Privacy Policy

Effective Date: 15 October 2026

1. Introduction

We value the trust guests and visitors place in Right Choice Apartments Nigeria Limited. This Privacy Policy explains how Right Choice Apartments Nigeria Limited (referred to as “Right Choice Hotels, Apartments and Suites”, “we”, “us” or “our”) collects, uses, discloses, retains and protects personal data in connection with our accommodation, related hospitality services and website.

It also explains the rights available to individuals under applicable Nigerian law, including the Nigeria Data Protection Act 2023 and the Nigeria Data Protection Act General Application and Implementation Directive 2025.

2. Who We Are

Right Choice Apartments Nigeria Limited is the business responsible for the personal data processed in connection with Right Choice Hotels, Apartments and Suites, located in Ado-Ekiti, Ekiti State, Nigeria. For the purposes described in this Policy, Right Choice generally acts as a data controller. Our full physical address and privacy contact details are provided in Section 19 and must be completed before publication.

3. Scope of This Policy

This Policy applies, as relevant, to guests and prospective guests; persons making reservations or enquiries; website visitors; visitors to the property; event organisers and attendees where events are offered; representatives of suppliers and partners; job applicants; and other individuals whose personal data we process in the course of our operations. Employee information may also be covered by separate internal privacy notices.

4. Categories of Personal Data We Collect

The information collected depends on your interaction with us. We collect only information appropriate for the stated purpose.

Category	Examples
Identity and contact	Full name, telephone number, email address, postal address and booking contact details
Reservation and stay	Room category (Bronze, Silver, Gold or Platinum), stay dates, guest numbers, preferences, special requests, booking references and check-in/check-out records
Identification and registration	Information from identification documents where reasonably necessary for lawful registration or security
Payments and billing	Amounts paid, payment status, transaction references, billing details, refunds and related records; payment-card data is handled by authorised payment providers
Communications	Telephone, email, WhatsApp, website forms, guest service conversations, complaints and feedback
Technical and online	IP address, browser and device information, website activity and cookie identifiers where applicable
Safety and security	Visitor logs, incident information and CCTV images where surveillance is installed and operated lawfully
Recruitment and business	Applications, qualifications and business contact information, where relevant
Sensitive data	Health, accessibility, allergy or other sensitive information voluntarily provided where needed for a specific service or emergency and lawfully processed

5. How We Collect Information

Directly from you when you enquire, make or manage a booking, check in, contact our team, submit a form or give feedback.
From authorised booking intermediaries, travel agents, corporate booking contacts and payment service providers when relevant to a reservation.
Automatically through website logs and cookies or similar technologies, in accordance with our Cookie Policy and applicable consent requirements.
At our property through guest registration procedures and, where installed, clearly notified security systems.

6. Purposes for Processing Personal Data

To receive, manage, verify and confirm reservations; prepare for arrivals; and deliver accommodation and other services requested by guests.
To process or reconcile payments, deposits, refunds and transaction records through authorised payment providers, including Paystack where offered.
To send essential reservation, payment, check-in, service and post-stay communications.
To respond to questions, feedback, complaints, disputes and customer support requests.
To administer our website, analyse its performance where permitted, improve guest experiences and prevent fraud or misuse.
To maintain safety and security, respond to incidents and comply with lawful requirements.
To administer permitted recruitment, supplier and other business relationships.
To communicate offers or promotions where we have an appropriate legal basis, including consent where required.

7. Lawful Bases for Processing

Depending on the purpose, we rely on one or more lawful bases recognised by Nigerian data protection law: performance of a contract or steps requested before a contract; compliance with a legal obligation; protection of vital interests; legitimate interests that are not overridden by the rights and freedoms of affected individuals; or valid consent. Where information qualifies as sensitive personal data, we apply the additional conditions and safeguards required by law. Consent may be withdrawn at any time without affecting prior lawful processing.

8. Reservations, Payment Platforms and Guest Communications

Reservations may be handled through our website booking system, our hotel team or authorised third-party platforms. We use booking details to manage room availability, verify reservations and communicate with guests. Online payments may be processed by a third-party authorised payment provider.

Card details entered into a payment provider’s secure payment interface are processed under that provider’s arrangements; Right Choice does not ask guests to disclose card PINs, passwords or one-time passcodes to hotel personnel.

We may receive payment confirmations, transaction references, amounts and status information needed for reconciliation and guest support.

We may use a customer relationship management and messaging platform to send transactional updates, booking confirmations, service follow-ups and feedback requests.

Promotional messages are handled separately as explained below. Where guests book through a third party, that provider may independently process their information under its own privacy notice.

9. Marketing Communications

We may send hospitality offers, event announcements or seasonal updates when permitted by law and, where required, after obtaining your consent. You may opt out through any available unsubscribe method or by contacting us. Withdrawing from marketing will not stop necessary communications concerning an active booking, payment or requested service. We will not treat acceptance of booking terms as automatic consent to unrelated marketing.

