Privacy policy
Proposed effective date 27 July 2026
Draft — not yet in force
It is accurate about what the platform does today, but it has not yet been reviewed by counsel. We are publishing it now because it describes what actually happens today, and you should be able to read that before it is finalised.
This policy explains what JIMO collects about you, why, who else sees it, and what you can make us do about it. It covers jimorealestate.com and the JIMO API.
JIMO is a property marketplace. We connect people looking for property in Nigeria with the agents and developers selling it. We are the data controller for the information described here, and you can reach us about any of it at privacy@jimorealestate.com.
It is longer than we would like, because being short would mean leaving things out. If you only read one section, read section 4 — advertising and analytics, which is the part most people would not otherwise expect.
1.What we collect
Things you type in.
| When | What |
|---|---|
| Creating an account | Your name, email address, phone number and password. Your state, if you give it. |
| Filling in your profile | Street address, LGA and state, a profile photo and a cover photo. |
| Signing in with Google | Your name and email address from your Google account. We never receive your Google password. |
| Applying to be an agent | Your licence number, agency name, specialisations, years of experience and a short bio — plus identity and licensing documents you upload for verification. |
| Enquiring about property | On the "can't find what you need" form: your name, email, phone, budget range, preferred location and what you are looking for. You do not need an account to send one. |
| Joining the mailing list | Your email address, and your name and phone number if the form asked for them. |
| Using the platform | Offers you make, inspections you book, reviews you write, and your messages with agents. |
| Asking JIMO AI | Your questions to the assistant, and the searches it runs on your behalf. |
Things we record as you use the site. Which listings you view and when, what you search for, which pages you open, what you save and unsave. When you view a listing we also record the IP address the view came from, so that ten refreshes of the same page do not read as ten buyers to the agent.
Things your browser sends. Your IP address, browser and device type, and the page you arrived from. If you reached us through an advert or a campaign link, the tracking parameters on that link (`utm_source`, `utm_medium`, `utm_campaign`, and similar).
We do not ask for and do not want your bank details, card numbers, BVN or NIN. JIMO never handles money. No payment for a property goes through this platform, so if anything on JIMO asks you to pay for a property here, it is not us — tell us at support@jimorealestate.com.
2.Why we use it, and what entitles us to
Under the Nigeria Data Protection Act 2023 we need a lawful basis for each purpose, not one blanket permission. Ours are:
| What we do with it | Why we are allowed to |
|---|---|
| Run your account, show you listings, pass your offers and enquiries to agents, deliver your messages | Performance of our contract with you — this is the service you signed up for. |
| Send you verification emails, password resets, and notices about your offers, inspections and messages | Performance of our contract. You can turn off the optional notification emails in your settings; you cannot turn off the security ones, because they are how you keep control of the account. |
| Verify that an agent is who they say they are, before letting them list | Legal obligation and substantial public interest — property fraud is the main harm this platform could enable, and checking is how we prevent it. |
| Detect abuse, fake listings, scraping and account takeover; keep security logs | Legitimate interests — ours and every other user's, in a platform that is not a fraud vector. |
| Count listing views and produce aggregate market figures | Legitimate interests — agents need to know how their listings perform, and nothing we publish identifies a viewer. |
| Keep records of completed sales, offers and inspections | Legal obligation — record-keeping under the Money Laundering (Prevention and Prohibition) Act 2022 and tax law. |
| Measure how the site is used (analytics) | Your consent, given through the cookie banner. Withdraw it any time on the cookie page. |
| Share what you do here with advertising platforms | Your consent, given separately from analytics. Withdraw it any time on the cookie page. |
| Send you marketing emails | Your consent. Every one has an unsubscribe link and it works. |
Where we rely on consent, refusing costs you nothing. The site works identically whether you accept or reject — no feature is withheld, and we do not ask again on every visit.
