Privacy Policy
Overview
This Privacy Policy explains how UseLodger Technologies Limited ("UseLodger", "we", "us", "our") collects, uses, stores, and protects personal data when you use our hotel management platform at uselodger.com and associated mobile applications.
This policy complies with the Nigeria Data Protection Regulation (NDPR) 2019 issued by the National Information Technology Development Agency (NITDA) and the Nigeria Data Protection Act 2023. It applies to all users of the platform — property owners, hotel staff, and guests.
Who we are
UseLodger Technologies Limited is a Nigerian technology company registered in Lagos, Nigeria. We operate the UseLodger hotel and property management SaaS platform.
- Company name: UseLodger Technologies Limited
- Registered address: Lagos, Nigeria
- Data Protection Officer (DPO): privacy@uselodger.com
- General contact: hello@uselodger.com
- Phone: +234 801 234 5678
UseLodger is a data controller for the personal data of property owners and hotel staff who use the platform. UseLodger is a data processor on behalf of property owners for guest data collected through the booking process.
Data we collect
A. Account and profile data
When you register for UseLodger, we collect:
- Full name, email address, phone number
- Password (stored as a bcrypt hash — never in plain text)
- Profile photo (uploaded to Cloudinary CDN)
- Date of birth (for age verification)
- Gender (optional)
- Address, city, state, country
- Government ID type and number (for property owners, for identity verification)
B. Property and listing data
- Property name, address, GPS coordinates
- Property photos and videos
- Room descriptions, pricing, and availability
- Bank account details (for Paystack subaccount setup)
- Property policies and house rules
C. Booking and transaction data
- Check-in and check-out dates
- Number of guests
- Total amounts, fees, and discounts
- Payment status and method
- Booking reference numbers
- Special requests and notes
- Guest reviews and ratings
We do not store full card numbers. Card payments are handled by Paystack and Flutterwave. We only store payment confirmation references returned by those gateways.
D. Usage and technical data
- IP address and device type
- Browser type and version
- Pages visited and time spent
- Login timestamps and session tokens
- Error logs and crash reports
E. Communication data
- Support messages and emails sent to us
- Demo booking requests
- Notification preferences
How we use your data
We use personal data only for the following purposes:
To provide the platform
- Create and manage your account
- Process bookings and payments
- Send booking confirmations, receipts, and reminders
- Enable check-in and check-out flows
- Generate invoices and financial reports
- Power the AI features (smart pricing, fraud detection)
To communicate with you
- Send transactional emails and SMS via KudiSMS/Termii
- Send push notifications via Firebase FCM (if enabled)
- Respond to support and demo requests
- Notify you of product updates and policy changes
To improve the platform
- Analyse usage patterns to improve features
- Debug errors and resolve technical issues
- Train and evaluate AI pricing and fraud models (using anonymised data only)
To meet legal obligations
- Comply with NDPR 2019 and the Nigeria Data Protection Act 2023
- Respond to lawful requests from Nigerian regulatory authorities
- Maintain financial records as required by law
- Detect and prevent fraud and abuse
Data sharing
We share personal data only with the following categories of recipients and only to the extent necessary:
Payment processors
Paystack and Flutterwave receive transaction data necessary to process payments. Both are PCI-DSS compliant. Paystack processes Nigerian card transactions and subaccount settlements. Flutterwave handles pan-African and international payments.
Infrastructure providers
- Cloudinary (media storage — property photos, room images, QR codes)
- Server hosting provider (Nigerian-based VPS for API data storage)
Communication providers
- KudiSMS / Termii (SMS delivery — phone number and message content only)
- SMTP email provider (email address and message content only)
- Firebase (device token for push notifications — no personal data stored by Firebase beyond the token)
Property owners (as data controllers)
When a guest makes a booking, their name, contact details, and stay information are shared with the property owner. Property owners are responsible for handling this data in accordance with NDPR. UseLodger provides a Data Processing Agreement (DPA) on request.
