PRIVACY POLICY

FortuneRealtors & Property Ltd
Effective Date: 16-08-2026
Last Updated: 16-08-2026

1. INTRODUCTION

FortuneRealtors & Property Ltd (“FortuneRealtors“, “we“, “us“, “our” or “Company“) respects your privacy and is committed to protecting the personal information entrusted to us.

This Privacy Policy explains how we collect, use, disclose, store, protect and otherwise process personal data when you visit our website, interact with our digital platforms, contact us, request information about our properties or services, book a property inspection, subscribe to our communications, purchase or express interest in a property, engage our services, apply for employment or independent property consultancy opportunities, or otherwise interact with FortuneRealtors.

FortuneRealtors is committed to processing personal data fairly, lawfully, transparently and securely and in accordance with applicable data protection laws and regulations, including the Nigeria Data Protection Act, 2023 (NDPA), applicable regulations, directives and guidance issued by the Nigeria Data Protection Commission (NDPC), and other applicable privacy and data protection requirements.

The NDPA establishes principles governing the lawful and responsible processing of personal data in Nigeria, including requirements relating to transparency, purpose limitation, data minimisation, accuracy, storage limitation, security and accountability.

By using our website or providing personal data to us, you acknowledge that you have read and understood this Privacy Policy. Where applicable law requires your consent, we will obtain it before processing your personal data for the relevant purpose.

2. WHO WE ARE

FortuneRealtors & Property Ltd is a real estate company engaged in the acquisition, development, marketing and sale of property and estates, as well as related real estate services.

Our business may involve acquiring strategically located land and property, conducting due diligence, developing estates and property opportunities, facilitating property transactions, providing property-related information and guidance, and supporting customers throughout relevant stages of their property journey.

For purposes of applicable data protection law, FortuneRealtors may act as a Data Controller when we determine the purposes and means of processing personal data.

In certain circumstances, we may also process personal data on behalf of another organisation and may therefore act as a Data Processor, where applicable.

3. SCOPE OF THIS PRIVACY POLICY

This Privacy Policy applies to personal data collected or processed by FortuneRealtors through or in connection with:

  • Our website and associated webpages;

  • Property enquiry forms;

  • Contact forms;

  • Property inspection booking forms;

  • Newsletter and email subscription forms;

  • Property purchase and reservation processes;

  • Customer onboarding and verification;

  • Property allocation processes;

  • Customer service communications;

  • Telephone calls and electronic communications;

  • Email, SMS and other communications;

  • Social media interactions;

  • Marketing and promotional activities;

  • Events, seminars and property viewings;

  • Employment applications;

  • Independent property consultant/marketer applications;

  • Business enquiries and professional relationships;

  • Transactions and contractual relationships; and

  • Other lawful interactions between you and FortuneRealtors.

This Policy applies whether information is collected directly from you or, where legally permitted, obtained from third parties.

4. WHAT IS PERSONAL DATA?

“Personal data” means information relating to an identified or identifiable individual.

Depending on your relationship with FortuneRealtors, personal data may include:

  • Full name;

  • Date of birth;

  • Gender, where relevant and lawfully collected;

  • Residential or correspondence address;

  • Telephone number;

  • Email address;

  • Identification information;

  • Nationality, where relevant;

  • Employment or professional information;

  • Company or organisation information;

  • Property preferences;

  • Property ownership or transaction information;

  • Payment and transaction information;

  • Information supplied during customer verification;

  • Communications and correspondence with us;

  • Photographs or recordings where applicable;

  • Information submitted through forms;

  • Website usage information;

  • Device and browser information;

  • IP address;

  • Cookies and similar technologies;

  • Marketing preferences;

  • Information contained in enquiries or complaints; and

  • Any other information you voluntarily provide to us or that we are lawfully required to process.

We will only collect personal data that is reasonably necessary for a specific, legitimate and lawful purpose.

