Persons accessing the Broll Nigeria web site, subject themselves to and agree to Broll Nigeria terms conditions and privacy policy, as set out below.

PRIVACY POLICY


Broll Nigeria respects your privacy and is committed to keeping your information confidential.

Broll Nigeria is a controller and processor for the personal information that it collects and uses about you. We respect your privacy and we are committed to insuring that your information is kept confidential in accordance with applicable data protection legislation. Our use of your personal data will be governed by this Privacy policy.

Generally, you can visit our Web Site without having to divulge any personal information about yourself. However, while using this Web Site you may provide information about yourself. Any and all information provided at this site will be kept strictly confidential and will not be sold, loaned, reused or otherwise disclosed to any organization.

We will only disclose or report personal information if and when required to do so by law or any regulatory authority and to our employees who require such information to carry out their duties.

This Privacy policy explains;

  • What personal information is
  • How we collect your personal information
  • The types of personal information we collect
  • How your personal information is used
  • The legal basis for processing your personal information
  • How your personal information is shared
  • How long we keep your personal information
  • How your personal information is kept secure
  • Your rights in relation to your personal information

If there are any changes to the way in which your personal information is used, this Privacy policy will be updated.

What is personal information?
Personal information is any information that tells us something about you. This could include information such as name, contact details, date of birth, address or any information about your needs or circumstances which would allow us to identify you.

Your personal information is used as is appropriate in the normal course of our business with you to provide the products and services you have requested. With your consent, we will only retain any information for purposes of ongoing business relationships or to communicate directly with you.

The types of personal information we collect
We may sometimes collect your name and contact details (such as phone number and email address) from you whenever you contact us to enable us to provide our services. Depending on the service that we provide to you (or on your behalf) we may also collect additional personal information as detailed below;

Buy, Sell, Let, Rent
If you are selling or letting a property through us;

  • We will collect a contact telephone number to get in touch with you about organizing viewings and updating you on any offers received or rental applications for your property.
  • Where you are not the legal owner of the property we will request details from you as to your ability to sell or let the property such as a Power of Attorney.

If you wish to purchase a property we are listing for sale, we will collect personal information relating to any specific requirements you may have in relation to a property so that we can find a property that is suitable for your needs. We will also collect personal information required to source a property for you and, where required, negotiate the purchase of a property on your behalf.

Facilities Management
Where we are managing property on your behalf we may need to pass your personal information on to third party contractors whom we have engaged to carry out maintenance on your properties.

Regulatory compliance
To comply with certain regulatory requirements, we will collect information required to identify you to meet anti-money laundering and counter terrorist financing requirements. We will collect information relating to your identity, which will include at least one form of photographic identification (such as a passport, a driving licence or an identification card) and one form of documentation with proof of your place of residence (such as a recent utility bill).
If you are an entity such as a company, trust or charity, we may need to collect personal information about the controllers and the beneficiaries of the entity.

Other
If you subscribe to receive research, news or other market updates from us, then in addition to the above we will collect details such as email address and the type of content that you would like to receive.

We maintain a list of e-mail addresses to which Broll Nigeria Newsletter is sent. Individuals must affirmatively request to join this list by using the subscribe form on the subscriptions page. Any members of this list may choose to unsubscribe at any time by using the same form. Our list server has been configured in such a way that the e-mail addresses can only be accessed by authorized Broll Nigeria staff.

We will only record your e-mail address if you send us a message. It will only be used for the purpose for which you provide it and will not be added to a mailing list unless you request that this be done. We will not disclose it without your consent.

We may share personal information with our regulators, governmental or quasi-governmental organizations, law enforcement authorities and with courts, tribunals and arbitrators as may be required in order to comply with our regulatory and legal obligations.

How your personal information is used
What is the legal basis of our data processing?

Under data protection legislation we are only permitted to use your personal information if we have a legal basis for doing so. We rely on the following legal bases to use your information;

  • Where we need information to perform the contract we have entered into with you
  • Where we need to comply with a legal obligation
  • Where the processing is necessary for us to carry out activities for which it is in Brolls' legitimate interests to do so and provided that your interests and fundamental rights do not override those interests.
    • Processing that is necessary for us to promote our business and products – this will include sending you marketing information from time to time after you have engaged us to provide services or received services from us either which may be similar and of interest to you or where you have expressly indicated that you would like to receive such information. You have the right to opt out of receiving this information at any time.
    • Processing that is necessary to improve our knowledge of the real estate sector – this will include undertaking market analysis and research so that we better understand trends in the property sector and provide better knowledge along with more tailored and relevant services for our customers in the future.

