ConfirmBase Privacy Policy
Effective date: 17 October 2026 · Last updated: 17 October 2026 · Version: 1.0
1. Introduction and scope
ConfirmBase ('we', 'us', 'our') is a rental discovery and verification service for the Kubwa area of Abuja, Federal Capital Territory, Nigeria. Our purpose is to help tenants view only the properties worth inspecting, and to connect them with verified agents and landlords.
This Privacy Policy explains how we collect, use, store, share and protect your personal data when you visit our website, join our waitlist, communicate with us, or participate in our WhatsApp communities. It is issued in accordance with the Nigeria Data Protection Act 2023 ('NDPA') and the regulations, directives and guidance issued by the Nigeria Data Protection Commission ('NDPC'), including the General Application and Implementation Directive, and any other applicable Nigerian law.
This Policy applies to:
- Tenants and prospective tenants who join our waitlist or use our service; and
- Agents, landlords and property managers who register their interest or submit listing information.
By submitting your details on our waitlist form, you confirm that you have read and understood this Policy. Where we rely on your consent, that consent is requested separately and clearly at the point of collection.
2. Who we are (Data Controller)
| Data Controller | ConfirmBase, a company incorporated in Nigeria |
|---|---|
| Location | Abuja, Federal Capital Territory, Nigeria |
| Privacy contact | hello@getconfirmbase.com |
We determine the purposes and means of processing the personal data described in this Policy and are responsible for its lawful handling.
3. Personal data we collect
We collect only the data we need for the purposes set out in this Policy (data minimisation).
3.1 Tenants and prospective tenants
| Category | Examples | Source |
|---|---|---|
| Identity and contact data | Name (if provided), WhatsApp phone number, email address | You, via the waitlist form |
| Rental preferences | Budget range, move-in timeframe, preferred areas within Kubwa, property type, style or taste preferences | You |
| Deal-breakers | Red flags or conditions you want to avoid in a property | You |
| Communication data | Messages you send us by email or WhatsApp, and your confirmation and opt-in records | You and our systems |
3.2 Agents, landlords and property managers
| Category | Examples | Source |
|---|---|---|
| Identity and contact data | Name, WhatsApp phone number, email address, business name | You |
| Professional data | Your role (agent, landlord, manager), approximate number of listings, areas covered | You |
| Listing and verification data | Listing details and evidence you provide so we can confirm a listing is genuine | You and, where applicable, third-party verification checks |
3.3 Technical data
When you use our website we may automatically collect your IP address, browser and device type, referring page, date and time of submission, and basic usage data. This is used for security, fraud and spam prevention, and service improvement (see Section 13).
3.4 Duplicate prevention
To keep our waitlist accurate and prevent duplicate or fraudulent sign-ups, we standardise (normalise) phone numbers and email addresses before storing them, and use them to detect repeat submissions.
4. Sensitive personal data: please do not submit it
The NDPA treats certain information as sensitive personal data, such as data about your health, religion or belief, ethnic or racial origin, political opinions, sexual life, genetic or biometric data, and similar categories.
Our forms include free-text fields (for example, 'deal-breakers' or 'taste'). Please do not enter sensitive personal data in these fields. We do not seek sensitive personal data, and we do not use any such data to match, rank or exclude any person. If you do volunteer it, we will delete it where practicable, or process it only as permitted by law.
ConfirmBase does not support discriminatory preferences. We reserve the right to disregard requests that discriminate against people on unlawful or unfair grounds.
5. Why we use your data and our lawful bases
Under Section 25 of the NDPA, we process personal data only where a lawful basis applies. Our purposes and bases are:
| Purpose | Lawful basis (NDPA s.25) |
|---|---|
| Adding you to our waitlist and sending you launch updates about ConfirmBase | Consent, s.25(1)(a). You opt in on our waitlist form, and may withdraw at any time |
| Sending your confirmation email, onboarding guidance and service messages | Steps at your request before entering into a contract, s.25(1)(b)(i) |
| Curating rental matches based on your stated budget, timeframe, areas and deal-breakers | Consent, s.25(1)(a), and steps at your request, s.25(1)(b)(i) |
| Reviewing agent and landlord requests, verifying listing authenticity, and connecting them with verified tenants | Legitimate interests, s.25(1)(b)(v): protecting tenants from fraudulent or misleading listings, and maintaining the integrity of our service. We have assessed that these interests are not overridden by your rights and freedoms |
| Admitting you to our moderated WhatsApp community groups | Consent, s.25(1)(a), given when you choose to join |
| Preventing duplicate sign-ups, spam, abuse and fraud; securing our systems | Legitimate interests, s.25(1)(b)(v) |
| Keeping records, responding to regulators, courts or law enforcement where legally required | Legal obligation, s.25(1)(b)(ii) |
| Backups, record keeping and disaster recovery | Legitimate interests, s.25(1)(b)(v) |
We will not use your personal data for a purpose that is incompatible with those above without telling you and, where required, obtaining your fresh consent.
6. Matching and automated processing
We use the preferences you give us to suggest properties that fit your budget, timeframe and deal-breakers. Our matching is carried out by our team, supported by software tools. Where matching is carried out by automated means, it is used only to recommend listings to you. It does not produce legal effects or similarly significant effects on you, and no decision is made solely by automated means that denies you a right or service. You may ask us for human review of any match or recommendation at any time.
