Privacy Policy

1. Who we are

This Privacy Policy explains how Livesmart Realty NG Ltd. ("Livesmart", "we", "us" or "our"), a company registered in Nigeria with registered office at Room 104, AHCN Towers, CIPM Avenue, Ikeja, Lagos, Nigeria, collects, uses, shares and protects your personal data.

Livesmart designs, supplies, installs, integrates, configures and supports smart-home and property-technology systems (including automation hubs, lighting, sensors, cameras, smart locks, voice assistants and remote-access tooling), and provides related advisory and property services.

For the personal data described in this Policy, Livesmart is the data controller. Where we install and configure systems that you then own and operate in your own home or premises, you may also become a controller of the data your system generates; this Policy explains the part we are responsible for.

Data Protection Officer / privacy contact — Email: hello@livesmart.ng · Phone: +234 903 948 9094 · Address: Room 104, AHCN Towers, CIPM Avenue, Ikeja, Lagos, Nigeria.

2. Scope of this Policy

This Policy applies to personal data we process when you:

• visit or interact with our website, social media pages or online forms;
• enquire about, request a quotation for, or purchase our products or services;
• have a smart-home or property-technology system surveyed, installed, integrated or serviced by us;
• receive ongoing support, remote assistance or monitoring from us; or
• communicate with us by phone, email, WhatsApp or in person.

It does not apply to third-party websites, apps or platforms that you choose to use alongside your system (for example Amazon Alexa, your camera manufacturer's cloud, or a remote-access provider). Those are governed by their own privacy policies, and we explain our role in Section 9.

3. The law we follow

We process personal data in line with the Nigeria Data Protection Act, 2023 (NDPA), the General Application and Implementation Directive, 2025 (GAID) issued by the Nigeria Data Protection Commission (NDPC), the Federal Competition and Consumer Protection Act, 2018 (FCCPA) where relevant, and the right to privacy guaranteed by sections 37 and 45 of the Constitution of the Federal Republic of Nigeria, 1999. Where we serve customers outside Nigeria, additional local laws may also apply.

4. The personal data we collect

Depending on how you interact with us, we may collect the following categories of personal data.

a. Information you give us

• Identity and contact details: name, address, email, phone/WhatsApp number, and for business clients, company details and contact persons.
• Property details needed to design a system: address, layout, number of rooms, photographs of the premises, network and power setup, and your automation preferences.
• Account and credential information you ask us to set up or connect on your behalf (for example a smart-home hub account, a voice-assistant account or a remote-access account). Where possible we configure these so that you, not we, hold the master credentials.
• Payment and billing information needed to process orders and invoices.
• Records of your enquiries, support requests, correspondence and feedback.

b. Information we collect automatically through our website

• Device and usage data such as IP address, browser type, pages viewed and approximate location, collected through cookies and similar technologies (see Section 11).

c. Information generated by an installed system

When we install, configure, service or remotely support a smart-home or property-technology system, we may have access to data that the system produces, including:

• camera/CCTV video footage and still images;
• audio captured by voice assistants or intercoms;
• sensor data such as motion, door/window state, occupancy, temperature and energy use;
• access and event logs, including smart-lock entry records;
• fingerprint or other biometric data used by smart locks; and
• device identifiers, network details and system diagnostic logs.

Our system architecture is deliberately local-first, meaning most of this data is designed to stay on equipment located in your own premises and under your control, rather than being routinely uploaded to us. We generally access it only where it is needed to install, configure, diagnose or repair your system, or where you ask us to.

5. Sensitive personal data

Some of the data above is sensitive personal data under the NDPA — in particular biometric data (such as fingerprints used by a smart lock), and potentially video or audio that reveals sensitive information. We only process sensitive personal data where the law allows, which in most cases means with your explicit consent, and we apply additional safeguards to it. You can decline biometric features and use alternatives (such as a PIN or key) instead.

6. Why we use your personal data, and our lawful basis

Under the NDPA we must have a lawful basis for every use of your personal data. In summary:

• Respond to enquiries and prepare quotations — to answer you and price your project: steps taken at your request before a contract; legitimate interests.
• Supply products, carry out installation, integration and servicing — to perform our agreement with you: performance of a contract.
• Provide support, remote assistance and (where agreed) monitoring — to keep your system working: performance of a contract; legitimate interests.
• Configure and connect accounts, devices and remote access on your behalf — to deliver the system you ordered: performance of a contract; your consent.
• Process biometric and other sensitive data (e.g. smart-lock fingerprints) — to enable features you choose: your explicit consent.
• Take payment, invoice and keep accounting records — to get paid and meet tax/legal duties: performance of a contract; legal obligation.
• Improve our services, products and security — to run and develop our business: legitimate interests.
• Send you service updates and, where permitted, marketing — to keep you informed: legitimate interests; consent for direct marketing.
• Comply with the law and respond to lawful requests — to meet legal duties: legal obligation; vital interests where life or safety is at risk.

Where we rely on legitimate interests, we balance our interests against your rights and only proceed where yours are not overridden. Where we rely on consent, you may withdraw it at any time (see Section 12).

