VaseCrib Privacy Policy

VASECRIB PRIVACY POLICY
1. INTRODUCTION AND SCOPE
This Privacy Policy explains how VaseCrib ("VaseCrib," "we," "us," or "our") collects, uses, protects, and shares personal information when you use the VaseCrib platform ("Platform"), whether as a Seeker or a Lister. This Policy is prepared with reference to the Nigeria Data Protection Act 2023 and applicable guidance issued by the Nigeria Data Protection Commission. By using the Platform, you acknowledge that your information will be handled as described in this Policy.

2. INFORMATION WE COLLECT
2.1 At registration, we collect the following from every user: full name, phone number, email address, date of birth, and gender.

2.2 If you register as a Lister, we additionally require a current photograph of you.

2.3 You create your own password at registration. Your password is encrypted and is not accessible to VaseCrib, including our own staff.

2.4 We do not currently collect your National Identification Number, Bank Verification Number, or any government-issued identification document. If this changes in future, it will be disclosed to you at the time of collection, and your consent will be sought where required by law.

2.5 We do not collect or store your card details or full bank account information directly. Where you make a Rent Payment, this information is provided directly to, and processed by, our designated payment partner, in accordance with their own privacy and security practices.

3. LEGAL BASIS FOR PROCESSING YOUR INFORMATION
We process your personal information on the following legal bases:
(a) Contractual necessity, to create and operate your account, enable Listings, and facilitate Rent Payments;

(b) Your consent, where you have specifically provided it, including for optional features such as requesting an Inspection Service; and

(c) Legal obligation, where processing is required to comply with an applicable law or a lawful request from a regulatory authority.

4. HOW WE USE YOUR INFORMATION
We use the information described in Clause 2 to create and manage your account, display and manage Listings, process and hold Rent Payments in Escrow, notify you of activity
relevant to your account, respond to Flags and Disputes, communicate with you about the Platform, and comply with our legal obligations.

5. WHAT INFORMATION IS VISIBLE TO OTHER USERS
5.1 If you register as a Lister, your name and photograph are visible on the Listings you create, so that Seekers can identify who they are dealing with. Your phone number becomes visible
to a Seeker once they view the full details of your Listing, to allow them to contact you.

5.2 If you register as a Seeker, your name, phone number, date of birth, and gender are not publicly visible to other users or to the general public. This information becomes visible only to the
specific Lister with whom you initiate a transaction, so that they can identify who has paid for their property.

5.3 We do not display your information to any user beyond what is described in this Clause 5.

6. DATA SHARING WITH THIRD PARTIES
6.1 We share the minimum information necessary with our designated payment partner to process and hold Rent Payments in Escrow, and to facilitate payout to Listers. Our payment partner is a licensed financial service provider and processes this information under its own regulatory
obligations.

6.2 We do not sell your personal information to any third party. We do not share your information with any other third party except where required by law, to enforce our Terms of Service,
or to protect the safety of our users.

7. DATA SECURITY
We apply reasonable technical and organisational measures to protect your information, including encryption of your password. No system is completely secure, and while we work to protect your information, we cannot guarantee absolute security.

8. DATA RETENTION
We retain your personal information for as long as your account remains active, and for a reasonable period afterward as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Where you request deletion of your account, we will delete or anonymise your
information except where retention is required by law.

9. YOUR RIGHTS
Under the Nigeria Data Protection Act 2023, you have the right to:
(a) Access the personal information we hold about you;

(b) Request correction of inaccurate or incomplete information; and

(c) Request deletion of your information, subject to any legal obligation requiring us to retain it. To exercise any of these rights, contact us through the details published on the Platform.

10. CHANGES TO THIS POLICY
We may update this Policy as our services evolve. Where a new use of your information requires it under Nigerian law, we will notify you and seek your fresh consent before that new use begins. Material changes will otherwise be communicated to you through the Platform or by email.

11. CONTACT
Questions about this Policy, or requests relating to your personal information, may be directed to us through the contact details published on the Platform.