5. PERSONAL DATA WE COLLECT

5.1 Information You Provide Directly

We may collect personal data when you:

  • Contact us;

  • Request information about a property;

  • Book a property inspection;

  • Request a property brochure or other information;

  • Subscribe to our newsletter;

  • Submit a contact form;

  • Request a callback;

  • Make a property enquiry;

  • Purchase or reserve a property;

  • Complete customer documentation;

  • Participate in an allocation process;

  • Communicate with our staff;

  • Submit a complaint or enquiry;

  • Apply for employment;

  • Apply to become an independent property consultant or marketer;

  • Participate in an event;

  • Respond to a survey;

  • Communicate with us through social media; or

  • Otherwise voluntarily provide information.

5.2 Information Collected Automatically

When you use our website, certain technical information may be collected automatically, including:

  • IP address;

  • Browser type;

  • Operating system;

  • Device type;

  • Screen characteristics;

  • Referring website;

  • Pages visited;

  • Time and duration of visits;

  • General interaction with our website;

  • Approximate location derived from technical information where applicable;

  • Website performance information; and

  • Other technical information generated through your use of our website.

This information may be collected through cookies, analytics technologies, server logs and similar technologies.

5.3 Information Received From Third Parties

Where legally permitted and necessary, we may receive information from third parties such as:

  • Professional advisers;

  • Legal advisers;

  • Financial institutions;

  • Payment service providers;

  • Verification providers;

  • Technology and hosting providers;

  • Marketing and communication platforms;

  • Business partners;

  • Regulatory authorities;

  • Publicly available sources;

  • Persons acting on your behalf; and

  • Other persons or organisations lawfully entitled to provide the information.

Where we receive personal data from a third party, we will process it in accordance with applicable law and this Privacy Policy.

6. PURPOSES FOR WHICH WE PROCESS PERSONAL DATA

We may process personal data for one or more of the following purposes:

6.1 Property Enquiries

To:

  • Respond to property enquiries;

  • Provide information about our properties and services;

  • Understand your property requirements;

  • Arrange property viewings;

  • Provide brochures and property information;

  • Respond to requests for quotations or other information; and

  • Communicate with you regarding properties in which you have expressed interest.

6.2 Property Inspections

Where you request a property inspection, we may process your:

  • Name;

  • Telephone number;

  • Email address;

  • Preferred inspection date;

  • Property of interest;

  • Location or meeting information;

  • Communication preferences; and

  • Other information reasonably required to arrange the inspection.

6.3 Property Transactions

Where you proceed with a property transaction, we may process information necessary to:

  • Verify your identity;

  • Complete transaction documentation;

  • Prepare contracts and related documents;

  • Process payments;

  • Issue receipts;

  • Process reservations;

  • Complete allocation procedures;

  • Maintain transaction records;

  • Provide customer support;

  • Comply with legal obligations; and

  • Protect our legal and contractual interests.

6.4 Customer Service

We process personal data to:

  • Respond to questions;

  • Handle complaints;

  • Resolve disputes;

  • Provide after-sales support;

  • Maintain records of communications; and

  • Improve our customer service.

6.5 Marketing and Communications

Where permitted by law and, where required, with your consent, we may use personal data to send:

  • Property updates;

  • New property announcements;

  • Market information;

  • Educational content;

  • Newsletters;

  • Events and invitations;

  • Promotional communications; and

  • Other information that may be relevant to your expressed interests.

You may unsubscribe from marketing communications at any time.

6.6 Website Improvement

We may process technical and usage information to:

  • Understand how visitors use our website;

  • Improve website functionality;

  • Identify technical problems;

  • Improve content and user experience;

  • Analyse website performance; and

  • Maintain website security.

6.7 Security and Fraud Prevention

We may process personal data to:

  • Protect our website, systems, staff and customers;

  • Detect and prevent fraud;

  • Investigate suspicious activities;

  • Prevent unauthorised access;

  • Protect property and physical premises;

  • Maintain appropriate security controls; and

  • Investigate potential violations of our policies.

