Privacy Policy

Homxe ("Homxe," "we," "us," or "our") operates the Homxe mobile application and the website at homxe.com (together, the "Service"), a platform for property listing, rental, management, and related payments. This Privacy Policy explains what personal data we collect, why we collect it, the legal basis for processing it, how it is shared, how long we keep it, and the rights available to you under applicable law, including the Nigeria Data Protection Act 2023 ("NDPA") and, where relevant, the EU/UK General Data Protection Regulation ("GDPR").

By using the Service, you confirm that you have read this Policy. Where we rely on your consent as the legal basis for a specific type of processing, you may withdraw that consent at any time, as described in Section 8.

1. Who We Are

Homxe is the data controller responsible for personal data collected through the Service. Our contact details, and those of our data protection contact, are set out in Section 12.

2. Information We Collect

• Account information: name, email address, phone number, and password when you register.
• Identity verification (KYC) information: to comply with financial regulations and enable wallet features, we collect identity documents (such as a government-issued ID) and related verification details. This is processed on our behalf by our identity verification partner, Dojah.
• Property data: listing details, photos, pricing, and location for properties you list or search for.
• Location data: with your permission, your device location, to support property search and mapping features via Google Maps.
• Wallet and payment information: Homxe's digital wallet is powered by our banking-as-a-service partner, Anchor. When you fund your wallet, make payments, or receive funds, transaction details (amounts, timestamps, wallet balance, and linked bank account information) are processed and held by Anchor on our behalf. We do not store full bank account or card numbers on our own servers.
• Communications: messages and calls sent through Homxe's in-app messaging between tenants, owners, and agents.
• Device and usage information: device identifiers, app usage patterns, and crash/performance data, collected automatically.

3. Legal Basis for Processing

• Performance of a contract: to create your account, list or search properties, process payments, and provide the core Service you signed up for.
• Consent: for location access, marketing communications, and any processing where we ask for your explicit permission. You may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.
• Legal obligation: for identity verification (KYC) and financial record-keeping required under Nigerian financial and anti-money-laundering regulations.
• Legitimate interests: for fraud prevention, service security, and improving app performance, balanced against your right to privacy.

4. How We Use Your Information

• To create and manage your account
• To display, match, and search property listings
• To verify identity and process wallet transactions and rental payments
• To enable messaging and calls between users
• To provide location-based property search
• To send service-related notifications
• To detect and prevent fraud, and maintain service security
• To improve app performance and fix issues
• To comply with legal and regulatory obligations

5. How We Share Your Information

We do not sell your personal data. We share it only with:

• Service providers acting on our behalf: our backend infrastructure provider (Supabase), mapping provider (Google Maps), wallet and payment infrastructure provider (Anchor), and identity verification provider (Dojah) — each under contractual obligations to protect your data and use it only for the purposes we specify.
• Other users: relevant property and contact details are shared with users you choose to interact with (for example, a tenant contacting a property owner).
• Regulators and legal authorities: where required by law, court order, or to protect the rights, safety, or property of Homxe, our users, or the public.
• Business transfers: if Homxe is involved in a merger, acquisition, or asset sale, your data may be transferred as part of that transaction, subject to this Policy or a policy offering equivalent protection.

6. International Data Transfers

Some of our service providers (including Supabase, Google Maps, Anchor, and Dojah) may process or store data outside Nigeria. Where this happens, we take reasonable steps to ensure an adequate level of protection is applied, consistent with NDPA requirements and, where applicable, GDPR safeguards such as standard contractual clauses.

7. Data Retention

We retain personal data for as long as your account is active or as needed to provide the Service, comply with legal and regulatory obligations (including financial record-keeping requirements), resolve disputes, and enforce our agreements. When data is no longer needed, we securely delete or anonymize it.

8. Your Rights

Subject to applicable law, you have the right to:

• Access: the personal data we hold about you.
• Correct: inaccurate or incomplete data.
• Delete: your data, subject to legal and legitimate business retention needs.
• Restrict or object to: certain processing.
• Data portability: where technically feasible.
• Withdraw consent: at any time, where processing is based on consent.
• Lodge a complaint: with the Nigeria Data Protection Commission (NDPC), or, where GDPR applies to you, your local supervisory authority.

To exercise any of these rights, contact us using the details in Section 12. We will respond within the timeframe required by applicable law.

9. Data Security

We use reasonable administrative, technical, and physical safeguards, including encryption in transit and access controls, to protect your information. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

10. Data Breach Notification

In the event of a data breach that poses a risk to your rights and freedoms, we will notify the NDPC (and affected users, where required) within the timeframe required under the NDPA, and will notify any applicable supervisory authority and affected individuals as required under GDPR where relevant.

11. Children's Privacy

Homxe is not directed at, and is not intended for use by, individuals under 18 years of age. We do not knowingly collect personal data from children. If we become aware that we have inadvertently collected such data, we will delete it promptly.

12. Contact Us

For questions about this Privacy Policy, or to exercise your data protection rights, contact us at:

Email: support@homxe.com

13. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. Material changes will be indicated by updating the "Last updated" date above, and, where required by law, we will provide additional notice.