1.1 Personal Identification Information

• Name, email address, phone number
• Profile information and verification details
• Property owner/landlord information
• Tenant/renter contact details
• Government-issued ID (for verification purposes)
• Account credentials and profile settings

1.2 Usage Data

• IP address, browser type, device information
• Location data (with your permission)
• Access times, pages visited, and user interactions
• Platform usage patterns and preferences

1.3 Property and Media Data

• Property photos, videos, and virtual tours
• Property descriptions and specifications
• Location data and property addresses
• Rental terms and availability information
• Property documents and certificates
• Profile pictures and identification documents

1.4 Communication and Interaction Data

• Messages between property owners and potential tenants
• Property reviews and ratings
• Inspection requests and scheduling data
• Customer service communications
• Feedback and platform interactions
• Support tickets and correspondence

1.5 Cookies and Tracking Technologies

We use cookies, web beacons, and similar technologies to:

• Remember your preferences and settings
• Analyze platform usage and performance
• Provide personalized content and recommendations
• Ensure platform security

You can manage cookie preferences through your browser settings or our cookie preference center.

We process your data based on:

• Consent: When you explicitly agree to data processing
• Contract Performance: To provide our services and fulfill agreements
• Legitimate Interest: To improve our platform and prevent fraud
• Legal Obligation: To comply with applicable laws and regulations

We use collected data for:

• Registering users as property owners or tenants
• Facilitating property listings and discovery
• Enabling communication between property owners and potential tenants
• Processing inspection requests and scheduling
• Verifying user identities and property authenticity
• Displaying property reviews and ratings
• Improving and personalizing your user experience
• Sending important updates and notifications about properties
• Responding to customer service requests
• Analyzing platform usage and performance
• Preventing fraud and ensuring platform security
• Complying with legal obligations
• Marketing communications (with your consent)

4.1 We may share your information with:

• Service Providers: Third-party vendors who help operate our platform
• Legal Authorities: When required by law or to protect rights and safety
• Business Partners: Only with your explicit consent
• Professional Advisors: Lawyers, accountants, and consultants under confidentiality agreements

4.2 Business Transfers

In case of merger, acquisition, or sale of assets, your data may be transferred as part of the business assets.

We do not sell your personal data to third parties.

5.1 Analytics Services

• Google Analytics: Website and app usage analytics. https://policies.google.com/privacy
• Firebase Analytics: Mobile app performance and user behavior. https://firebase.google.com/support/privacy

5.2 Communication Services

• Twilio: SMS and communication services. https://www.twilio.com/legal/privacy
• SendGrid: Email delivery services. https://www.twilio.com/legal/privacy

We use the above listed third-party services that may collect data independently. Please review their respective privacy policies for information about their data practices.

We implement appropriate technical and organizational security measures including:

• Encryption of data in transit and at rest
• Regular security assessments and updates
• Access controls and authentication systems
• Employee training on data protection

However, no system is 100% secure, and we cannot guarantee absolute security of your data.

We retain your data for the following periods:

• Account Data: Until account deletion or 3 years after last activity
• Property Listings: Until removed by owner or 1 year after last activity
• Communication Data: 2 years from last message for safety and dispute resolution
• Reviews and Ratings: 5 years to maintain platform integrity
• Inspection Records: 2 years for safety and verification purposes
• Usage Data: 18 months from collection
• Legal Compliance Data: As required by applicable laws
• Marketing Data: Until you withdraw consent or 2 years of inactivity

Data may be retained longer if required for legal proceedings, regulatory compliance, or safety investigations.

8.1 Universal Rights

• Access: Request a copy of your personal data
• Correction: Request correction of inaccurate data
• Deletion: Request deletion of your data ("right to be forgotten")
• Withdrawal: Withdraw consent for data processing

8.2 Additional Rights (GDPR/CCPA)

• Portability: Receive your data in a portable format
• Restriction: Limit how we process your data
• Objection: Object to processing based on legitimate interest
• Automated Decision-Making: Opt-out of automated profiling

8.3 Exercising Your Rights

To exercise any of these rights:

• Email us at: privacy@cozzyconnect.com
• Use our in-app privacy settings
• Contact our support team

Depending on your location, you have the above listed rights. We will respond to your request within 30 days (or as required by local law).

If you are located outside our primary operating region, your data may be transferred internationally. We ensure adequate protection through:

• Standard contractual clauses
• Adequacy decisions by regulatory authorities
• Other appropriate safeguards as required by law

In the event of a data breach that poses a risk to your rights and freedoms, we will:

• Notify relevant authorities within 72 hours
• Inform affected users without undue delay
• Provide clear information about the breach and remedial actions
• Take immediate steps to secure the platform and prevent further breaches

CozzyConnect is not intended for users under 13 (or 16 in the EU). We do not knowingly collect personal data from children. If we become aware that we have collected data from a child, we will delete it immediately. Parents or guardians who believe we have collected their child's data should contact us immediately.

12.1 Nigeria Data Protection Act (NDPA) 2023

As a platform operating in Nigeria, we comply with the Nigeria Data Protection Act 2023 and are registered with the Nigeria Data Protection Commission (NDPC) as a Data Controller of Major Importance.

• NDPC Registration Category: [Insert MDP-UHL/MDP-EHL/MDP-OHL as applicable]
• Registration Number: [Insert NDPC Registration Number]
• Registration Date: [Insert Date]
• Right to access your personal data
• Right to rectification of inaccurate data
• Right to erasure ("right to be forgotten")
• Right to restrict processing
• Right to data portability
• Right to object to processing
• Right to withdraw consent

Complaints: You have the right to lodge a complaint with the Nigeria Data Protection Commission at complaints@ndpc.gov.ng or visit www.ndpc.gov.ng

12.2 GDPR (European Union)

We comply with the General Data Protection Regulation for EU users. You have additional rights under GDPR, including the right to lodge a complaint with your local data protection authority.

12.3 CCPA (California)

California residents have additional rights under the California Consumer Privacy Act, including the right to know what personal information is sold or disclosed and to opt-out of the sale.

12.4 Other Jurisdictions

We comply with applicable privacy laws in all jurisdictions where we operate.

We may update this policy periodically to reflect:

• Changes in our data practices
• Updates to applicable laws
• New features or services

13.1 Notification of Changes

We will notify you of material changes through:

• Email notification to registered users
• Prominent notice on our platform
• In-app notifications
• Updated "Last Modified" date at the top of this policy

Continued use of our platform after changes constitutes acceptance of the updated policy.

If you have questions, concerns, or requests regarding this privacy policy or our data practices reach out to use at privacy@cozzyconnect.com or support@cozzyconnect.com