PRIVACY POLICY.

1. INTRODUCTION

a. COOL REAL ESTATE LIMITED is a private limited liability company incorporated under the laws of the Federal Republic of Nigeria (herein after referred to as Cool Real, we us or ours). Cool Real is engaged in the business of buying, selling, and renting of commercial, property, residential property as well as residential development but not limited to theses business. We aim to make the dreams of our clients a reality by meeting them at the point of their specific needs.

b. This privacy notice for COOL REAL ESTATE LIMITED ("we," "us," or "our"), describes how and why we might collect, store, use, and or share ("process") your information when you use our website or services ("Services"), such as when you visit our website at http://www.coolrealestate.ng, or any website of ours that links to this privacy notice or when you engage with us in other related ways, including any sales, marketing, or events

c. Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at legal@coolgroup.ng.

2. INFORMATION WE COLLECT

a. In processing of personal identifiable data, we adhere strictly to the provisions of the NDPA as it touches on the principles of data processing. While Processing data of individuals or data subjects, we ensure Confidentiality, Integrity and Availability of all data collected. We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

b. In processing PII or SPII, we ensure that consent is obtained from the data subject by first reading this policy before ticking the small box annexed to this policy. As such, all data subjects have the right to give their consent, withdraw or withhold their consent to data processing.

c. We may collect personal information that you voluntarily provide to us when you register on the website, express an interest in obtaining information about us or our products and Services, when you participate in activities on the website or register on the website, or otherwise when you contact us depending on the services we offer and your level of interaction with us, we process your personal data to varying extents. The following are the types of information we collect and process but not limited to them;
i. Name
ii. Phone number
iii. Email Address
iv. Contact Address
v. Sex and Date of Birth
vi. Payment Information (such as bank name and bank account number and only when applicable)
vii. Identification Documents (such as a government-issued ID)

d. The legal basis for collecting this data is majorly contractual but not limited to contract but also includes security and consent and to ensure that our services suit the purpose of data subjects and to measure our performance Some may involve legitimate interest or legal obligation where analytics are tailored towards crime prevention and legal obligation.

e. ll personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

3. NATURE OF INFORMATION WE PROCESS

a. We process your information to provide, improve, and administer our services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

b. We process your personal information for a variety of reasons, depending on how you interact with our Services, including:
i. To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.

ii. To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.

iii. To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.

iv. To send you marketing and promotional communications. We may process the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time. For more information, see "WHAT ARE YOUR PRIVACY RIGHTS?" below.
v. To deliver targeted advertising to you. We may process your information to develop and display personalized content and advertising tailored to your interests, location, and more.

vi. To evaluate and improve our Services, products, marketing, and your experience. We may process your information when we believe it is necessary to identify usage trends, determine the effectiveness of our promotional campaigns, and to evaluate and improve our Services, products, marketing, and your experience.

vii. To comply with our legal obligations. We may process your information to comply with our legal obligations, respond to legal requests, and exercise, establish, or defend our legal rights.

4. SHARING OF PERSONAL INFORMATION

a. We may share information in specific situations described in this section and/or with the following third parties.

b. We may need to share your personal information in the following situations:
i. usiness Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

ii.When we use Google Maps Platform APIs. We may share your information with certain Google Maps Platform APIs (e.g., Google Maps API, Places API).

c. We may also share your information with our affiliates, in which case we will require those affiliates to honor this privacy notice. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.

d. We may share your information with our business partners to offer you certain products, services, or promotions.

5. COOKIES AND OTHER TECHNOLOGIES a. We may use cookies and other tracking technologies to collect and store your information.

b. We may use cookies and similar tracking technologies (like web beacons and pixels) to gather information when you interact with our Services. Some online tracking technologies help us maintain the security of our Services and your account, prevent crashes, fix bugs, save your preferences, and assist with basic site functions.

c. We also permit third parties and service providers to use online tracking technologies on our Services for analytics and advertising, including to help manage and display advertisements, to tailor advertisements to your interests, or to send abandoned shopping cart reminders (depending on your communication preferences). The third parties and service providers use their technology to provide advertising about products and services tailored to your interests which may appear either on our Services or on other websites.

d. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice.

6. INFORMATION RETENTION a. We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.

b. We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than three (3) months past the termination of the user's account.

c. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

7. SAFETY AND PROTECTION OF DATA

a. We aim to protect your personal information through a system of organizational and technical security measures.

b. We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cyber criminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

8. MINORS

a. We do not knowingly collect data from or market to children under 18 years of age.

b. We do not knowingly collect, solicit data from, or market to children under 18 years of age, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at legal@coolgroup.ng.

9. YOUR PRIVACY RIGHTS

a. You may review, change, or terminate your account at any time, depending on your country, province, or state of residence.

b. Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided below.

c. However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

d. Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us using the details provided in the section below. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

10. ACCOUNT INFORMATION

a. If you would at any time like to review or change the information in your account or terminate your account, you can:
i. Log in to your account settings and update your user account.

ii. Contact us using the contact information provided.

b. Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

11. COOKIES AND SIMILAR TECHNOLOGIES

a. Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services.

b. If you have questions or comments about your privacy rights, you may email us at legal@coolgroup.ng.

12. POLICY UPDATE

a. we reserve the right to update this notice as necessary to stay compliant with relevant laws. The updated version will be indicated by an updated "Revised" date at the top of this privacy notice. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

13. POLICY REVIEW AND UPDATE

a. You have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. To request to review, update, or delete your personal information, please visit: legal@coolgroup.ng.

14. HOW TO CONTACT US

a. If you have questions or comments about this notice, you may email us at legal@coolgroup.ng or contact us by post at:
COOL GROUP OF COMPANIES LIMITED First Floor, Right Wing Gold Crest Mall, Ikota, Lekki-Ajah Expressway Lagos Island, Lagos, Nigeria