7. Who we share your data with
We do not sell your personal data. We share it only as follows.
7.1 Service providers (data processors). We use trusted providers to operate our service, including cloud hosting and database providers, email delivery and communication tools, website analytics, and backup storage. They act on our written instructions, under contracts that require confidentiality, security and compliance with the NDPA.
7.2 Agents and landlords (for tenants). We share your contact details and relevant rental preferences with a verified agent or landlord only when you have agreed to be connected, or as part of a match you have asked us to make. We do not hand your data to agents in bulk.
7.3 Tenants (for agents and landlords). We may share your business name, listing details and verification status with tenants who are matched to your listings.
7.4 WhatsApp community groups. If you join our moderated Kubwa tenant or Kubwa agent WhatsApp groups, other members of the group may be able to see your name, profile photo and phone number, and any message you post. These groups are operated on WhatsApp, a service of Meta Platforms, which processes data under its own privacy policy. Join only if you are comfortable with this, and you may leave a group at any time. Group rules are shared on joining.
7.5 Legal and regulatory disclosures. We may disclose personal data where required by law, court order or a competent authority, or to establish, exercise or defend legal claims.
7.6 Business changes. If we merge with, are acquired by, or transfer our business to another organisation, your data may be transferred, and the new owner must honour this Policy.
8. Transfers outside Nigeria
Some of our service providers (for example, cloud hosting, email or messaging platforms) may process data on servers outside Nigeria. We transfer personal data abroad only where the destination provides an adequate level of protection, or where appropriate safeguards are in place (such as contractual clauses), or where another basis recognised by the NDPA applies. You can ask us for details of the safeguards we use.
9. How long we keep your data
We keep personal data only as long as necessary for the purposes described, and then delete or anonymise it.
| Data | Retention period |
|---|---|
| Waitlist data (tenants) | Until you withdraw consent, or 12 months after our public launch in Kubwa if you do not become an active user, whichever is earlier |
| Agent and landlord registration data | For as long as you remain registered, and up to 12 months after you cease to engage with us |
| Communication records | 24 months |
| Consent and opt-out records | For as long as needed to prove compliance, up to 6 years |
| Backups | Overwritten or deleted within 90 days of the source data being removed |
| Technical and security logs | Up to 12 months |
Where a longer period is required by law, we will retain only the data legally required.
10. How we protect your data
We apply appropriate technical and organisational measures, including:
- encryption of data in transit (HTTPS/TLS) and, where supported, at rest;
- restricted, role-based access, with access given only to staff who need it;
- confidentiality obligations on staff and contractors;
- secure handling of data exports (for example, CSV files), which are access-controlled, stored securely and deleted when no longer needed;
- encrypted, access-controlled backups and periodic restoration testing;
- logging, monitoring, and regular security review of our systems; and
- data protection impact assessments where processing presents high risk.
No system is completely secure. If you believe your data or account has been compromised, contact us immediately.
11. Your rights
Under the NDPA you have the right to:
- Be informed about how your data is used (this Policy);
- Access the personal data we hold about you and receive a copy;
- Rectify inaccurate or incomplete data;
- Erase your data, where there is no overriding reason for us to keep it;
- Restrict processing in certain circumstances;
- Object to processing based on legitimate interests, and to direct marketing at any time;
- Data portability, receiving your data in a structured, commonly used, machine-readable format where applicable;
- Withdraw consent at any time, without affecting the lawfulness of processing before withdrawal; and
- Not be subject to a decision based solely on automated processing that significantly affects you.
How to exercise your rights: email hello@getconfirmbase.com with the subject 'Data Request'. We may ask you to verify your identity first. We will respond within 30 days and will not charge a fee unless a request is manifestly unfounded or excessive.
Withdrawing consent or unsubscribing: use the unsubscribe link in any email, reply 'STOP' to our messages, leave a WhatsApp group, or contact us as above. Withdrawal is as easy as giving consent.
12. Children
ConfirmBase is intended for persons aged 18 and over. We do not knowingly collect personal data from children. If you believe a child has provided us data, contact us and we will delete it promptly.
13. Cookies and analytics
Our website may use cookies and similar technologies to operate, secure and improve the site. Our waitlist website currently uses only the cookies and similar technologies it needs to work and stay secure. It loads Vercel Analytics, a cookieless analytics service that records aggregate page views and does not track you across other sites, and its web fonts are self-hosted, so loading a page does not contact Google. Where we use non-essential cookies or analytics, we will ask for your consent through a cookie notice, and you can change your choice at any time through your browser settings or our cookie preferences.
14. Third-party links and services
Our website and communications may link to third-party sites or services, including WhatsApp. We are not responsible for their privacy practices; please read their policies.
15. Changes to this Policy
We may update this Policy to reflect changes in law or our service. Material changes will be notified by email or a prominent website notice, and we will request fresh consent where legally required. The 'Last updated' date above shows the current version.
16. Complaints
We would like to resolve any concern directly, so please contact us first at hello@getconfirmbase.com. You also have the right to lodge a complaint with the regulator.
17. Governing law
This Policy is governed by the laws of the Federal Republic of Nigeria.
18. Contact us
ConfirmBase, Abuja, FCT, Nigeria. Email: hello@getconfirmbase.com