UPWARD
GET STARTED

Legal

Privacy Policy

Last updated: August 24, 2026

UPWARD BY LIVEABLE SMARTCITY TECHNOLOGIES LIMITED — PRIVACY POLICY

Upward by Liveable Smartcity Technologies Limited (hereinafter referred to as “Upward” or “Company”) is committed to safeguarding your privacy and protecting your Personal Data. This Privacy Policy outlines how we collect, use, store, and disclose Personal Data in the course of operating our platform (collectively, our Services).

This Privacy Policy applies to information collected through our website, subdomains, platforms, and other channels related to our Services. By accessing or using our Services, you confirm that you have read, understood, and agree to the collection, use, Processing, and disclosure of your Personal Data as described in this Privacy Policy and in accordance with our Terms of Service.

This Privacy Policy explains how Upward by Liveable Smartcity Technologies collects and Processes your Personal Data that we collect and the measures we have in place to ensure the confidentiality of your Personal Data.

1. Definitions and key terms

To help you understand this Privacy Policy clearly, the following defined terms are used throughout:

  • Cookie: A small piece of data stored on your web browser by a website. Cookies help us recognize your browser, collect analytics, and remember preferences (like language or login information) to enhance your experience on our website.
  • Company: When this Privacy Policy mentions “Company”, “we”, “us” or “our” it refers to Upward by Liveable Smartcity Technologies, which is responsible for your Personal Data under this Privacy Policy.
  • Contact Data: Includes information such as your address (billing and operational), email address, and telephone numbers provided to us when engaging our Services or making inquiries.
  • Country: Refers to the Federal Republic of Nigeria, being the domicile of Data Subjects, whose Personal Data is processed.
  • Customer: Refers to any company, organization, or individual who engages Upward by Liveable Smartcity Technologies for its Services.
  • Data Protection Laws: Means the Nigeria Data Protection Act, 2023, the Nigeria Data Protection Act General Application and Implementation Directive, 2025, and any other ancillary laws regulating the use of Data in the Country.
  • Data Subject: Any identifiable natural person whose Personal Data is collected, stored, transmitted, or otherwise Processed by Upward in the course of its business operations.
  • Device: Any internet-enabled equipment such as a smartphone, computer, tablet, or any other device used to interact with our Services or platforms.
  • Identity Data: Includes personal identifiers such as your full name, gender, date of birth, identification number, and other similar information.
  • IP address: Means a unique string of numbers assigned to your device when it connects to the internet. It may indicate the geographic location of the device accessing our systems or Website.
  • NDPC: Refers to the Nigeria Data Protection Commission, the regulatory body overseeing data protection and privacy compliance in the Country.
  • Personnel: Refers to individuals employed by Upward by Liveable Smartcity Technologies or contracted to provide services on Upward by Liveable Smartcity Technologies’s behalf, including software engineers, consultants, or support staff.
  • Personal Data: Any information relating to an identified or identifiable natural person.
  • Processing, Process, or Processed: means any activity that involves the use of Personal Data or as the Data Protection Laws may otherwise define processing, processes or process. It includes any operation or sets of operations which are performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction. Processing also includes transferring Personal Data to third parties but does not include the mere transit of Personal Data originating outside the Country.
  • Services: Refers to the suite of enterprise AI data and insight solutions provided by Upward and related support services.
  • Technical Data: Includes information such as your IP address, login data, browser type and version, time zone setting, device model, platform, and technology used to access our website or systems.
  • Website: Liveable Smartcity Technologies’s website
  • You: Refers to the individual or entity (e.g., client, visitor) who interacts with Us or uses our Services and whose Personal Data may be collected or processed by us.

2. Our Objectives

  • To empower the individual: Upward by Liveable Smartcity Technologies wants you to be in charge of your Personal Data and to make your own voluntary choices about how your information is used.
  • To keep and secure Personal Data: We do not take your trust in us for granted. We take full responsibility for ensuring that strong security measures are in place to keep your Personal Data safe across all our technology.
  • To be transparent and to educate Users: We want you to easily understand what Personal Data we collect, how we collect it, why we need it, and how we protect it.
  • To abide by local laws: Our privacy practices are tailored to meet the specific legal and privacy requirements of every community and region where we operate.
  • To keep Personal Data up to date: We take active steps to make sure the Personal Data we hold is kept accurate and correct.
  • Only collecting what we actually need: We only collect the Personal Data that is absolutely necessary to make our services work for you. When we store or keep your data, we only do so for as long as local laws require or permit.