In more limited circumstances we may also rely on the following legal bases:

  • Where we need to protect your interests (or someone else's interests); and/or
  • Where it is needed in the public interest or for official purposes

We may process special categories of personal information and criminal conviction information in the following limited circumstances:

  • With your explicit consent, in which case we will explain the purpose for which the information will be used at the point where we ask for your consent.

Buy, Sell, Let, Rent

  • We use your personal information for the purposes of fulfilling our obligations to you to let or sell your property or, if you are a buyer or tenant, for the purposes of arranging a contract for sale or a lease for you.
  • If you are purchasing a property we are acting as agents for the sale of or selling a property through us we will share your personal information with your appointed solicitors and the solicitors acting for the other side of the deal as is necessary to facilitate the sale or purchase.


Facilities Management

  • Where we are managing property on your behalf we may need to pass your personal information from time to time on to third party contractors whom we have engaged to carry out maintenance on your properties.

Other uses of your personal information

  • If we sell any part of our business and/or integrate it with another organisation your details may be disclosed to our advisers and to prospective purchasers or joint venture partners and their advisers. If this occurs the new owners of the business will only be permitted to use your information in the same or similar way as set out in this privacy policy.
  • We will share personal information with our regulators, governmental or quasi-governmental organisations, law enforcement authorities and with courts, tribunals and arbitrators as may be required from time to time in order to comply with our regulatory and legal obligations;

What happens if you do not provide information that we request?
We need some of your personal information to perform the services you have requested from us. For example:

  • where we are selling a property on your behalf we need to know your contact information so that we can update you with information on viewings, offers and the progress of the sale;
  • where you have asked us to find you a property which meets certain access requirements, we may need to know some further details about your particular circumstances so that we can find you a suitable property;

We also need some information so that we can comply with our legal obligations. For example, we may need identity documents from you to meet our obligations to prevent fraud and money laundering.

If you do not provide the information required for these purposes, we will not be able to perform our contract with you and may not be able to provide services to you or continue to provide certain services to you. We will explain when this is the case at the point where we collect information from you.

How we keep your information secure
The security of information is very important to us and we have measures in place which are designed to prevent unauthorized access to your personal information including but not limited to:

  • Our client files are stored on our secure systems. Access is restricted on our client systems to those within the business who are required to have access to your information for legitimate business purposes.
  • Hard copy documentation is stored in locked cabinets.

We ensure access to personal information is restricted to Broll employees and workers or other persons working within the Broll Group on a need to know basis. Training is provided to any of those Broll employees and workers who need access to personal information.

For how long do we keep your personal information
The period for which we will keep your personal information will depend on the type of service you have requested from us. The retention period may be longer than the period for which we are providing services to you where we have statutory or regulatory obligations to retain personal information for a longer period, or where we may need to retain the information in case of a legal claim.

Your rights in relation to your personal information
You have a number of rights in relation to your personal information, these include the right to:

  • Be informed about how we use your personal information
  • Obtain access to your personal information that we hold
  • Request that your personal information is corrected if you believe it is incorrect, incomplete or inaccurate
  • Request that we erase your personal information in the following circumstances:
    • If Broll is continuing to process personal information beyond the period when it is necessary to do so for the purpose for which it was originally collected
    • If Broll is relying on consent as the legal basis for processing and you withdraw consent
    • If Broll is relying on legitimate interests as the legal basis for processing and you object to this processing and there is no overriding compelling ground which enables us continue with the processing
    • If the personal information has been processed unlawfully (i.e. in breach of the requirements of the data protection legislation)
    • If it is necessary to delete the personal information to comply with a legal obligation
  • Ask us to restrict our data processing activities where you consider that:
    • personal information is inaccurate
    • our processing of your personal information is unlawful
    • where we no longer need the personal information but you require us to keep it to enable you to establish, exercise or defend a legal claim
    • where you have raised an objection to our use of your personal information
  • Request a copy of certain personal information that you have provided to us in a commonly used electronic format. This right relates to personal information that you have provided to us that we need in order to perform our agreement with you and personal information where we are relying on consent to process your personal information.
  • Not be subject to wholly automated decisions which produce legal effects or which could have a similarly significant effect on you.

If you would like to exercise any of your rights you may submit your request via our Subject Access Request form. Upon a request made, we will furnish you with details of the personal information we hold about you. Should you believe that any information we hold about you is incorrect, please inform us at the above page and we will correct it.

Please note that we will keep a record of the fact that you have made a request to exercise your rights, and our response to your request, in order to demonstrate compliance with our data protection obligations and so that we can handle any queries, complaints or claims in relation to your request. This record will be kept in accordance with our retention policies as explained above.

Please note that, while all attempts are made to secure information transmitted to this Web Site, if you are submitting personal details or other information over the Internet which you wish to remain private, there is a possibility that information you submit could be observed by a third party while in transit.