Privacy Policy

1. Data Controller

TitleShield Governance Platform Limited is the data controller for personal data processed through this website (titleshield.ng) and through the platform (app.titleshield.ng). RC: [PLACEHOLDER: CAC Registration Number]. Registered address: [PLACEHOLDER: Abuja, FCT, Nigeria].

Mary Kolo Consulting (MKC) and Maryland Real Estate Services & Facilities Management Company Ltd (Maryland RSFM) are separate data controllers for data they process directly in connection with their respective services. Sharing of personal data between entities is governed by Data Processing Agreements and disclosed in this policy.

2. What Personal Data We Collect

Community registration

• Full name, email address, phone number
• Country of residence
• Interest type (investor / property owner / both)
• Estimated capacity (optional)
• Referral source
• Consent status for marketing communications

Contact form submissions

• Name, email address, subject, message content

Property owner submissions

• Name, email, phone, property details, document readiness information

Platform accounts (app.titleshield.ng)

• Identity documents (passport, national ID)
• Address verification documents
• Source of funds declaration
• Bank account details for distributions
• Transaction history on the platform

Website usage

We do not use Google Analytics, Facebook Pixel, or any tracking cookies. We collect no analytics data without your explicit consent. Server logs may capture IP addresses for security purposes only — these are not used for profiling.

3. How We Use Your Data

• To process community registrations and send relevant communications
• To respond to enquiries submitted via contact forms
• To conduct KYC, AML, and SCUML screening for platform accounts
• To process co-owner registrations and SPV documentation
• To send platform notifications, distribution statements, and governance reports
• To send educational content (only where consent is given)
• To comply with legal obligations under NDPA 2023, SCUML requirements, and CAMA 2020
• To detect and prevent fraud and money laundering

4. Legal Basis for Processing

• Consent: Marketing communications, educational content (withdraw at any time)
• Contract performance: Processing necessary to perform co-ownership agreements and SPV operations
• Legal obligation: KYC/AML/SCUML compliance, tax reporting, regulatory requirements
• Legitimate interest: Platform security, fraud prevention, system administration

5. Data Sharing

We share personal data with the following parties:

• Mary Kolo Consulting (MKC): For due diligence verification purposes
• Maryland Real Estate Services & Facilities Management Company Ltd (Maryland RSFM): For property management where co-owners' properties are managed
• Brevo (email service provider): For processing community and marketing emails
• Nigerian regulatory bodies: SCUML, NDPC, SEC Nigeria, CAC — as legally required
• Legal and professional advisers: Under confidentiality obligations

We do not sell, rent, or transfer your personal data to third parties for marketing purposes. Ever.

6. Data Retention

• Community data: retained until platform launch, then for the duration of your account
• Contact form data: 24 months
• KYC documentation: 5 years from account closure (regulatory requirement)
• SPV and transaction records: 7 years (CAMA 2020 / tax requirements)
• Marketing consent records: until consent is withdrawn

7. Your Rights

Under NDPA 2023, you have the following rights:

• Right of access: Request a copy of personal data we hold about you
• Right to rectification: Correct inaccurate or incomplete data
• Right to erasure: Request deletion (subject to legal retention obligations)
• Right to restriction: Restrict processing in certain circumstances
• Right to data portability: Receive your data in a structured, machine-readable format
• Right to object: Object to processing based on legitimate interest
• Right to withdraw consent: For marketing communications, at any time

To exercise any of these rights, email: privacy@titleshield.ng. We will respond within 30 days.

8. Data Security

We implement appropriate technical and organisational measures to protect your personal data, including: HTTPS encryption for all data in transit; encrypted storage for sensitive data; role-based access controls; regular security assessments; and incident response procedures. In the event of a data breach that is likely to affect your rights, we will notify you and the NDPC within the timeframes required by law.

9. Cookie Policy

TitleShield uses only strictly necessary cookies — session cookies that are required for the website to function. We do not use:

• Analytics cookies (no Google Analytics, no Plausible, no Matomo)
• Advertising or retargeting cookies
• Third-party social media cookies
• Persistent user-tracking cookies

Strictly necessary cookies are set automatically and cannot be disabled without breaking core website functionality. They expire when you close your browser session, or within 24 hours.

This privacy-first approach is part of TitleShield's commitment to NDPA 2023 compliance and to our co-owners' data protection rights.

10. Contact the Data Protection Officer

For any data protection enquiries, to exercise your rights, or to make a complaint:

Data Protection Officer
TitleShield Governance Platform Limited
Email: privacy@titleshield.ng
[PLACEHOLDER: Postal address, Abuja FCT]

If you are unsatisfied with our response, you have the right to lodge a complaint with the Nigeria Data Protection Commission (NDPC) at ndpc.gov.ng.