3.Who else sees it
Other people on JIMO. Some of what you do here is visible by design, and it is worth being precise about which:
- Agents you contact see your name, your message, and the offer or inspection you submitted. If you have added a phone number to your profile, they see that too — it is how they call you back.
- Anyone visiting the site sees reviews you publish, with the name on your profile. Reviews are public. If you would rather not be identified by a review, do not publish one.
- Anyone visiting the site sees an agent's profile, listings, ratings and reviews in full. If you have an agent account, your professional details are public — that is what the account is for.
- Nobody sees your saved properties, saved agents, saved articles, browsing history, or your enquiries. Those are yours.
JIMO staff. Our support and moderation staff can read message threads, enquiries and reviews when they are investigating a report, a dispute or suspected fraud. They can see your profile details. They cannot see your password — we only ever store a one-way hash of it, and we cannot recover it either.
Our own infrastructure. The database holding everything described in this policy runs on servers JIMO controls in the European Union — not on a third-party managed database service. The same is true of the short-lived cache that holds JIMO AI conversations. No outside company has standing access to either. See section 7 for what that means for you.
Companies that process data for us. Each is contractually limited to what we instruct and cannot use your data for their own purposes:
| Who | What they do, and what they get |
|---|---|
| Cloudinary (image hosting) | Stores and resizes profile photos, cover photos, listing photos and uploaded documents. United States. |
| Google (sign-in) | If you use "Sign in with Google", Google confirms your identity to us. Google's own handling of that is governed by their privacy policy, not ours. |
| Google (Places API) | We ask Google what schools, hospitals and transit stops are near a property. We do not send your location or identity — the query is about the listing, not about you. |
| Microsoft Azure OpenAI, or Groq | Runs the JIMO AI assistant. Receives your question and the recent conversation, and returns an answer. See section 6. |
| Our email provider | Delivers verification, password reset, notification and marketing emails. Receives your email address and the message. |
| Advertising and analytics platforms | See section 4 — this one deserves its own section. |
Authorities. We will hand over data when the law requires it — a court order, a lawful request from the NDPC, or a genuine police investigation. We check that the request is valid before complying, and we tell you unless we are legally barred from doing so.
A buyer of the business. If JIMO is acquired or merged, your data moves with it. Whoever holds it would be bound by this policy until they gave you notice of a different one.
We do not sell your personal data. We also do not share it with data brokers or list-rental businesses. Section 4 describes advertising platforms, which is not the same thing — but read it and judge for yourself.
4.Advertising and analytics
This is the part that differs from what most people assume, so here is exactly how it works.
If — and only if — you agree, we tell advertising and analytics platforms about certain things you do on JIMO: signing up, joining the mailing list, sending an enquiry, booking an inspection, viewing a listing, running a search. The platforms are:
- Google Analytics — audience measurement. Governed by the *Analytics* choice.
- Meta (Facebook and Instagram), TikTok, LinkedIn, X, and Snapchat — advertising measurement and remarketing. Governed by the *Advertising* choice.
What each event contains. Your email address, phone number, name and JIMO account ID are hashed first — converted to an irreversible fingerprint using SHA-256, so the platform can recognise a customer it already knows without receiving your actual address. Your IP address, browser and the page URL are sent as they are, not hashed, because the platforms use them to match the event to a person and to discard duplicates.
Be clear-eyed about what hashing does. It stops a platform reading your email address; it does not stop a platform that already holds your email address from recognising you. Hashed identifiers are still personal data, and we treat them as such. If that trade is not one you want to make, choose Reject all — nothing on the site changes.
These events are sent by our server, not your browser. That is unusual enough to spell out: an ad blocker or a tracker-blocking browser will not stop them, because they do not travel through your browser at all. Your choice on the cookie banner is the control that works, and it works because our API refuses to contact a platform whose category you have not agreed to. It is enforced on our side, not left to the browser to respect.
Until you choose, nothing is sent. Not to any of the seven platforms. The banner is not a notice that tracking has started — it is the question asked beforehand.
