Privacy Policy

Effective date: June 1, 2026

Data Controller: Terralume Limited, Lagos, Nigeria

1. Introduction

Terralume Limited ("Terralume," "we," "us," "our") operates a platform across two divisions — Real Estate Acquisition & Intelligence and Renewable Energy as a Service (EaaS) — and this policy explains what personal data we collect through terralume.com and the client dashboard, why we collect it, and what rights you have under the Nigeria Data Protection Act 2023 (NDPA) and the regulations of the Nigeria Data Protection Commission (NDPC).

By submitting a property intake, an energy needs assessment, or otherwise providing personal data through our website, you acknowledge that you have read and understood this policy.

2. What We Collect

Category	Examples	Collected when
Identity & contact data	Full name, phone, email	Any intake form, contact form, account creation
Property-related data	Target location, budget, ownership purpose, timeline, financing status, title documents	Real estate intake; document vault uploads
Financial data	Budget range, financing/mortgage status, payment info where applicable	Real estate and EaaS intake; invoicing
Energy usage data	Property type, grid reliability, consumption pattern, ownership/financing preference	Energy needs assessment
Account & dashboard data	Login credentials, communication history, document access logs	Dashboard registration and use
Technical & usage data	IP address, browser/device type, pages visited, cookies	Automatically, via website use

3. Why We Collect It (Purpose & Lawful Basis)

Purpose	Lawful Basis under NDPA
To evaluate and source suitable property against our four-pillar framework	Consent / performance of a contract you have requested
To size and propose a renewable energy solution matched to your needs	Consent / performance of a contract you have requested
To manage your client file and assign you to the relevant Terralume team	Performance of a contract
To verify title and conduct financial/economic due diligence on your behalf	Consent, and where applicable, legal obligation
To communicate about your intake, proposal, or active engagement	Performance of a contract / legitimate interest
To meet regulatory, tax, and record-keeping obligations	Legal obligation
To improve the website and understand how it is used	Legitimate interest, subject to your cookie preferences

In plain terms: the information you give us is the information we use to actually find, evaluate, or build the property and energy solution you asked for. We do not sell, rent, or use your data for unrelated purposes.

4. Who We Share Data With

We share personal data only where necessary to deliver our services, with parties bound by confidentiality and data-protection obligations. Recipients include:

Title and legal verification partners
Financial institutions where you have engaged us in connection with financing
Technology and EPC partners (limited to technical specifications needed for deployment)
Regulatory bodies where disclosure is required by law (e.g. NERC, FIRS, NDPC)
Professional advisers (lawyers, auditors) where needed for a transaction or legal obligation

We do not share your data with third parties for their own marketing purposes.

5. Cross-Border Transfers

Where a diaspora client or engagement involves a party outside Nigeria, any transfer of personal data outside Nigeria will only take place in line with NDPA requirements — where the receiving country or organisation provides adequate data protection, or under appropriate safeguards and your informed consent.

6. Data Retention

Active client files are retained for the duration of the engagement and a reasonable period afterward.
Closed or inactive intake forms with no follow-through are retained for a limited period (e.g. 12–24 months) then securely deleted.
Financial and tax-relevant records are retained as required under Nigerian tax and company law.

Exact periods should be confirmed by Terralume's legal/finance team before publishing.

7. Your Rights Under the NDPA

Be informed

About how your data is collected and used (this policy).

Access

The personal data we hold about you.

Correct

Inaccurate or incomplete data.

Request erasure

Of your data, subject to our legal retention obligations.

Restrict or object

To certain processing.

Data portability

Receive your data in a structured, commonly used format.

Withdraw consent

At any time, without affecting prior lawful processing.

Lodge a complaint

With the Nigeria Data Protection Commission (NDPC).

To exercise any of these rights, contact us at info@terralume.org. We will respond within the timeframe required by the NDPA.

8. Data Security

We apply technical and organisational measures including:

Encrypted storage for sensitive documents (e.g. title documents in the document vault)
Role-based access limited to the Terralume staff handling your file
Access logging

No system is completely secure; we encourage you to safeguard your own dashboard login credentials.

9. Cookies

Our website uses cookies for core functionality and to understand site usage. You can control non-essential cookies through your browser settings or any cookie-preference tool provided on the site.

10. Children's Privacy

Our services are intended for adults entering into property and energy transactions. We do not knowingly collect personal data from minors.

11. Changes to This Policy

We may update this policy from time to time. Material changes will be notified on the website, with the effective date updated accordingly.

12. Contact

Questions, requests, or complaints:

Email:info@terralume.org

Phone:+234 704 667 6828

Working draft:This privacy policy is built around Terralume's actual data flows and the core obligations of the NDPA 2023. Have Nigerian legal counsel review data-retention periods, the NDPC complaint mechanism, and liability clauses before publishing.