# GateWise NG Privacy Policy Effective date: 25th May, 2026 This Privacy Policy explains how GateWise NG collects, uses, shares, stores, protects, and deletes personal data when you use our platform, websites, web application, mobile application, visitor-pass features, support channels, and related services. GateWise NG is a product of Globulus Technology Limited. In this Policy, "GateWise", "GateWise NG", "we", "us", or "our" means Globulus Technology Limited acting through the GateWise NG product. "Customer" means an estate, property manager, estate association, company, or organization using GateWise. "User" means any person using GateWise, including estate administrators, supervisors, guards, residents, visitors, sales partners, and platform administrators. ## 1. Scope This Policy applies to personal data processed through GateWise. It covers: - estate administrators and staff - guards and security supervisors - residents and household representatives - visitors invited to an estate - sales administrators and approved partners - people who contact support or request information - users of the GateWise website, web app, and mobile app Where GateWise processes data for a Customer, the Customer may also have its own privacy notices and legal responsibilities. ## 2. Personal Data We Collect The data we collect depends on your role and the features enabled for your estate or account. ### Account Data We may collect: - name - phone number - email address where used - role and permission information - account status - estate or organization affiliation - login and verification records - support and communication history ### Estate and Property Data We may collect: - estate name - estate location or general address - estate type - number of units or residents - subscription plan and onboarding status - assigned administrators or partner contacts ### Resident and Household Data We may collect: - resident name - phone number - unit, house, apartment, or address information inside the estate - resident status - visitor invitation and pass activity ### Guard and Supervisor Data We may collect: - name - phone number - role or duty assignment - device-related identifiers used to protect guard account access - check-in, checkout, and incident activity ### Visitor Data We may collect: - visitor name - phone number - visit purpose where provided - host or resident being visited - vehicle information where provided - visitor photo where enabled by the estate - pass status, pass code, QR code, validity period, and usage records - check-in and checkout records ### Payment and Billing Data We may collect: - subscription plan selection - invoice, payment, and transaction references - payment status - payment provider metadata needed to confirm payment GateWise does not intentionally store full card numbers or bank account credentials. Payment details are handled by payment providers according to their own terms and privacy practices. ### Technical and Usage Data We may collect: - device type - app version - browser type - approximate location derived from network information where available - log-in time and activity timestamps - feature usage records - error logs and diagnostic data - security and audit records ### Support and Communication Data When you contact us, we may collect: - name and contact details - issue description - screenshots or files you choose to send - call, message, or ticket history - feedback and survey responses ## 3. How We Collect Data We collect data when: - you or your estate creates an account - an estate administrator adds users or residents - a resident creates or shares a visitor pass - a guard checks a visitor in or out - a user reports an incident - a payment is initiated or confirmed - you contact support - you use the website, web app, or mobile app - approved third-party providers send us status updates needed to provide the service ## 4. Why We Use Personal Data We use personal data to: - provide and operate GateWise - create and manage accounts - authenticate users - support visitor invitations and pass verification - record check-in and checkout activity - support incident reporting and estate operations - manage estate onboarding, subscriptions, and billing - send service messages, OTPs, alerts, and operational notifications - provide customer support - prevent fraud, abuse, unauthorized access, and misuse - maintain audit records - comply with legal, regulatory, accounting, and dispute-resolution obligations - improve platform reliability, usability, and security We do not sell personal data. ## 5. Legal Basis for Processing Depending on the context, GateWise may process personal data because: - it is necessary to provide the service requested by a Customer or User - it is necessary for a contract or pre-contractual onboarding - the Customer or User has provided consent where required - the processing is necessary for legitimate operational, safety, security, billing, or support interests - the processing is necessary to comply with legal obligations - the processing is necessary to protect vital interests in an emergency Where a Customer provides personal data to GateWise, the Customer is responsible for ensuring that it has an appropriate lawful basis to do so. ## 6. Who Can Access Personal Data Access depends on role, estate affiliation, plan, and enabled features. Personal data may be available to: - the resident or user who provided it - the estate administrator responsible for the estate - authorized supervisors or guards performing access operations - authorized GateWise personnel who need access for support, safety, compliance, billing, or platform operations - approved sales partners only where their access has been enabled and is necessary for onboarding or support - third-party service providers who help us provide the platform - regulators, courts, law enforcement, or other authorities where required by law Users should not access or disclose data unless their role allows it and it is necessary for a legitimate platform or estate purpose. ## 7. Sharing with Third Parties GateWise may share limited data with service providers that help us operate the platform, such as: - hosting and infrastructure providers - payment processors - SMS and communication providers - email providers - customer support tools - analytics and error-monitoring tools - professional advisers We require service providers to protect personal data and use it only for authorized purposes. ## 8. International Transfers Some service providers may process data outside Nigeria or outside your country of residence. Where this happens, we use appropriate safeguards required by applicable law, such as contractual protections, security controls, and due diligence on service providers. ## 9. Data Retention We keep personal data only for as long as needed for the purposes described in this Policy, including service delivery, safety, audits, billing, legal compliance, dispute resolution, and legitimate business records. Retention periods may vary by data type, estate policy, legal requirements, and customer agreement. More detail is provided in the [Data Retention and Deletion Policy](data-retention-and-deletion-policy.md). ## 10. Data Deletion and Anonymization You may request deletion of personal data. After a verified request, and where no legal, contractual, safety, billing, or dispute-related reason requires continued retention, GateWise will delete, anonymize, or make the data unidentifiable to persons. When data is made unidentifiable, direct identifiers such as name, phone number, or other personal references are removed, masked, or replaced so the record is no longer reasonably linked to an identifiable person. Some non-identifying records may be retained for security, statistics, accounting, service integrity, or legal reasons. Backups may retain deleted data for a limited period until they are overwritten in the normal backup cycle. ## 11. Your Privacy Rights Depending on applicable law and your relationship with GateWise or a Customer, you may have the right to: - request access to your personal data - request correction of inaccurate data - request deletion or anonymization - object to certain processing - withdraw consent where processing is based on consent - request restriction of processing - request information about how your data is used - lodge a complaint with a data protection authority If your data was provided by an estate or Customer, we may need to involve that Customer in responding to your request. ## 12. Security GateWise uses administrative, technical, and organizational safeguards designed to protect personal data. These include access controls, authentication, role-based permissions, audit records, security monitoring, provider review, and operational procedures. No digital service can guarantee absolute security. Users and Customers must also protect accounts, devices, login codes, and local procedures. ## 13. Children's Privacy GateWise is not intended for independent use by children below 18 years. If an estate processes information about minors as residents or visitors, the Customer is responsible for ensuring that appropriate notice, authority, and safeguards are in place. ## 14. Marketing Communications GateWise may send service-related messages that are necessary for account, security, billing, or operational purposes. Where we send marketing messages, we will provide opt-out options where required. ## 15. Changes to This Policy We may update this Policy from time to time. We will post the updated version with a new effective date and provide additional notice where required. ## 16. Contact For privacy questions or requests, contact: Globulus Technology Limited Email: privacy@gatewise.ng Phone: +234 8037 552 346 If you are contacting us about data connected to a specific estate, please include the estate name and your relationship to the estate so we can verify and route the request appropriately.