6.8 Legal and Regulatory Compliance

We may process personal data where necessary to:

  • Comply with applicable laws;

  • Respond to lawful requests from government or regulatory authorities;

  • Meet accounting, tax, financial or regulatory obligations;

  • Establish, exercise or defend legal claims;

  • Maintain required records; and

  • Fulfil other legal obligations.

6.9 Recruitment

If you apply for employment with FortuneRealtors, we may process information necessary to:

  • Assess your application;

  • Contact you;

  • Conduct interviews;

  • Verify information provided;

  • Evaluate qualifications and experience;

  • Maintain recruitment records; and

  • Comply with applicable employment laws.

6.10 Independent Property Consultants and Marketers

Where you apply to work with FortuneRealtors as an independent property consultant, marketer or similar representative, we may process information required to:

  • Assess your application;

  • Contact you;

  • Provide training;

  • Manage your relationship with FortuneRealtors;

  • Administer relevant programmes;

  • Communicate property information;

  • Maintain business records; and

  • Comply with legal obligations.

7. LAWFUL BASES FOR PROCESSING

We will process personal data only where there is a lawful basis for doing so.

Depending on the circumstances, our lawful bases may include:

7.1 Consent

We may process personal data based on your consent where consent is legally required or appropriate.

You may withdraw consent at any time where processing is based on consent. Withdrawal of consent will not affect the lawfulness of processing carried out before withdrawal.

7.2 Performance of a Contract

We may process personal data where processing is necessary to enter into, perform or manage a contract with you.

This may include property transactions, customer services, appointments and other contractual relationships.

7.3 Legal Obligation

We may process personal data where necessary to comply with a legal or regulatory obligation applicable to FortuneRealtors.

7.4 Legitimate Interests

Where permitted by applicable law, we may process personal data where necessary for our legitimate interests or those of a third party, provided those interests do not override your fundamental rights and freedoms.

Examples may include:

  • Website security;

  • Fraud prevention;

  • Business administration;

  • Customer service;

  • Improving our services;

  • Protecting our legal interests; and

  • Managing business relationships.

7.5 Protection of Vital Interests

Where legally applicable, we may process personal data where necessary to protect the vital interests of an individual.

7.6 Public Interest

Where applicable under law, we may process personal data where necessary for a task carried out in the public interest or in accordance with applicable legal authority.

We will not rely on a particular lawful basis where it does not apply to the relevant processing activity.

8. DATA MINIMISATION

FortuneRealtors is committed to collecting and processing only personal data that is adequate, relevant and reasonably necessary for the purposes for which it is processed.

We do not seek to collect personal information merely because it is available.

Where information is not necessary for the relevant purpose, we will endeavour not to request it.

The NDPA’s data protection principles include data minimisation, purpose limitation and storage limitation.

9. HOW WE USE YOUR INFORMATION

We may use personal data to:

  • Provide our products and services;

  • Respond to enquiries;

  • Arrange property inspections;

  • Process property transactions;

  • Manage customer relationships;

  • Communicate with customers;

  • Provide requested information;

  • Send service-related communications;

  • Send marketing communications where permitted;

  • Improve our website;

  • Analyse website usage;

  • Prevent fraud and abuse;

  • Maintain security;

  • Conduct internal administration;

  • Manage business relationships;

  • Recruit employees;

  • Manage independent consultants;

  • Comply with legal obligations;

  • Establish or defend legal claims;

  • Protect our rights and property; and

  • Carry out other lawful activities reasonably connected to our business.

10. MARKETING COMMUNICATIONS

We may send marketing communications to you where permitted by applicable law.

These communications may include information about:

  • New estates;

  • Available properties;

  • Property opportunities;

  • Events;

  • Educational materials;

  • Market insights;

  • Company news;

  • Property guides;

  • Newsletters; and

  • Other relevant information.

Where consent is required, we will obtain it before sending the relevant marketing communications.

