Data Privacy Policy

1. Introduction & Scope

Fhemfel Group (“Fhemfel Group”, “we”, “us”, or “our”) is committed to protecting the personal data and privacy of our customers, employees, business partners, users, visitors, and other individuals whose data we process.

This Privacy Policy explains how we collect, use, store, protect, and share personal data when you use our website, applications, digital platforms, products, and services.

This Policy applies to all Fhemfel Group services, including the Fhemfel Homes customer mobile app and the staff/agent mobile app for Android and iOS, as well as our websites and other digital platforms.

Our website is https://fhemfelgroup.com

This Policy is designed to comply with the Nigeria Data Protection Act, 2023 (NDPA) and other applicable Nigerian data protection requirements.

2. Personal Data We Collect

Depending on your relationship with Fhemfel Group, we may collect:

• Full name
• Email address
• Telephone number
• Residential or contact address
• Account and registration details
• Identification or verification information where required
• Transaction and service information
• Communications and enquiries
• Device and browser information
• IP address
• Website access dates and times
• Referring websites or pages
• Other information reasonably necessary to provide our services

We collect only data that is adequate, relevant, and necessary for the purpose for which it is processed.

3. Location Data

Subject to our Users' authorization and where essential for our operations, we may obtain geographical information through your hardware, web clients, software applications, or data shared with us.

This information may encompass:

• High-accuracy coordinates, including satellite-based positioning
• Regional context, such as municipality or administrative territory
• Physical residential or site-specific addresses
• Geographical details linked to fulfillments, business visits, or formal queries
• Approximate location derived from network protocols

Processing of such data is conducted to:

• Deliver and facilitate area-specific solutions
• Locate proximal assets, corporate centers, or operational zones
• Administer and execute organizational taskings
• Confirm address validity or structural locations
• Enhance platform integrity and mitigate fraudulent risks
• Evaluate distribution patterns and platform engagement
• Forward pertinent updates, guidance, or corporate messaging
• Observe statutory mandates or oversight regulations

Strict geographical tracking is limited to necessary service functions where consent has been granted or another valid legal ground is identified. Users retain the ability to restrict these features through system preferences, though this may constrain certain functionalities.

Where location features are used, positioning and address look-ups may be provided through your device’s location services and mapping providers such as Google Maps Platform, which are subject to their own terms and privacy notices.

We process only such data as is proportionate, pertinent, and required for the stated processing objectives.

4. How We Collect Personal Data

We may collect personal data:

• Directly from you when you register, complete forms, request services, make transactions, or contact us.
• Automatically when you use our website or digital services, including technical and usage information.

5. Why We Process Personal Data

We may use personal data to:

• Provide and manage our products and services
• Create and manage accounts
• Process transactions and payments
• Communicate with customers and users
• Respond to enquiries, complaints, and requests
• Provide customer support
• Manage employees, vendors, contractors, and business relationships
• Improve our website, applications, and services
• Maintain system security and prevent fraud or unauthorised activity
• Perform administrative and operational activities
• Meet legal and regulatory obligations
• Conduct necessary analytics and reporting

We will not use personal data for incompatible purposes unless permitted or authorised by law.

6. Lawful Basis for Processing

Fhemfel Group processes personal data only where a lawful basis exists under applicable data protection law.

Depending on the circumstances, this may include:

• Consent: Where you have provided consent for a specific purpose. You may withdraw consent where applicable.
• Contract: Where processing is necessary to enter into or perform a contract.
• Legal Obligation: Where processing is required to comply with applicable laws or regulations.
• Legitimate Interests: Where processing is necessary for legitimate interests and does not override your rights and freedoms.
• Other Lawful Bases: Where recognised under applicable Nigerian data protection law.

7. Data Protection Principles

Fhemfel Group is committed to processing personal data in accordance with the following principles:

• Lawfulness, fairness and transparency – Data is processed lawfully and transparently.
• Purpose limitation – Data is collected for specific and legitimate purposes.
• Data minimisation – Only necessary data is collected and processed.
• Accuracy – Reasonable steps are taken to keep data accurate and up to date.
• Storage limitation – Data is retained only as long as necessary unless legally required.
• Security – Appropriate technical and organisational measures are used to protect personal data.

