Privacy Policy

01

Who We Are

OptiaHQ Ltd ("OptiaHQ", "we", "us") provides LevyPass — a digital estate management and access control platform for residential estates in Nigeria. This platform is operated on behalf of Community Development Associations (CDAs) and estate management bodies ("your Estate").

Your primary data relationship is with your Estate's CDA admin, who manages your registration and account. OptiaHQ provides the technology platform and acts as a data processor on behalf of your Estate.

LevyPass is a product of OptiaHQ Ltd, registered in Nigeria (RC: 9128270), Lagos.

02

What Data We Collect

We collect only what is necessary to operate the platform securely. The following table describes every category of data we collect:

Data	Why We Collect It	How Long Kept
Full Name	Identity verification at the gate	Until account deleted
Phone Number	Login and emergency contact	Until account deleted
Photo	Visual identity verification at gate	Until account deleted
Unit / Building Address	Estate records and levy assignment	Until account deleted
Move-in Date	Levy calculation	Until account deleted
Household Members	Gate access for family members	Until removed by admin
GPS Location	Emergency alert only — when you press the emergency button	Automatically deleted after 1 hour
Gate Movement Log	Security audit trail	90 days rolling
Levy Payment Records	Financial records for CDA	3 years

03

What We Do NOT Collect

We are deliberate about what we do not collect. The following data is never collected by LevyPass under any circumstances:

We never collect:

National Identification Number (NIN) or any government ID numbers
Bank account details (only CDA bank details for payment reference)
Biometric data such as fingerprints or face scans
Continuous location tracking — only a single snapshot during emergencies
Social media profiles or browsing history
Data for advertising or marketing profiling of any kind

04

How We Protect Your Data

We take data protection seriously, especially given the security context of our platform. The following protections are built into LevyPass by design:

Address hidden from security officers — gate staff only see your name and levy status when verifying your gate pass. They cannot see your home address or phone number.
Emergency location auto-expires — GPS coordinates are automatically removed from our system 1 hour after an emergency alert is triggered.
Encrypted data transfer — all data is transmitted over HTTPS/TLS encryption.
Role-based access — security officers, administrators, and residents each see only what they need for their role. Nothing more.
No advertising tracking — we do not track your behaviour for advertising or share usage data with third-party marketing platforms.

⚠️ Important Note on Security Officers

Security officers at your gate can see your name and levy payment status (Fully Paid, Partially Paid, or Zero Payment) when verifying your gate pass. They cannot see your home address, phone number, or any financial amounts. This is a deliberate design decision to protect your privacy while enabling effective security.

05

Who Has Access to Your Data

Your CDA Admin — full access to manage estate records within your estate only
Security Officers — name and levy status only during gate verification
OptiaHQ Technical Team — access for platform maintenance and support only, never for commercial use

No Third-Party Data Sharing

Your data is never sold, rented, traded, or shared with advertisers, data brokers, or any commercial third parties. The only external party that handles any data is Paystack, which processes levy payments under PCI DSS compliance standards.

06

Emergency Alert Location Data

When you press the emergency button in the resident app, your device's GPS location is captured and sent to your estate's security team. This is the only time we collect your location.

Location is captured once — it is not tracked continuously
Security can only see your location for 1 hour after the alert is triggered
After 1 hour, location data is automatically and permanently removed from the system
Location is never used for any purpose other than responding to your emergency

07

Your Rights Under NDPR

Under Nigeria's Data Protection Regulation (NDPR 2019), you have the following rights as a data subject:

👁️

Right to Access

Request a copy of all personal data we hold about you at any time.

✏️

Right to Correct

Ask your CDA admin to update any inaccurate or incomplete information.

🗑️

Right to Delete

Request deletion of your account and personal data, subject to legal retention requirements.

🚫

Right to Object

Object to certain types of data processing where you have grounds to do so.

To exercise any of these rights, contact your CDA admin directly or reach OptiaHQ at the contact details below.

08

Data Retention

We keep your data only as long as necessary for its stated purpose:

Active resident records — kept while you are a registered resident of the estate
Gate movement logs — 90 days rolling; older records are automatically removed
Emergency location data — 1 hour from the time the alert was triggered
Levy payment records — 3 years for financial and compliance purposes
When you move out — your CDA admin deactivates your account; data can be deleted on request after deactivation

09

Cookies and Session Storage

The LevyPass platform uses session storage (not persistent cookies) to keep you logged in during your active session. When you close the browser or log out, your session ends and session data is cleared.

We do not use advertising cookies, tracking pixels, or third-party analytics services that share your data externally.

10

Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in the platform or applicable law. When we do, we will update the "Last Updated" date at the top of this page. Significant changes will be communicated to CDA administrators who will inform residents accordingly.

Continued use of the LevyPass platform after changes to this policy constitutes acceptance of the updated terms.

📋 Summary — What You Need to Know