You can withdraw your marketing preferences at any time by:

  • Clicking the unsubscribe option in an email;

  • Contacting us using the details provided in this Privacy Policy; or

  • Following any other available opt-out mechanism.

Even if you opt out of marketing communications, we may continue to send essential service or transactional communications where necessary, such as information relating to a transaction, inspection, payment, account, contract or other existing relationship.

11. COOKIES AND SIMILAR TECHNOLOGIES

Our website may use cookies and similar technologies.

A cookie is a small data file stored on your device when you visit a website. Cookies may help us operate the website, remember preferences, understand website usage and improve user experience.

We may use the following categories of cookies:

11.1 Strictly Necessary Cookies

These cookies may be required for the website to function properly.

They may support:

  • Security;

  • Navigation;

  • Form functionality;

  • Session management; and

  • Essential website features.

These cookies generally cannot be disabled through our cookie management tools where doing so would prevent essential website functions.

11.2 Preference Cookies

These cookies may remember choices and preferences made by users.

11.3 Analytics Cookies

These cookies may help us understand how visitors use our website, including information such as pages visited and general interaction patterns.

11.4 Marketing Cookies

Where implemented, marketing cookies may be used to support advertising, campaign measurement or relevant communications.

Where applicable, non-essential cookies will be deployed subject to the requirements of applicable law and your cookie preferences.

You may manage cookies through our cookie consent mechanism or through your browser settings.

The NDPC has specifically indicated that organisations operating through digital platforms should provide appropriate privacy and cookie notices and give data subjects an opportunity to accept or decline applicable cookies.

12. THIRD-PARTY SERVICES AND DATA PROCESSORS

We may engage third-party service providers to perform services on our behalf.

These may include providers of:

  • Website hosting;

  • Website development and maintenance;

  • Cloud storage;

  • Email delivery;

  • Customer relationship management;

  • Marketing automation;

  • Analytics;

  • Payment processing;

  • Communication services;

  • Security services;

  • Identity or information verification;

  • IT support;

  • Professional services;

  • Legal services;

  • Accounting services; and

  • Other business-support functions.

Where a third party processes personal data on our behalf, we will take appropriate steps to ensure that the processing is governed by appropriate contractual and data protection obligations.

We do not authorise our service providers to use your personal data for unrelated purposes merely because we have provided them with access.

13. DISCLOSURE OF PERSONAL DATA

We may disclose personal data where necessary and lawful to:

  • Service providers and data processors;

  • Professional advisers;

  • Legal advisers;

  • Financial institutions;

  • Payment processors;

  • Verification providers;

  • Technology providers;

  • Auditors and consultants;

  • Government agencies and regulators;

  • Law enforcement authorities where legally required;

  • Courts and dispute-resolution bodies;

  • Business partners where necessary for a legitimate transaction or service;

  • Persons acting on your behalf; and

  • Other persons where you have authorised the disclosure or applicable law permits or requires it.

We will not sell your personal data as a commercial commodity.

14. PROPERTY TRANSACTIONS AND THIRD-PARTY INFORMATION

Property transactions can require the exchange of information with certain third parties.

For example, where necessary to complete a transaction, we may need to provide or receive information from:

  • Legal practitioners;

  • Surveyors;

  • Financial institutions;

  • Payment providers;

  • Relevant authorities;

  • Professional consultants;

  • Verification providers; and

  • Other transaction participants.

We will limit disclosures to information reasonably necessary for the relevant purpose and will take appropriate measures to ensure lawful processing.

15. INTERNATIONAL DATA TRANSFERS

Some of our service providers or technology providers may process personal data outside Nigeria.

Where personal data is transferred or made accessible outside Nigeria, FortuneRealtors will take appropriate measures required by applicable data protection law.