10. Cookies and Similar Technologies

Our website may use essential technologies for security, session management and booking functions, as well as optional analytics or advertising technologies. Where consent is required, non-essential technologies will not be activated until an appropriate choice has been made. The Cookie Policy and the website’s cookie controls, where implemented, explain the technologies actually in use and how to change preferences.

The Cookie Policy must be updated if the website’s tracking tools change.

11. Sharing Personal Data

We disclose personal data only when there is a legitimate operational or legal reason. Recipients may include authorised staff; website hosting and technical providers; booking, customer relationship management and communications providers; payment processors and banks; professional advisers; and regulators or law enforcement agencies where disclosure is lawful or required.

We may also disclose information to a successor entity as part of a lawful reorganisation, subject to applicable safeguards. We do not sell guest personal data. We take appropriate steps to establish confidentiality, security and data-processing arrangements with service providers where required.

12. Processing or Transfers Outside Nigeria

Certain cloud, payment, communications or reservation service providers may process or store personal data outside Nigeria. When international transfers occur, we assess the legal basis and appropriate safeguards required under the Nigeria Data Protection Act 2023 and applicable regulatory instruments. Further information about relevant transfers may be requested using the contact details in Section 19.

13. Retention of Personal Data

We retain personal data only for the period reasonably necessary for the purposes for which it was collected, taking account of legal requirements, accounting, security, dispute management and legitimate operational needs. Retention periods are set according to record type and documented in our internal retention schedule. They may be extended when required for a legal claim, investigation or statutory obligation. Data no longer needed is deleted, anonymised or otherwise securely disposed of.

Record category	Retention approach
Guest reservations and stay records	For the applicable operational, accounting and legal retention period set out in the approved internal schedule
Payment and financial records	For the period required by applicable tax, accounting and other laws
CCTV recordings, if used	For a proportionate, documented period based on security purpose, storage capacity and incident preservation needs
Marketing records	Until consent is withdrawn or the documented retention period expires; minimal suppression data may be retained to honour opt-outs
Job applications	For a documented recruitment-retention period, subject to applicable law and any relevant consent
Cookies and technical logs	As described in the final Cookie Policy and applicable system settings

14. Information Security and Data Breaches

We apply appropriate administrative, physical and technical safeguards proportionate to the risks involved, including access controls, staff confidentiality procedures, appropriate service-provider oversight and protection of guest records. No system is entirely risk-free. If a personal data breach occurs, we will assess it and make notifications to the Nigeria Data Protection Commission and affected individuals where required by law.

15. Your Data Protection Rights

Subject to applicable conditions and exemptions, you may request confirmation of whether we process your personal data, access to that data, correction of inaccuracies, erasure or restriction in appropriate circumstances, and portability where applicable.

You may object to certain processing, including direct marketing, withdraw consent where consent is the basis for processing, and exercise protections applicable to qualifying automated decisions. We may seek reasonable proof of identity before fulfilling a request and will respond in accordance with applicable law.

16. Children’s Personal Data

Our website is not designed to solicit personal data directly from children. Where a child accompanies a guest or information about a child is necessary to provide a requested service, we seek to deal with the parent or lawful guardian and follow the relevant legal requirements, including consent where applicable. We do not knowingly use children’s data for behavioural advertising.

17. CCTV and Property Security

Where CCTV is installed at our property, it is used for legitimate security, safety and incident-management purposes in appropriate areas. Notices will be displayed where required. We restrict access to recordings and retain them for a proportionate period in line with our approved retention schedule. Recordings may be shared when required by law or where another valid legal basis applies. CCTV will not be used in areas where guests reasonably expect a high degree of privacy.

18. Third-Party Websites and Services

Our website may contain links or integrations provided by third parties, such as payment pages, maps, social networks, booking channels or messaging services. These parties may operate under their own privacy notices and terms. We encourage you to review their information before sharing personal data with them.

19. Contact and Privacy Requests

Right Choice Apartments Nigeria Limited
Address: 1, Aseusi Street, Opposite Oye Jesu Blocks, Ilawe Road, Ado-Ekiti, Ekiti State
Email: info@rightchoicehotel.com
Telephone: 07046420559
Website: www.rightchoicehotel.com

Please use the subject line “Privacy Request” when emailing us about access, correction, deletion, objection or other privacy matters. If a designated data protection officer or contact is appointed, these details should be updated accordingly.

20. Complaints to the Nigeria Data Protection Commission

We encourage you to contact us if you have any concern about how your personal data is handled so that we can investigate and respond. You may also lodge a complaint with the Nigeria Data Protection Commission (NDPC), where appropriate. Information about the Commission is available at https://ndpc.gov.ng/.

21. Changes to This Policy

We may amend this Privacy Policy to reflect changes in services, technology, legal requirements or our practices.

We will update the effective date when a revised version is published. Where a change materially affects individuals, we will take reasonable steps to provide additional notice where required.