8. Sharing and Disclosure

We may share personal data where necessary and lawful with:

• Authorised employees and personnel
• Service and technology providers
• Professional advisers
• Business partners
• Financial and payment service providers
• Government or regulatory authorities where legally required
• Other parties where you have authorised the disclosure or where permitted by law

We limit access to personal data to what is reasonably necessary for the relevant purpose and require appropriate safeguards where third parties process data on our behalf.

9. Data Security and Retention

We take reasonable measures to protect personal data against unauthorised access, loss, misuse, alteration, or destruction.

These measures may include:

• Encryption
• Firewalls
• Secure servers
• Access controls
• Authentication
• Role-based access
• Security monitoring
• Backup and recovery measures

We retain personal data only for as long as necessary to fulfil the purpose for which it was collected, meet contractual or operational requirements, comply with legal obligations, or fulfil other lawful purposes.

When data is no longer required, we may securely delete, anonymise, or otherwise dispose of it.

10. Your Data Protection Rights

Subject to applicable legal limitations, you may have the right to:

• Be informed about how your personal data is processed
• Access the personal data we hold about you
• Request correction of inaccurate or incomplete data
• Object to certain processing
• Request restriction of processing in certain circumstances
• Receive or transfer your data where applicable
• Request deletion or erasure of your data where legally permitted
• Withdraw consent where processing is based on consent
• Request appropriate human intervention in applicable automated decision-making

These rights may be subject to legal, contractual, regulatory, or other lawful limitations.

11. Account and Data Deletion

You can permanently delete your account and associated personal data at any time directly within our mobile apps. In the Fhemfel Homes customer app or the staff/agent app, go to Profile → Delete account, confirm with your password, and your account and associated personal data will be permanently deleted.

If you are unable to access the app, you may request account and data deletion by emailing info@fhemfelgroup.com with the subject line “Account Deletion”. We will verify your identity and process verified requests within 30 days.

Some information may be retained after deletion where we are required to do so by law or for legitimate purposes such as completed financial transaction records, fraud prevention, and dispute resolution. Retained data is kept only for as long as necessary and is then securely deleted or anonymised.

12. Exercising Your Rights & Complaints

To exercise your data protection rights or raise a privacy concern, contact us using the details provided below.

Your request should, where possible, include your name, contact information, the nature of your request, and information that will help us identify the relevant data.

We may verify your identity before processing certain requests and will respond within the timeframe required by applicable law.

If you are not satisfied with our response, you may contact the Nigeria Data Protection Commission (NDPC) or another competent supervisory authority where applicable.

13. Third-Party Websites and Services

Our website or digital platforms may contain links to third-party websites, applications, or services.

Fhemfel Group is not responsible for the privacy practices, content, or security of independent third parties. Users should review the privacy policies of such third parties before providing personal data.

14. Children’s Data

Our services and mobile applications are intended for individuals aged 18 and above and are not directed to children. We do not knowingly collect personal data from children. If we become aware that we have collected personal data from a child without appropriate consent, we will take reasonable steps to delete it. If you believe a child has provided us with personal data, please contact us at info@fhemfelgroup.com .

15. Changes to This Policy

We may update this Privacy Policy to reflect changes in our services, processing activities, technology, applicable laws, or regulatory requirements.

The updated Policy will be published on our website with a revised “Last Updated” date. Where changes are material, we may provide additional notice where required or appropriate.

16. Contact Information

For questions, requests, complaints, or concerns regarding this Privacy Policy or the processing of your personal data:

Fhemfel Group

Email: info@fhemfelgroup.com

Address: House 4, 14 Road off First Avenue, Gwarimpa, Nigeria

Website: https://fhemfelgroup.com

Fhemfel Group is committed to responsible, transparent, secure, and accountable processing of personal data in accordance with applicable Nigerian data protection requirements.