Depending on the circumstances, these measures may include:

  • Ensuring an appropriate legal basis for the transfer;

  • Using appropriate contractual protections;

  • Assessing the destination and relevant safeguards;

  • Obtaining consent where legally required;

  • Implementing appropriate security measures; and

  • Complying with applicable NDPA and NDPC requirements.

Where required by law, we will provide additional information concerning international transfers.

16. DATA SECURITY

FortuneRealtors takes reasonable and appropriate technical, organisational and administrative measures to protect personal data against:

  • Unauthorised access;

  • Unauthorised disclosure;

  • Unlawful processing;

  • Accidental loss;

  • Destruction;

  • Damage;

  • Alteration;

  • Theft;

  • Misuse; and

  • Other forms of unauthorised processing.

Depending on the nature and sensitivity of the information, security measures may include:

  • Access controls;

  • Authentication mechanisms;

  • Password protection;

  • Encryption where appropriate;

  • Secure hosting;

  • Data backup;

  • Staff confidentiality obligations;

  • Access limitation;

  • Security monitoring;

  • System updates;

  • Vendor controls;

  • Incident management procedures; and

  • Staff awareness and training.

No electronic transmission or storage system can be guaranteed to be completely secure. Accordingly, while we take reasonable measures to protect personal data, we cannot guarantee absolute security.

17. DATA BREACHES AND SECURITY INCIDENTS

If FortuneRealtors becomes aware of a personal data breach, we will assess and respond to the incident in accordance with applicable law.

Depending on the nature and severity of the breach, we may:

  • Investigate the incident;

  • Contain and mitigate the breach;

  • Assess risks to affected individuals;

  • Preserve relevant evidence;

  • Notify appropriate regulatory authorities where required;

  • Notify affected data subjects where required;

  • Take remedial measures; and

  • Review our security controls to prevent recurrence.

We will not delay required regulatory or individual notifications where applicable law requires notification within a prescribed period.

18. DATA RETENTION

We will retain personal data only for as long as reasonably necessary for the purpose for which it was collected, unless a longer period is required or permitted by law.

Retention periods may depend on:

  • The nature of the information;

  • The purpose for which it was collected;

  • Whether there is an ongoing customer relationship;

  • Contractual requirements;

  • Accounting and tax requirements;

  • Legal obligations;

  • Regulatory requirements;

  • Dispute resolution;

  • Fraud prevention;

  • Legal claims; and

  • Legitimate business requirements.

When personal data is no longer required, we will take reasonable steps to securely delete, destroy, anonymise or otherwise dispose of it in accordance with our retention procedures and applicable law.

19. DATA ACCURACY

We take reasonable steps to ensure that personal data we hold is accurate, complete and, where necessary, kept up to date.

You should notify us if information you have provided changes or if you believe information we hold about you is inaccurate.

Where appropriate, we will correct or update the relevant information.

20. YOUR DATA PROTECTION RIGHTS

Subject to applicable law and any lawful limitations, you may have the following rights in relation to your personal data:

20.1 Right to Be Informed

You have the right to receive clear information about how your personal data is collected and processed.

20.2 Right of Access

You may request access to personal data we hold about you and information about how it is being processed.

20.3 Right to Rectification

You may request that inaccurate or incomplete personal data be corrected.

20.4 Right to Erasure

In certain circumstances, you may request deletion of your personal data.

This right is not absolute. We may retain information where retention is necessary or legally required.

20.5 Right to Restrict Processing

In certain circumstances, you may request that we restrict the processing of your personal data.

20.6 Right to Object

You may have the right to object to certain processing activities, including certain processing based on legitimate interests or direct marketing.

20.7 Right to Data Portability

Where applicable, you may have the right to receive personal data you have provided to us in a structured, commonly used and machine-readable format, or request that it be transmitted to another controller where technically feasible and legally applicable.

20.8 Right to Withdraw Consent

Where processing is based on consent, you may withdraw your consent at any time.

Withdrawal does not affect the lawfulness of processing carried out before the withdrawal.

20.9 Rights Relating to Automated Decision-Making

Where applicable, you may have rights concerning decisions based solely on automated processing that produce legal or similarly significant effects.

20.10 Right to Lodge a Complaint

You have the right to lodge a complaint regarding our processing of your personal data with the appropriate data protection supervisory authority, including the Nigeria Data Protection Commission where applicable.

The NDPC identifies rights including information, access, rectification, objection, portability, erasure, rights relating to automated decision-making and the right to lodge a complaint.

21. HOW TO EXERCISE YOUR DATA RIGHTS

To exercise a privacy right, you may contact FortuneRealtors using the contact details provided in Section 31 of this Privacy Policy.

Your request should, where possible, include:

  • Your full name;

  • Contact information;

  • The nature of your request;

  • Relevant account, transaction or communication details;

  • The specific personal data involved; and

  • Any information reasonably necessary for us to identify and process your request.

For security purposes, we may need to verify your identity before completing certain requests.

We will respond to valid requests within the period required by applicable law.

Where we cannot comply with a request, we will explain the applicable reason, subject to lawful restrictions.

22. WITHDRAWING MARKETING CONSENT

You may withdraw consent to receive marketing communications at any time.

You can usually do this by selecting the “unsubscribe” option included in marketing emails or by contacting us directly.

Withdrawing marketing consent will not necessarily result in the deletion of all personal data we hold about you, because certain information may continue to be processed under another lawful basis, including contractual or legal obligations.

23. CHILDREN’S PRIVACY

Our website and services are primarily intended for adults.

We do not knowingly collect personal data from children where doing so would be unlawful.

If you believe that a child has provided personal data to us without appropriate authorisation or where such collection is not legally permitted, please contact us so that we can assess the situation and take appropriate action.

Where applicable law imposes specific requirements regarding children’s data, we will comply with those requirements.

24. SENSITIVE PERSONAL DATA

Certain categories of personal data may receive enhanced protection under applicable law.

We will not intentionally collect sensitive personal data unless there is a lawful and legitimate reason to do so.

Where processing sensitive personal data is necessary, we will implement appropriate safeguards and rely on a lawful basis permitted under applicable data protection law.

You should avoid submitting unnecessary sensitive personal information through general website forms.

25. THIRD-PARTY WEBSITES AND LINKS

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

These third-party websites operate independently from FortuneRealtors and may have their own privacy policies and terms.

We are not responsible for the privacy practices, content, security or data-processing activities of third-party websites that we do not control.

We encourage you to review the privacy policy of any third-party website before providing personal data.

26. SOCIAL MEDIA

FortuneRealtors may maintain accounts or pages on third-party social media platforms.

If you interact with us through social media, your interaction may also be subject to the privacy policy and terms of the relevant platform.

We may receive information that you choose to make available to us through those platforms.

We do not control how third-party social media platforms independently process information collected through their services.

27. DIRECT COMMUNICATIONS

When you contact us by telephone, email, messaging platform, social media or other communication channel, we may retain records of the communication where reasonably necessary for:

  • Customer service;

  • Transaction administration;

  • Complaint handling;

  • Quality assurance;

  • Legal compliance;

  • Security;

  • Training where appropriate; or

  • Establishing or defending legal claims.

Where calls are recorded, we will provide an appropriate notice where required by applicable law.

28. AUTOMATED PROCESSING AND PROFILING

We may use automated technologies for limited purposes such as:

  • Website analytics;

  • Personalisation;

  • Marketing segmentation;

  • Fraud detection;

  • Security monitoring; and

  • Service improvement.

We will not subject you to a decision based solely on automated processing that produces legal or similarly significant effects without appropriate safeguards where such safeguards are required by applicable law.

Where applicable, you may request human intervention or exercise other rights provided by law.

29. DATA PROTECTION BY DESIGN AND ACCOUNTABILITY

FortuneRealtors is committed to incorporating privacy and data protection considerations into relevant business processes, technology systems and services.

Where appropriate, we may:

  • Conduct privacy assessments;

  • Review processing activities;

  • Assess risks associated with personal data;

  • Limit access to personal data;

  • Train relevant personnel;

  • Review third-party processors;

  • Maintain internal data protection procedures;

  • Implement appropriate security measures; and

  • Review and update privacy practices.

We recognise that data protection is an ongoing responsibility rather than a one-time compliance exercise.

30. YOUR RESPONSIBILITIES

When providing personal data to FortuneRealtors, you should ensure that:

  • The information you provide is accurate;

  • You update us when relevant information changes;

  • You do not provide information that is unnecessary for the requested service;

  • You do not provide another person’s personal data without appropriate authority;

  • You protect the confidentiality of any account credentials or secure information provided to you; and

  • You notify us if you believe your information has been compromised.

If you provide personal information about another person, you should ensure that you are legally entitled to provide that information.

31. CONTACT US ABOUT PRIVACY

If you have questions, concerns, complaints or requests relating to this Privacy Policy or the processing of your personal data, please contact FortuneRealtors.

FortuneRealtors & Property Ltd

Address:
FIRST FLOOR IBUKUNOLU PLAZA,
CHEMIST BUS STOP, OJO ALABA INTERNATIONAL MARKET,
LAGOS, LAGOS STATE, NIGERIA.

Email: info@fortunerealtors.com

Telephone: +2349 1600 07473

Privacy/Data Protection Contact: [Insert designated privacy/DPO email or contact]

Where FortuneRealtors has formally appointed a Data Protection Officer or designated Data Protection contact, privacy-related requests should be directed to that person through the contact details published above.

32. COMPLAINTS

We take privacy complaints seriously.

If you believe that FortuneRealtors has processed your personal data unlawfully or has otherwise failed to respect your privacy rights, you should first contact us using the details in this Privacy Policy.

We will review the complaint, investigate where appropriate and take reasonable steps to resolve the matter.

You may also have the right to lodge a complaint with the Nigeria Data Protection Commission or another competent supervisory authority where applicable.

The NDPC provides regulatory channels for data protection complaints and privacy-related matters.

33. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect:

  • Changes in our business;

  • Changes in our website or services;

  • Changes in technology;

  • Changes in data processing activities;

  • Changes in applicable law;

  • New regulatory guidance;

  • Changes in data protection requirements; or

  • Improvements to our privacy practices.

When we make material changes, we will take reasonable steps to notify affected individuals where required.

The updated Privacy Policy will be published on our website with a revised “Last Updated” date.

We encourage you to review this Privacy Policy periodically.

34. GOVERNING LAW

This Privacy Policy shall be interpreted in accordance with the laws of the Federal Republic of Nigeria, including applicable Nigerian data protection legislation.

Nothing in this Privacy Policy is intended to remove or restrict any mandatory legal right or protection available to you under applicable law.

35. SEVERABILITY

If any provision of this Privacy Policy is determined to be invalid, unlawful or unenforceable, that provision shall be interpreted or modified to the extent necessary to make it lawful and enforceable.

If it cannot be modified, it shall be severed from the Privacy Policy without affecting the validity of the remaining provisions.

36. NO WAIVER

Failure by FortuneRealtors to enforce any provision of this Privacy Policy shall not constitute a waiver of its right to enforce that provision in the future.

37. ENTIRE PRIVACY NOTICE

This Privacy Policy, together with any specific privacy notices provided at the point of data collection, applicable cookie notices, consent notices and other privacy-related notices issued by FortuneRealtors, explains our general approach to the processing and protection of personal data.

Where a specific privacy notice applies to a particular processing activity, that notice should be read together with this Privacy Policy.

38. EFFECTIVE DATE

This Privacy Policy takes effect on [Insert Effective Date] and was last updated on [Insert Last Updated Date].

FortuneRealtors & Property Ltd
Committed to responsible, transparent and secure handling of personal data.

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