# GateWise NG Data Protection Policy

Effective date: 25th May, 2026.

This Data Protection Policy explains the principles GateWise NG follows when handling personal data. GateWise NG is a product of Globulus Technology Limited. It is written for Customers, Users, employees, contractors, partners, and service providers who interact with GateWise.

## 1. Purpose

GateWise processes personal data to provide estate visitor-management, access-support, onboarding, billing, support, and related services. This Policy sets out how we protect personal data and respect privacy rights.

## 2. Data Protection Principles

GateWise follows these principles:

- Lawfulness, fairness, and transparency: we process personal data for clear and lawful purposes.
- Purpose limitation: we use personal data only for the purpose it was collected or another compatible purpose.
- Data minimization: we collect only data reasonably needed for platform and estate operations.
- Accuracy: we provide tools and support channels to help keep data accurate.
- Storage limitation: we keep personal data only as long as necessary.
- Security: we apply safeguards to protect personal data.
- Accountability: we maintain policies, procedures, and records to show responsible data handling.

## 3. Roles and Responsibilities

GateWise may act as a data controller, data processor, or joint participant in data handling depending on the activity.

Customers are generally responsible for deciding why estate user, resident, guard, and visitor data is entered into GateWise. GateWise is generally responsible for operating the platform, protecting the data we process, and using it according to applicable agreements and policies.

All GateWise personnel, contractors, and approved partners must handle personal data only for authorized purposes.

## 4. Data Categories

GateWise may process:

- account and contact data
- estate and property data
- resident and household data
- guard and supervisor data
- visitor and pass data
- check-in, checkout, and incident data
- billing and subscription data
- support and communication data
- technical, diagnostic, and security data

GateWise does not ask users to submit unnecessary sensitive personal data. Customers and Users should avoid entering sensitive information unless it is required for a lawful and approved purpose.

## 5. Collection and Notice

GateWise provides privacy information through our public policies and customer communications. Customers should provide any additional notices required for their estate residents, staff, guards, visitors, or other users.

Where Customers collect visitor or resident data through GateWise, Customers should ensure that affected individuals understand why the data is collected and how it will be used.

## 6. Access Control

GateWise limits access to personal data based on user role, estate affiliation, account status, plan, enabled features, and operational need.

Users should only access data needed to perform their authorized role. Customers are responsible for assigning roles carefully and removing access when a user no longer requires it.

## 7. Data Accuracy

Customers and Users are responsible for providing accurate information. GateWise provides tools and support routes to correct inaccurate data where permitted.

Users should promptly report incorrect resident, visitor, guard, account, payment, or access records.

## 8. Security Safeguards

GateWise applies safeguards designed to protect personal data from unauthorized access, loss, misuse, alteration, or disclosure.

Safeguards may include:

- account authentication
- role-based permissions
- operational logging
- administrative review
- secure service providers
- protected support workflows
- restricted staff access
- periodic access review
- incident response procedures

GateWise does not publish sensitive details about its security configuration, internal systems, or defensive controls.

## 9. Service Providers and Partners

GateWise may use trusted service providers to deliver hosting, communication, payment, analytics, support, and security services. GateWise requires providers to process personal data only for authorized purposes and to apply appropriate safeguards.

Approved sales partners may receive limited customer or estate information only where GateWise has enabled that access for onboarding, customer success, or support. Partners must not use personal data for unrelated purposes.

## 10. Data Subject Requests

Individuals may request access, correction, deletion, anonymization, or other privacy rights where applicable.

GateWise may need to verify identity and confirm the relevant estate or Customer before responding. If the request relates to data controlled by a Customer, GateWise may route the request to that Customer or work with the Customer to respond.

## 11. Deletion and Anonymization

GateWise supports deletion and anonymization where appropriate. When a verified deletion request is approved and no lawful reason requires continued retention, GateWise will delete personal data or make it unidentifiable to persons.

Anonymized or de-identified records may be retained where they no longer reasonably identify a person and are needed for statistics, audit integrity, billing records, safety records, or service improvement.

## 12. Incident Handling

GateWise maintains procedures to identify, assess, contain, investigate, and respond to suspected personal data incidents.

Where required, GateWise will notify affected Customers, Users, or authorities in accordance with applicable law and customer agreements.

## 13. Training and Awareness

GateWise personnel and relevant contractors should receive appropriate guidance on data protection, confidentiality, security, and responsible platform operations.

Customers should train estate administrators, supervisors, and guards on lawful and respectful handling of resident and visitor data.

## 14. Reviews and Updates

GateWise will review this Policy periodically and update it when our services, legal obligations, or data practices change.

## 15. Contact

For data protection questions or requests, contact:

Globulus Technology Limited
Email: privacy@gatewise.ng
Phone: +234 8037 552 346