Legal disclosure
We may disclose personal data if required to do so by law, court order, or a Nigerian regulatory authority (including NITDA). We will notify you of such requests unless legally prohibited from doing so.
Paystack & payment data
UseLodger uses Paystack's split payment (subaccount) feature to automatically distribute booking payments between property owners (95%) and the platform (5%).
- Property owners' bank account details (bank name, account number, account name) are stored by UseLodger and transmitted to Paystack to create a subaccount
- Card details entered by guests are processed directly by Paystack — UseLodger never receives or stores card numbers, CVVs, or PINs
- UseLodger stores only the payment reference, amount, and status returned by Paystack after a transaction
- Paystack's own Privacy Policy governs their processing: paystack.com/privacy
Data storage & security
Where data is stored
All UseLodger platform data (user accounts, bookings, financial records) is stored on servers located in Nigeria, in compliance with NDPR requirements for localised data storage. Media files (photos, videos) are stored on Cloudinary's global CDN, which includes servers outside Nigeria — this is disclosed in line with NDPR cross-border transfer provisions.
Security measures
- Passwords hashed with bcrypt (never stored in plain text)
- All data transmission encrypted via TLS 1.3
- JWT tokens with 7-day expiry and per-device session tracking
- Two-factor authentication (TOTP) available for all accounts
- Database access restricted to application layer only
- Full audit log of all data changes with user, timestamp, and IP
- Regular automated backups with encrypted storage
Security incident response
In the event of a data breach affecting your personal data, we will notify affected users within 72 hours of becoming aware, as required by NDPR. We will also notify NITDA where required.
Data retention
We retain personal data for the following periods:
| Data type | Retention period | Reason |
|---|---|---|
| Account data | Duration of account + 90 days after deletion | Service delivery |
| Booking records | 7 years | Financial/tax compliance |
| Payment records | 7 years | Nigerian tax law |
| Audit logs | 2 years | Security and compliance |
| Support communications | 2 years | Service quality |
| Usage analytics | 12 months (anonymised after 30 days) | Product improvement |
| Session tokens | 7 days or until logout | Authentication |
After retention periods expire, data is permanently deleted or anonymised. Certain financial records must be retained for 7 years under Nigerian tax law regardless of account deletion requests.
Your rights under NDPR
Under the Nigeria Data Protection Regulation 2019 and the Nigeria Data Protection Act 2023, you have the following rights regarding your personal data:
Right to access
Request a copy of all personal data we hold about you.
How to exercise: Email privacy@uselodger.com — we respond within 30 days
Right to rectification
Correct inaccurate or incomplete personal data.
How to exercise: Update directly in Account Settings or email us
Right to erasure
Request deletion of your personal data. Note: we must retain financial records for 7 years under Nigerian law.
How to exercise: Email privacy@uselodger.com
Right to data portability
Receive your data in a structured, machine-readable format (JSON or CSV).
How to exercise: Email privacy@uselodger.com
Right to object
Object to processing of your data for specific purposes.
How to exercise: Email privacy@uselodger.com
Right to withdraw consent
Withdraw consent at any time where processing is based on consent (e.g. marketing emails).
How to exercise: Unsubscribe link in every email, or Account Settings → Notifications
Children's privacy
UseLodger is not directed at children under the age of 18. We do not knowingly collect personal data from anyone under 18 years old.
If you believe a child under 18 has provided us with personal data, please contact us at privacy@uselodger.com and we will delete it promptly.
Changes to this policy
We may update this Privacy Policy from time to time. When we make material changes, we will:
- Update the 'Last updated' date at the top of this page
- Notify all registered users by email at least 14 days before changes take effect
- Post a notice on the platform dashboard
- Update the Changelog at /changelog
Continued use of the platform after the effective date constitutes acceptance of the updated policy. If you disagree with the changes, you may delete your account before the effective date.
Contact & Data Protection Officer
For all privacy-related requests, complaints, or questions, contact our Data Protection Officer:
Questions about this policy? privacy@uselodger.com
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