3. Who We Are and How to Contact Us

Upward by Liveable Smartcity Technologies, with its business address at NITDA Hub, 6 Commercial Rd, University of Lagos, Lagos State, is committed to protecting your privacy. This Privacy Policy is issued by Upward by Liveable Smartcity Technologies in its individual capacity. If, in the future, operate through subsidiaries, affiliates, or other related entities, references to “we”, “us” or “our” in this Privacy Policy will be deemed to include such entities where applicable.

Upward by Liveable Smartcity Technologies is the controller and processor and is responsible for your Personal Data.

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact the DPO using the information set out below:

Email address: hello@goodtenants.africa
Postal address: NITDA Hub, 6 Commercial Rd, University of Lagos, Lagos State

4. What Personal Data Do We Collect?

We collect Personal Data from you when you interact with us, such as when you visit our website, complete an inquiry or registration form, request our Services, integrate your system into our platform to access our Services, subscribe to our communications, or participate in a survey. The Personal Data we collect may include your full name, email address, phone number, company name, job title, and location (city/country). Personal data collected may also include financial data, marketing and communications data, log/technical data, etc.

In addition to personal and technical data, we may collect banking details, financial background information, government-issued identification, and risk profiles required to facilitate third-party banking and insurance services on your behalf.

In the course of delivering our Services, we may also collect additional information necessary for service delivery or compliance with legal obligations.

5. Why Do We Collect the Information We Collect?

We collect the information to process your data based on the following:

  • Because you have granted us consent to do so.
  • Because we require it to perform our obligations under our terms and conditions and other contractual obligations.
  • To facilitate account opening, identity verification, and onboarding with our financial, banking, and insurance partners upon your request or election to use integrated financial tools.
  • To comply with legislative and regulatory requirements, especially as it relates to taxation and social security contributions.
  • For our legitimate interest.
  • To protect your vital interests; or
  • For public interest.

6. How Do We Use the Personal Data We Collect?

The Personal Data we collect from you may be used in the following ways:

  • To deliver our Services effectively: Your information enables us to provide tailored suite of enterprise-AI data and insight solutions.
  • To personalize your experience: We use your Data to better understand your specific needs and preferences, so we can offer relevant services and support.
  • To improve our offerings: Feedback and data you provide help us refine our Services, digital platforms, and user experience.
  • To enhance customer support: Your information helps us respond more efficiently to inquiries, requests, or service-related issues.
  • To administer surveys or Service reviews: This helps us gain insights into client satisfaction and areas for improvement.
  • To communicate with you: We may use your contact details to send you Services updates, newsletters, promotional content (where permitted), or respond to inquiries.

7. How Do We Use Your Email Address?

By submitting your email address on this Website, you agree to receive emails from us. You can cancel your participation in any of these email lists at any time by clicking on the opt-out link or other unsubscribe option that is included in the respective email. We only send emails to people who have authorized us to contact them, either directly, or through a third party. We do not send unsolicited commercial emails.

By submitting your email address, you also agree to allow us to use your email address for customer audience targeted on sites like Facebook, where we display custom advertising to specific people who have opted in to receive communications from us.

8. Sharing Information with Third Parties

We may engage trusted third-party service providers to support the delivery of our Services, including but not limited to website hosting, server maintenance, data storage and management, email communication, analytics, and customer support. Where necessary, we may share your Personal Data and, in some cases, non-Personal Data with these service providers to enable them to perform such tasks on our behalf.

We share your Personal Data with licensed banking institutions, payment service providers, and insurance partners for the purpose of opening bank accounts, onboarding and identity verification, and onboarding requested by or offered to you through the Platform.

For analytics and Service improvement, we may share anonymized or aggregated usage Data, such as IP addresses or browser types, with third-party analytics partners. This information may be used to help us understand user behaviors, optimize our digital platforms, and evaluate Service performance.

We may disclose your Personal Data or non-Personal Data where we believe it is necessary or appropriate to:

  • Comply with applicable laws, regulations, or legal processes (such as court orders or subpoenas).
  • Respond to lawful requests from government or law enforcement agencies.
  • Protect the rights, property, or safety of Upward by Liveable Smartcity Technologies, our users, our Personnel, or others.
  • Detect, investigate, and help prevent fraud or other illegal activity.

We require all third parties with whom we share your Personal Data to respect its confidentiality and to process it in accordance with applicable Data Protection Laws. They are not permitted to use your Personal Data for their own purposes and are only authorized to process it as instructed by Upward by Liveable Smartcity Technologies and solely for specified and legitimate purposes.

If Upward becomes involved in a merger, acquisition, or any form of sale of some or all of its assets, we may share your Personal Data with parties involved in the transaction and any entity that acquires our business will continue to process your Personal Data in line with this Privacy policy, or a revised version that we will communicate to you.