7. Direct marketing

We will only send you marketing about our products, packages and offers where you have agreed to receive it, or where the law otherwise permits. Every marketing message will give you an easy way to opt out, and you can also contact us at any time to stop.

8. Children

Our services are aimed at adults. We do not knowingly collect personal data directly from children. Where a system we install captures data relating to children in a household (for example on a camera), the householder is responsible for how that system is used; we provide guidance on responsible configuration on request. If you believe we hold a child's data without an appropriate basis, contact us and we will address it.

9. When we share your personal data

We do not sell your personal data. We share it only as follows:

• Our team and authorised installers who need it to design, install or support your system, under confidentiality obligations.
• Service providers (data processors) who help us operate — for example website hosting, IT, payment processing and communications — under written agreements that require them to protect your data and use it only on our instructions.
• Third-party platforms you choose to use, such as a voice-assistant provider (e.g. Amazon Alexa), a camera manufacturer's cloud service, or a remote-access provider. Where you ask us to connect these, data may flow to them under their privacy terms; we are not the controller of what they do with it, and we will tell you which providers are involved in your build.
• Professional advisers such as our lawyers, accountants and insurers, where reasonably needed.
• Authorities, courts and regulators where we are required by law, or to establish, exercise or defend legal claims, or to protect the vital interests of any person.
• A buyer or successor if we restructure, merge or sell part of our business, subject to this Policy.

10. Transfers outside Nigeria

Some providers we or you use (for example certain voice-assistant, cloud-camera or remote-access services) may store or process data outside Nigeria. The NDPA allows such transfers only where there is an adequate level of protection or another lawful safeguard in place, such as an adequacy decision, appropriate contractual clauses, or your informed consent. Because our architecture is local-first, we aim to keep most of your system's data within your premises and to minimise cross-border transfer. Where a feature you select requires a transfer abroad, we will make that clear so you can decide whether to use it.

11. Cookies and similar technologies

Our website uses cookies and similar technologies to make it work, to remember your preferences, and to understand how it is used. You can control non-essential cookies through the cookie banner or your browser settings. Where required, we ask for your consent before setting non-essential cookies.

12. Your rights

Under the NDPA you have the right to:

• be informed about how we use your data (this Policy);
• access the personal data we hold about you;
• rectify data that is inaccurate, incomplete or out of date (free of charge where the error is ours);
• request erasure ("right to be forgotten") in certain circumstances;
• restrict or object to certain processing, including direct marketing;
• request portability of data you provided, in a usable format;
• withdraw consent at any time, without affecting processing already carried out; and
• not be subject to a decision based solely on automated processing that significantly affects you, and to request human review.

To exercise any right, contact our Data Protection Officer using the details in Section 1. We will respond within the time the law allows. We may need to verify your identity first. If you are not satisfied, you may lodge a complaint with us under the Standard Notice to Address Grievance (SNAG) procedure, and you may also complain to the Nigeria Data Protection Commission (NDPC) at ndpc.gov.ng.

13. Automated decision-making

We do not use your personal data to make decisions about you based solely on automated processing that produce legal or similarly significant effects. Smart-home automations (for example a light turning on when a sensor triggers) operate on rules you and we configure and are not used to make decisions about you as an individual.

14. Cameras, audio and monitoring

If your system includes cameras or microphones, you (the householder or premises owner) are responsible for using them lawfully and considerately — for example, by not capturing public areas or neighbouring property without justification, and by informing people who may be recorded where the law requires. We will advise on responsible placement and configuration. Where we provide remote support, we access camera or audio feeds only with your authorisation and only as needed to do the work.

15. How we protect your data

We use appropriate technical and organisational measures to protect personal data, including a local-first design that keeps most system data in your premises, access controls, encryption where appropriate, network segmentation, secure remote-access tooling, staff confidentiality obligations, and resilience measures suited to local power and connectivity conditions. No system is perfectly secure, but we work to reduce risk and to respond quickly if something goes wrong.

16. Data breaches

If a personal data breach occurs that is likely to risk your rights and freedoms, we will notify the NDPC within 72 hours of becoming aware of it where the law requires, and we will inform you without undue delay where the breach is likely to result in high risk to you.

17. How long we keep your data

We keep personal data only for as long as needed for the purposes in this Policy — to deliver and support your system, to honour warranties, and to meet legal, tax and accounting duties — after which we securely delete or anonymise it. Operational data generated by your installed system is generally retained on equipment under your control and according to settings you choose.

18. Third-party links

Our website and your system may link to third-party sites, apps or services. We are not responsible for their privacy practices, and we encourage you to read their policies.

19. Changes to this Policy

We may update this Policy from time to time. The "Last updated" date shows the current version, and significant changes will be brought to your attention where appropriate.

20. Contact us

For any question or request about this Policy or your personal data:

Livesmart Realty NG Ltd. — Data Protection Officer. Email: hello@livesmart.ng · Phone: +234 903 948 9094 · Address: Room 104, AHCN Towers, CIPM Avenue, Ikeja, Lagos, Nigeria.

You may also contact the Nigeria Data Protection Commission (NDPC) if you believe your data-protection rights have been breached.