Changing your mind takes effect immediately, on the cookie page. We cannot claw back events already delivered — no one can — so withdrawing consent stops future sharing rather than undoing past sharing. To reach what a platform already holds, you will need to ask that platform.
6.JIMO AI
The assistant answers questions about listings and the market. Here is what happens to what you type into it.
- Your question and the recent conversation go to our model provider — Microsoft Azure OpenAI or Groq — which returns an answer. Nothing else about your account goes with it.
- Your conversations are not used to train anyone's model. Our agreements with these providers prohibit it.
- The transcript is held in a temporary cache for 24 hours and then gone. It is not stored in our database, which is also why it cannot appear in a data export — by the time you request one, it no longer exists.
- When the assistant does something on your behalf — running a search, fetching a listing — we do log which action it took and with what arguments, for up to 24 months. That log is how we debug wrong answers, and you can see it in your data export.
The assistant can be confidently wrong. It is not a valuer, an agent, a lawyer or a tax adviser, and neither are the market figures on the site. Check anything that matters before you act on it — see the terms.
7.Where your data goes
JIMO is a Nigerian business serving a Nigerian market, but the infrastructure it runs on is not in Nigeria — so being straightforward about where your data physically sits matters.
Our own servers are in the European Union. The database holding everything in this policy, and the short-lived cache holding JIMO AI conversations, both run there on machines we control. Practically, that means your data sits inside one of the strictest data protection regimes there is: the operators of that infrastructure are bound by the EU General Data Protection Regulation, and so are we in respect of the processing we carry out there.
Our third-party processors are in the United States: image hosting (Cloudinary), the AI model provider, and every advertising and analytics platform in section 4. Google operates globally.
So your data is transferred outside Nigeria. Section 41 of the NDPA 2023 permits that where adequate protection is in place. For our EU infrastructure we rely on the adequacy of the EU regime; for the US processors we rely on their standard data protection terms, incorporating the European Commission's Standard Contractual Clauses where they apply.
If you are in the EU or the UK, the GDPR gives you rights that closely mirror the ones in section 9 — access, rectification, erasure, portability, objection and restriction. Use the same address and we will handle your request under whichever regime gives you more, not less.
You are entitled to see the safeguards we rely on for a specific recipient. Ask at privacy@jimorealestate.com and we will tell you.
8.How long we keep it
We keep things for as long as we have a reason to, and no longer. When the reason expires, so does the data.
| What | How long |
|---|---|
| Your account and profile | While the account is open. Deleted or anonymised when you close it — see section 9. |
| Saved properties, saved agents, saved articles | Until you unsave them, or you close your account. |
| Messages with agents | 6 years from the last message, then deleted. Kept this long because they are the record of what was agreed if a dispute arises later. |
| Offers and inspection bookings | 6 years from creation. |
| Completed sales | 7 years from the sale date. This one we cannot shorten on request — it is a statutory record-keeping period. |
| Agent verification documents | 6 years after the agent account closes, or 6 months after a rejected application. A rejected applicant's ID documents are not something to keep. |
| Reviews you publish | Until you delete them, or you close your account. |
| Listing view records (including IP address) | 12 months, then deleted. The aggregate view count on the listing survives; the individual records behind it do not. |
| Activity log (pages, searches, saves) | 14 months. |
| AI assistant conversation transcripts | 24 hours. |
| AI assistant action log | 24 months. |
| Property enquiries from the "can't find what you need" form | 24 months from the last contact about it. |
| Mailing list entries | Until you unsubscribe, then a suppression record — your email address and nothing else — kept indefinitely so we do not accidentally add you back. |
| Notifications | 12 months. |
| Security, error and email delivery logs | 90 days. |
9.Your rights, and how to use them
Under the NDPA 2023 you have the rights below. Two of them you can exercise yourself, right now, without asking us — which we think is how it should be.