9. Where and When Information is Collected

We will collect the personal information that you submit to us including:

  • Your direct disclosures to us when you are onboard on our platform or access our website.
  • Your personal information disclosed from the use of our Services, primarily in relation to customer accounts, administrators, and team members on our platform.
  • Your communication to us through our customer support channels, email, chat, telephone, or any other means.
  • Your reading of our emails or notices, online research on social media and websites which may not be publicly available.
  • When you apply for employment opportunities, we advertise.
  • When you register for and attend our webinars, events or online discussions.
  • Investigations on publicly available databases in furtherance of our compliance obligations.
  • Your participation in surveys which we make available to you, for competitions and promotions.
  • Third parties such as regulatory and enforcement agencies, and other public sources.

10. Security of Your Information

We take precautions to protect the security of your information. We have physical, electronic, and managerial procedures to help safeguard, prevent unauthorized access, maintain data security, and correctly use your Personal Data. However, neither people nor security systems are foolproof, including encryption systems. In addition, people can commit intentional crimes, make mistakes, or fail to follow policies. Therefore, while we use reasonable efforts to protect your Personal Data, we cannot guarantee its absolute security.

11. Legal Rights and Control

You have the right to request access, correction, erasure, or restriction of processing your Personal Data. Specifically:

  • Right to be informed: You have the right to be informed about how and why we collect, process, and store your data. This Privacy Policy explains our privacy practices.
  • Request access: Commonly known as a “Data Subject Access Request”. This enables you to receive a copy of the Personal Data we hold about you.
  • Request correction: This enables you to have any incomplete or inaccurate Personal Data we hold about you corrected.
  • Request erasure: This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to Process it.
  • Object to processing: Where we are relying on a legitimate interest and there is something about your situation that impacts your fundamental rights and freedoms.
  • Request restriction: This enables you to ask us to suspend the Processing of your Personal Data in certain scenarios.
  • Request transfer: We will provide your Personal Data in a structured, commonly used, machine-readable format.
  • Withdraw consent: At any time where we are relying on consent to Process your Personal Data.

12. Data Utilization

  • Scope of Data Utilization: By registering an account and using the Platform, you acknowledge and agree that Upward collects and processes your personal data, rental history, payment data, and transaction metadata. This data is processed to build credit/tenant profiles, conduct risk assessments, and facilitate automated decision-making processes.
  • Purpose and Impact: Automated decision-making and profiling are utilized to streamline tenant screening, evaluate transaction risks, and improve platform functionality.
  • Proprietary Insights and Rights: All algorithmic outputs, risk scores, aggregated datasets, and models developed through the processing of your data are the sole intellectual property of Upward. Processing your data for these analytics and automated decisions does not confer on you any right to financial compensation, equity, royalties, or future commercial benefits.
  • Right to Request Information and Human Review: In accordance with the Nigeria Data Protection Act (NDPA) 2023, you retain the right to request information regarding the logic involved in automated decisions affecting you, as well as the right to request human review where an automated decision produces significant legal or contractual effects.

13. Remedies for Breach

In the case of a breach, a data breach procedure is established and maintained. We will investigate to determine if an actual breach has occurred and will take the actions required to manage such breach.

In the event you believe we have breached any applicable law or this Privacy Policy, you have the right to file a complaint with the Nigeria Data Protection Commission. You may, however, contact our DPO to enable us to rectify such breach as soon as possible.

14. Cross-Border Transfers

Information collected via our website may be transferred from time to time to our offices or Personnel or to third parties located throughout the world. Whenever we transfer your Personal Data out of the Country, we ensure a similar degree of protection is afforded to it by ensuring at least one of the safeguards is implemented as required by the NDPC.

15. Data Retention

We may retain personal data for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable laws and regulations. We may also retain personal data for longer periods if:

  • Required by law or regulation.
  • Necessary for litigation or dispute resolution.
  • Needed to enforce our terms and conditions or protect our rights.

When personal data is no longer required, we will securely delete or anonymize it.

16. Amendment to Privacy Policy

We shall communicate any changes in its privacy policy with reasonable dispatch. Such changes may be communicated by either of the following ways:

  • Posting a notice on our website or mobile app
  • Sending an email to the email address associated with your account
  • Displaying a prominent notice within our Services
  • Using other communication channels, we deem appropriate

The privacy notice shall reflect the changes in the Privacy policy as well as the effective date of such changes.

Questions About This Privacy Policy

If you have any questions about this Privacy Policy or our privacy practices, you can contact us at: hello@goodtenants.africa.