.

9. Data Security

We use appropriate technical and organisational measures intended to protect information against unauthorised access, alteration, disclosure, loss or destruction.

Depending on the relevant system and service configuration, these measures may include:

• Authentication and access controls.
• Role-based permissions.
• Company workspace separation.
• Secure transmission using HTTPS where enabled.
• System monitoring and security logging.
• Restricted administrative access.
• Backup and recovery procedures.
• Software maintenance and security updates.

No internet-based service can guarantee absolute security. Users should protect their credentials, avoid sharing accounts and report suspected unauthorised access promptly.

10. Data Breaches and Security Incidents

Where a personal data breach occurs, we will assess the incident and take appropriate steps in accordance with applicable law.

This may include:

• Investigating the incident.
• Containing and mitigating its effects.
• Preserving relevant evidence.
• Notifying affected customers or individuals where required.
• Reporting to the appropriate regulatory authority where legally required.
• Implementing corrective measures.

Where HOWSEY acts as a processor, we will notify the relevant customer in accordance with applicable legal requirements and our contractual arrangements.

11. Your Privacy Rights

Subject to applicable law, individuals may have rights including:

• The right to be informed about processing.
• The right to request access to their personal information.
• The right to request correction of inaccurate or incomplete information.
• The right to request deletion in appropriate circumstances.
• The right to request restriction of processing.
• The right to object to certain processing.
• The right to data portability where applicable.
• The right to withdraw consent where consent is the lawful basis.
• The right to lodge a complaint with the relevant supervisory authority.

Some rights are subject to legal exceptions and limitations.

How to exercise your rights

If your information is held within a property management company’s workspace, you should ordinarily contact that company first because it may be the controller responsible for the information.

For information controlled directly by HOWSEY, contact:

We may request reasonable information to verify your identity and understand your request before responding.

You may also have the right to lodge a complaint with the Nigeria Data Protection Commission.

12. Cookies and Similar Technologies

HOWSEY may use cookies or similar technologies necessary for website operation, authentication, security and user preferences.

Where optional analytics or marketing technologies are introduced, they should be disclosed and managed in accordance with applicable law and appropriate consent requirements.

You can manage cookie preferences through available browser settings and any consent controls provided on our website.

Disabling essential cookies may affect the availability of certain platform functions.

13. Third-Party Websites and Services

The HOWSEY website or platform may contain links to external websites or services.

We do not control the privacy practices of independent third parties. You should review their respective privacy notices before providing personal information to them.

14. Children’s Information

HOWSEY is designed primarily for property management businesses and their authorised users.

We do not knowingly seek to collect children’s personal information unnecessarily. Where a property-management customer enters information relating to a minor, the customer must ensure that the collection and processing are lawful and subject to appropriate safeguards.

Please contact us if you believe personal information has been submitted unlawfully.

15. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes in our services, technology, business operations or legal requirements.

Where changes are material, we will take reasonable steps to communicate them through the website, platform or another appropriate channel.

The latest version will be published at:

https://howsey.site/privacy

16. Contact Us

For questions, complaints or requests concerning this Privacy Policy, contact: