This notice is intended to reflect the Nigeria Data Protection Act, 2023 (the "NDPA") and applicable guidance issued by the Nigeria Data Protection Commission (the "NDPC"). It is not a substitute for advice from a Nigerian privacy lawyer. Royaldome should confirm its registered address, privacy contact, data protection officer arrangements, vendor contracts, retention schedule, and NDPC registration obligations before production launch.
1. Who we are and who this notice covers
Verified Close ("Verified Close", "we", "us", or "our") provides a transaction verification service for real estate agents, agencies, developers, and prospective buyers, primarily through a web dashboard and WhatsApp.
This notice applies when you visit our public pages, create or use an account, respond to a tracked property link, interact with our WhatsApp flow, or otherwise provide information to Verified Close. An agency or developer may also have its own privacy notice. If that organisation decides why and how your information is used, it may be the data controller for that processing and Royaldome may act as its processor.
2. Information we collect and how we receive it
Depending on how you use the service, we may collect:
- Account information: your name, email address, phone number, password credentials, role, agency, and profile details.
- Property and transaction information: listing details, property photos, buyer enquiries, qualification answers, viewing or confirmation events, and commission-related records.
- Messages: messages and responses sent through a Verified Close WhatsApp flow, where needed to operate the service and maintain an accurate event record.
- Technical information: IP address, browser and device information, approximate usage data, referring page, timestamps, and security logs.
- Cookies and similar technology: essential session, authentication, preference, and security information. We will request consent before using non-essential analytics or marketing cookies where required.
- Information you provide about others: only where you have a lawful basis and permission to share it, such as a buyer or team member's contact details.
We receive information directly from you, from the agency or agent that invites or refers you, from your use of a tracked link or WhatsApp, and from service providers that help us secure and operate the platform. We do not intentionally collect biometric data, precise location data, or sensitive personal data unless it is necessary, lawful, and separately addressed. Please do not send such information through a listing or message unless the service asks for it.
3. Purposes and lawful bases
We use information to:
- create and secure accounts and provide the service;
- track property links, enquiries, qualifications, and confirmations;
- maintain tamper-evident records of relevant transaction events;
- communicate service messages, invitations, and account notices;
- improve reliability, prevent misuse, and protect the platform; and
- meet legal, regulatory, accounting, or dispute-resolution obligations.
Under the NDPA, our lawful basis may be performance of a contract, taking steps at your request before a contract, compliance with a legal obligation, your consent, or our legitimate interests where those interests do not override your rights. We will tell you when information is required and what may happen if you do not provide it. You may withdraw consent at any time, but withdrawal does not affect processing already carried out lawfully before withdrawal.
4. Direct marketing and communications
We send transactional communications needed to create accounts, deliver invitations, respond to enquiries, provide security alerts, and operate a transaction record. We will only send optional marketing where we have a lawful basis and any consent required by applicable Nigerian law. You can opt out of marketing at any time using the unsubscribe option or by contacting us. Opting out does not stop essential service notices.
5. Roles, sharing, and recipients
We do not sell personal information. We may share information with the agency, agent, developer, or buyer involved in a relevant transaction; with service providers that host, secure, message, or support the platform; when required by law or a valid legal process; or when needed to protect users, Royaldome, or the public. We require service providers to handle information only for agreed purposes and with appropriate safeguards.
- Account owners: an agency or developer may access information submitted within its workspace and may determine the purposes for which it is used.
- Transaction participants: relevant agents, buyers, agencies, and developers may see information needed to coordinate an enquiry or verify an introduction.
- Processors: hosting, database, authentication, messaging, email, image-storage, maps, security, and support vendors that process information on our documented instructions.
- Authorities and advisers: regulators, law enforcement, courts, auditors, insurers, and professional advisers where disclosure is lawful and necessary.
We may also disclose information as part of a merger, financing, restructuring, or sale of assets, subject to confidentiality and lawful safeguards. We do not permit vendors to use your information for their own unrelated advertising.
6. WhatsApp, cookies, and external services
If you use a WhatsApp-based flow, your interaction also passes through WhatsApp and may be subject to Meta's terms and privacy practices. We use hosting, authentication, storage, messaging, and analytics providers as needed to operate Verified Close. Those providers may process data in countries other than Nigeria, subject to appropriate contractual or technical safeguards.
Essential cookies support login, security, routing, and preferences. Optional cookies may measure page performance or remember marketing preferences. You can manage cookies through your browser and any preference controls we provide. Blocking essential cookies may prevent some features from working. Links to other websites are governed by those websites' own notices.
7. International transfers
Some suppliers may process information outside Nigeria. Before making a cross-border transfer, we will use a lawful transfer mechanism and appropriate safeguards required by the NDPA, including an adequacy decision where applicable, contractual protections, or another lawful basis. You may request general information about relevant safeguards through the privacy contact below, subject to confidentiality and security limitations.
8. Retention and deletion
We retain information only for as long as necessary for the purpose collected, including account administration, transaction integrity, dispute resolution, fraud prevention, tax and accounting records, legal claims, and regulatory obligations. When information is no longer needed, we delete it, anonymise it, or securely isolate it unless a lawful reason requires further retention. An append-only event record may remain in a limited form where deletion would undermine an active dispute or legal obligation; we will restrict its use where appropriate.
9. Security and data breach response
We use risk-appropriate technical and organisational measures including access controls, least-privilege permissions, encrypted connections, backups, monitoring, and staff or vendor confidentiality obligations. Security is a shared responsibility: use a strong unique password, keep devices secure, and report suspected unauthorised access promptly.
We maintain procedures to identify, contain, investigate, remediate, and document personal-data breaches. Where a breach presents a risk to your rights and freedoms, we will make notifications to the NDPC and affected people as required by the NDPA and applicable NDPC guidance, within the applicable statutory or regulatory timeframes.
10. Your rights under the NDPA
Subject to the NDPA and other applicable law, you may request to be informed, access your data, correct inaccurate data, object to or restrict processing, receive portable data, request erasure, withdraw consent, and not be subject to a decision based solely on automated processing that produces legal or similarly significant effects. You may also complain to the NDPC. We will verify your identity, respond within the period required by law, and explain any lawful reason we cannot fulfil a request. We do not currently use solely automated decisions to determine legal or similarly significant outcomes.
To exercise a right, email privacy@vclose.ng with "Data subject request" in the subject line, or use the support channel in your account. You may also contact the NDPC through its official contact page if you are dissatisfied with our response.
11. Children and vulnerable people
Verified Close is intended for adults working in or engaging with real estate transactions. We do not knowingly collect children's data. If you believe a child has provided information, notify us so we can assess and remove it where appropriate. Users must not pressure or manipulate a person into providing information.
12. Changes to this policy
We may update this policy when the service, law, or our data practices change. We will post the updated version on this page and revise the date above. Material changes may also be communicated through the service.
13. Complaints and contact
Royaldome Investment Limited is the organisation responsible for this notice. For privacy questions, requests, or complaints, contact privacy@vclose.ng or use the support channel in your account. We aim to acknowledge requests promptly and investigate complaints fairly. Nothing in this notice limits your right to complain to the NDPC or seek another remedy available under Nigerian law.