Privacy Policy
1. Who We Are
Bezalel Estate Management Limited ("Bezalel," "we," "us," "our") is a Pan-African investment company registered in Nigeria (RC: 1677227), operating in real estate, energy, mining, and agriculture. This policy covers the Bezalel Estate mobile application, its companion web dashboard, and bezalelestate.org (together, the "Service").
We are the data controller for personal data collected through the Service, as defined under the Nigeria Data Protection Act 2023.
2. Personal Data We Collect
2.1 Account & Identity Data
| Category | Fields | Collected from |
|---|---|---|
| Basic profile | Full name, phone number, email address, residential address | All users, at sign-up |
| Government identity documents | A photo of a government-issued ID and a photo of proof of address | Clients and investors, at registration |
| National identity numbers | Bank Verification Number (BVN); National Identification Number (NIN) where applicable | Individual affiliate agents, at registration, for identity verification |
| Business registration data | CAC registration number, registered company name, Tax Identification Number (TIN), director's name | Corporate affiliate agents, at registration |
2.2 Financial & Transaction Data
| Category | Fields | Collected from |
|---|---|---|
| Purchases | Property/unit selected, price, payment plan, deposit and installment amounts, payment status, uploaded proof-of-payment images | Clients purchasing property |
| Investments | Investment pool selected, amount committed, payment status, uploaded proof-of-payment images | Direct investors |
| Payout details | Bank name, account name, account number | Affiliate agents, for commission payouts |
| Commission & referral data | Referral codes, referred-client relationships, commission amounts and status | Generated from affiliate activity |
2.3 Communications Data
If you use the in-app AI Advisor or Profit Calculator, the questions you ask and the context needed to answer them (e.g. unit price, plan type) are sent to a third-party AI service provider to generate a response, as described in Section 4.
2.4 Technical Data
Standard technical data generated by using a mobile app or website (e.g. device type, app version, crash logs), collected automatically through our infrastructure providers.
3. Why We Collect It (Legal Basis)
| Purpose | Legal basis |
|---|---|
| Creating and managing your account | Performance of a contract with you |
| Verifying your identity (BVN/NIN/CAC checks) | Legal obligation (KYC/AML) and performance of a contract |
| Processing a property purchase or investment | Performance of a contract |
| Paying affiliate commissions | Performance of a contract |
| AI Advisor / Profit Calculator responses | Consent (given by choosing to use the feature) and legitimate interest in providing a useful product |
| Fraud prevention and security | Legitimate interest and legal obligation |
| Sending you SMS one-time passcodes | Performance of a contract (account security) |
4. Who We Share Data With
We do not sell personal data. We share it only with the following categories of service providers, each acting as a data processor on our instructions, strictly to operate the Service:
| Provider | Role | Data involved |
|---|---|---|
| Supabase | Database, authentication, and file storage host for the Service | All account, KYC document, and transaction data described above |
| Hyparrow | Identity and business verification (BVN, NIN, CAC) and payment infrastructure | BVN/NIN/CAC numbers submitted for verification; payment account details |
| AI model provider(s) | Generates responses for the AI Advisor and Profit Calculator features (currently one or more of: Anthropic, xAI, Groq, Alibaba Cloud/Qwen, depending on availability) | The text of your questions and the property/plan context needed to answer them |
| SMS/OTP provider (Sendchamp or successor) | Delivers one-time passcodes for phone verification | Phone number |
We may also disclose personal data where required by law, court order, or a lawful request from the Nigeria Data Protection Commission or another regulator.
5. International Data Transfer
Our primary database and file storage infrastructure (Supabase) is hosted in the European Union (Ireland). This means personal data collected by the Service, including KYC documents and identity numbers, is transferred outside Nigeria for processing and storage.
This transfer is governed by contractual data-protection obligations with our processor, consistent with the Nigeria Data Protection Act 2023.
6. Data Retention
We retain personal data for as long as your account is active, and afterward for as long as necessary to comply with our legal obligations (including KYC/AML record-keeping requirements), resolve disputes, and enforce our agreements.
7. Your Rights
Under the Nigeria Data Protection Act 2023, you have the right to:
- Be informed about how your data is processed (this policy);
- Access the personal data we hold about you;
- Request correction of inaccurate or incomplete data;
- Request deletion of your data, subject to our legal retention obligations;
- Object to or restrict certain processing;
- Withdraw consent, where processing is based on consent, without affecting processing already carried out;
- Lodge a complaint with the Nigeria Data Protection Commission (NDPC).
To exercise any of these rights, contact us using the details in Section 10.
8. Data Security
We apply access controls at the database level (row-level security) so that a user's data is only ever readable by that user or an authorized administrator; identity documents and payment receipts are stored in private, access-controlled storage, never publicly reachable; and administrative actions that affect money or verification status are logged and restricted to authorized administrator accounts.
9. Children's Privacy
The Service is intended for users who are at least 18 years old and legally able to enter into property or investment agreements. We do not knowingly collect personal data from anyone under 18.
10. Contact Us
| General inquiries | info@bezalelestate.org |
|---|---|
| Data protection / privacy inquiries | privacy@bezalelestate.org |
| Phone | +234-916-1010-223 · +234-802-2210-102 |
| Registered office | 31B Usuma Street, Off Gana Street, Maitama, Abuja |
11. Changes to This Policy
We may update this policy as the Service changes. Material changes will be reflected by updating the "Last updated" date above; where required by law, we will provide additional notice.