PRIVACY POLICY
Sentinel Escrow
Last Updated: June 2025
1. Introduction
<b> Sentinel Escrow Limited </b> ("we," "us," or "our") is committed to protecting the privacy and security of your personal data in compliance with the Nigeria Data Protection Act (NDPA) 2023 and other applicable laws and regulations. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you use our escrow services through any of our platforms or channels. By using our services, you consent to the practices outlined and described in this policy.
2. Scope
This policy applies to:
- Clients (buyers, sellers, and agents- regardless of role or designation) using our escrow services.
- Visitors to our website or digital platforms.
- Third parties whose data we process in connection with our services.
3. Information We Collect
We may collect the following categories of personal data:
A. Personal Identification Data
- Full name, date of birth, gender, nationality.
- Government-issued ID (e.g., passport, driver’s license, NIN).
- Contact details (email, phone number, address).
- Any other information by which you may be identified to enable us render escrow and related services to you.
B. Financial and Transaction Data
- Bank account details, payment records, transaction history, amounts and date of payment and parties to such transaction.
- Tax information (where applicable).
C. Technical and Usage Data
- IP address, device information, browser type, access time and duration, pages viewed.
- Cookies and analytics data (see paragraph 7 “cookies and tracking technologies”).
D. Sensitive Personal Data (if required)
- Biometric data (for identity verification).
- Other sensitive data as permitted under Section 30 of the NDPA.
4. Lawful Basis for Processing
We process your data based on:
- Contractual necessity: To fulfill escrow agreements.
- Legal obligation: Compliance with anti-money laundering (AML) and tax laws.
- Consent: For marketing, research and other additional services (opt-in requirement fulfilled/met by your clicking the read and understood button in the terms of use).
- Legitimate interest: Fraud prevention, service improvement.
5. How We Use Your Data
Your data is used for:
- Access the personal data we hold about you.
- Facilitating and securing escrow transactions.
- Marketing communications, research, promotions and service updates.
- Internal research, general service analysis and trend analysis to improve our services and user experience.
- Customer support and dispute resolution.
- Regulatory reporting and legal compliance.
- Improve our platform’s functionality and performance.
- Improving our services (anonymized or pseudonymized where possible).
6. Data Sharing and Transfers
We may share your data with:
- Regulators: As required by Nigerian law
- Banks/Payment Processors: To complete transactions.
- Legal Authorities: For fraud investigations or court orders.
- Third-Party Service Providers: our platforms may contain third party link and we may also share your data with third parties to enable us render proper services to you, our sharing of your data with such third parties shall however be done under strict confidentiality agreements (we encourage you to review third party links privacy policy before providing your information).
Cross-border transfer of data (if applicable) will comply with Sections 41–43 of the NDPA, ensuring adequate data subject’s rights safeguards in recipient jurisdiction.
Note however, that we never sell your data to third parties and all third parties with whom we share personal data are contractually obligated to maintain data protection standards that are consistent with this Privacy Policy and the NDPA.
7. Cookies and Tracking Technologies
We use cookies to:
- Enhance website functionality.
- Analyze traffic patterns.
- You can manage your cookie preferences through your browser settings or by using any consent tools provided on our platform.
8. Data Security
We implement technical and organizational measures (encryption, access controls, audits) to protect your data per Section 39 of the NDPA. This we do in order to ensure security, integrity and confidentiality of your personal data in our possession or under our control including protections against accidental or unlawful destruction, loss, misuse, alteration, unauthorized disclosure, or access.
9. Data Retention Policy
We retain your data for as long as is necessary to fulfill the purpose for which it was collected, including any legal, regulatory, tax, accounting, or reporting requirements.
10. Your Rights Under the laws
You have the right to:
- Access, correct, or delete your data
- Right to be Informed about how their personal data is being collected, used, and processed (this we have done by this privacy policy- please refer to preceding paragraphs).
- Withdraw consent.
- Object to processing.
- Right to data portability.
- Right to object to decisions based solely on automated processing, including profiling, and to have your personal data subject to human intervention.
- Lodge complaints with the Nigeria Data Protection Commission (NDPC). If you have any questions about your data rights or how your data is being handled, you may contact our Data Protection Officer at support@sentinelescrow.com
11. Updates to This Policy
We may update this policy periodically. Changes will be posted on our website with a revised effective date.
12. Data Retention Policy
If you have any questions about your data rights or how your data is being handled, you may contact our Data Protection Officer at support@sentinelescrow.com