See everything we hold about you. Go to Settings → Your data and download it. You get a JSON file covering your profile, saved items, reviews, offers, inspections, sales, your message threads, enquiries, notifications, the activity log, the listings you have viewed, AI assistant actions and mailing-list entries. It is generated on the spot from the live database, not assembled by hand later.
Delete your account. Also in Settings → Your data. It happens immediately and cannot be undone. What that does precisely:
| Outcome | What it applies to |
|---|---|
| Deleted outright | Saved properties, saved agents, saved articles and insights, notifications, your activity log, reviews you wrote, your property enquiries, your mailing-list entries, and your AI assistant history. |
| Stripped of your identity | Listing view records — the count stays on the listing, your identity and IP address are removed from it. |
| Kept, with your identity removed | Offers, inspection bookings, completed sales, and message threads. Your name, email, phone and address are erased from all of them. |
We are keeping some things and you should know why. A completed sale is the agent's record as much as yours and carries a statutory retention period. A message thread with your name removed is still legible to the agent who was in it — deleting one side of a conversation would destroy their record of what was agreed. If you need something in that last row gone as well, write to us: some of it we can do, and where we cannot we will tell you which law stops us.
Agent and staff accounts cannot be deleted from the settings page. Live listings, verification documents and commission records have to be reassigned first, and that needs a person. Email us and we will handle it.
You also have the right to correct anything wrong (most of it you can edit in your profile), to object to processing based on legitimate interests, to withdraw consent for analytics and advertising at any time on the cookie page, to ask us to restrict processing while a complaint is open, and to receive your data in a portable format — which the export already is.
To exercise anything not available in your settings, email privacy@jimorealestate.com. We reply within 30 days, and sooner where we can. We may ask you to confirm your identity first — not as an obstacle, but because handing your file to someone impersonating you would be the worse failure.
If we get it wrong, complain to us first and we will try to fix it. You can also complain directly to the Nigeria Data Protection Commission at ndpc.gov.ng, and you do not need our permission to do so.
10.How we protect it
- Passwords are stored as bcrypt hashes. We cannot read them, and neither can an attacker who takes the database.
- All traffic to the site and the API is encrypted in transit (HTTPS/TLS).
- Sign-in sessions use short-lived tokens — 15 minutes — refreshed in the background, so a stolen token has a small window. A refresh token can be used once, then it is dead.
- Access to production data is limited to the staff who need it, and staff actions on accounts, listings and reviews are logged.
- Agent verification documents are held separately from public profile data.
Two honest caveats. Sign-in tokens are held in your browser's local storage, which means a malicious script on the page could read them — we mitigate that by controlling what runs on the page, but it is a weaker position than a cookie the browser will not hand to scripts, and we are moving to that. And no system is unbreachable. If a breach affects you, we will tell you and the NDPC within 72 hours of finding out, and we will tell you what we know rather than waiting until we know everything.
11.Children
JIMO is for adults. You must be 18 or over to create an account, which is also a condition of the terms of service. We do not knowingly collect data about children, and we do not profile anyone as a child or an adult.
If you believe a child has created an account, tell us at privacy@jimorealestate.com and we will remove it.
12.Changes to this policy
When we change how we use your data, we change this document, and the dates at the top tell you when.
For a material change — a new purpose, a new category of recipient, a longer retention period — we will email registered users at least 14 days before it takes effect, so the notice arrives while you can still act on it. For corrections and clarifications we will update the page and the date.
If the categories on the cookie banner change, we ask again. Consent to one set of purposes is not consent to a different set.
13.Contact us
About your data or this policy: privacy@jimorealestate.com
About anything else: support@jimorealestate.com
Supervisory authority: Nigeria Data Protection Commission, ndpc.gov.ng
A person reads that first address, not a ticket queue. If you have a question about something in here that does not make sense, ask — the answer is also useful to us, because it means this document was not clear enough.