Legal Document NDPA 2023 & GDPR Compliant Google Play & Apple Store Ready

Privacy Policy

This Privacy Policy explains how Pentfield Technologies collects, uses, protects, and discloses personal data across the Pentfield Hamlet ecosystem, including our mobile applications, web portals, and desktop management systems.

Publisher: Pentfield Technologies
Effective Date: September 27, 2026
Version: 2.4.0 (Annual Modern Revision)
Applicable Apps: Pentfield Hamlet Resident & Security Apps

1. Introduction & Scope

Welcome to Pentfield Technologies ("Pentfield", "we", "us", or "our"). We are committed to safeguarding the privacy, confidentiality, and security of personal information entrusted to us by our clients, facility managers, estate residents, security personnel, and visitors.

This Privacy Policy applies to personal data collected or processed through the entire Pentfield Hamlet suite, including:

By downloading, registering, accessing, or using any part of the Pentfield Hamlet platform, you acknowledge that you have read, understood, and agreed to the practices outlined in this Privacy Policy and our Terms of Service.

2. Roles: Data Controller vs. Data Processor

To ensure total transparency and statutory compliance under the Nigeria Data Protection Act 2023 (NDPA), the Nigeria Data Protection Regulation (NDPR), and international standards such as the General Data Protection Regulation (GDPR), the parties hold distinct legal roles:

Legal Designation of Roles
Data Controller: The residential estate association, property owner, facility management company, or landlord ("Hamlet Manager") that licenses the platform is the primary Data Controller. They determine what resident records, visitor logs, and fee structures are administered within their respective estate.

Data Processor: Pentfield Technologies operates strictly as a Data Processor and Software-as-a-Service (SaaS) provider. We store, transmit, and process records strictly on behalf of and according to the instructions of the respective Hamlet Manager and authorized end users.

Information you provide directly to your estate management or security personnel outside the digital Hamlet app (such as manual physical visitor registers, gate ledger sheets, CCTV surveillance systems, or tenancy leases) is governed exclusively by that estate's private policies and is outside Pentfield's direct control.

3. Information We Collect

We only collect data necessary to provide effective facility operations, robust gate security clearance, automated utility billing, and rapid emergency alerts. Data collected includes:

3.1. Information Provided Directly by Users

3.2. Information Collected via the Security App (Gate Clearance)

3.3. Financial & Payment Data

Zero Cardholder Data Storage Guarantee
Pentfield Technologies NEVER captures, stores, or processes full credit/debit card numbers (PAN), CVV/CVC codes, card expiration dates, or bank account PINs. All card payments are routed directly through PCI-DSS Level 1 certified payment processors (such as Paystack).

3.4. Technical, Device & Operational Telemetry

4. Mobile Device Permissions (Google Play & Apple App Store Disclosures)

Our mobile applications require specific Android and iOS permissions to deliver essential security and access control functionalities. Every permission is requested contextually and used strictly for stated purposes:

Swipe table horizontally to view full details
Permission Technical Identifier Purpose & Operational Justification
Camera android.permission.CAMERA Required to scan visitor QR code gate passes at the security entrance, capture user/dependent profile photos, and take pictures of maintenance defects or incidents.
Push Notifications android.permission.POST_NOTIFICATIONS Required to transmit instant alerts when a visitor arrives at the estate gate, broadcast community emergency SOS alarms, deliver gate pass approvals, and notify of payment receipts.
Photos & Storage READ_MEDIA_IMAGES
READ_EXTERNAL_STORAGE
Used to allow users to select profile pictures from their gallery and download or save payment advice receipts, digital gate passes, and estate notices in PDF or image format.
Internet & Network android.permission.INTERNET
ACCESS_NETWORK_STATE
Required to securely transmit data to the cloud, authenticate users, check real-time gate pass validity, and process dues transactions.
Flashlight android.permission.FLASHLIGHT Enables the camera flash as a torch to illuminate and scan QR codes in low-light conditions at night gate entrances.
Strict Privacy Protection Principles
• We DO NOT request background GPS location tracking.
• We DO NOT access your contacts address book, SMS inbox, or microphone.
• We DO NOT track you across other third-party websites or services.

5. How We Use Your Information (Legal Bases)

We process personal data strictly in accordance with applicable data protection laws under the following lawful bases:

6. Third-Party Disclosures & Service Providers

Pentfield Technologies does not sell, trade, rent, or lease personal information to third parties for marketing or advertising. We only share data with vetted third-party service providers who assist us in operating our platform, subject to strict confidentiality and data protection agreements:

7. Payments & Financial Security

When you make payments through Pentfield Hamlet (such as estate service charges, maintenance levies, water bills, or electricity tokens):

8. Emergency SOS Telemetry & Critical Safety Disclaimer

The Pentfield Hamlet platform includes an Emergency SOS Panic Alarm feature designed to transmit rapid visual and auditory distress alerts to on-duty estate security personnel and registered emergency contacts.

Critical Emergency Service Disclaimer
PENTFIELD TECHNOLOGIES IS A SOFTWARE COMPANY, NOT A SECURITY SERVICE PROVIDER, POLICE FORCE, OR EMERGENCY DISPATCHER.

The Emergency Alarm feature is an auxiliary electronic communication tool. It relies upon active device battery power, cellular data/Wi-Fi coverage, cloud server connectivity, and the physical vigilance of estate security guards.

PENTFIELD DOES NOT DISPATCH GUARDS, AMBULANCES, OR FIRST RESPONDERS, AND ACCEPTS ZERO LIABILITY FOR ANY DELAY, TRANSMISSION FAILURE, GUARD INACTION, THEFT, BURGLARY, ASSAULT, BODILY INJURY, OR LOSS OF LIFE. In any life-threatening situation, always contact national emergency numbers (e.g. 112 / 199 in Nigeria) and local law enforcement immediately.

9. Data Security & Technical Safeguards

Pentfield Technologies applies industry-standard administrative, physical, and technical safeguards to protect personal data against unauthorized access, loss, misuse, or alteration:

10. Data Retention & Account Deletion (Google Play & Apple Compliant)

We retain personal information for as long as your account remains active or as required to fulfill legitimate facility management purposes, resolve disputes, and satisfy statutory tax and legal obligations.

10.1. How to Delete Your Account

We empower all users with direct and autonomous control over their personal data. You may delete your Pentfield Hamlet account at any time through either of the following methods:

  1. Directly In-App: Open the Pentfield Hamlet App → Navigate to Settings → Scroll down to Delete Hamlet Account → Confirm your deletion request.
  2. Web Deletion Portal: Visit our dedicated public account deletion portal at https://hamlets-hub.com/delete-hamlet-account.html and follow the verification instructions.
  3. Support Request: Email support@pentfieldtechnologies.com from your registered email address with the subject "Account Deletion Request".

10.2. What Happens When You Delete Your Account

Upon confirmed account deletion:

Records Retained by the Estate Data Controller
Because your estate management operates as an independent Data Controller with statutory audit and legal compliance obligations, the following records will remain in the Estate's historical database:
• Official payment ledgers, receipts, and invoices for service charges or dues paid.
• Security gate records of past visitor entries and exits.
• Incident reports and emergency alarm logs associated with historical estate safety evaluations.

11. Children & Minor Dependents

The Pentfield Hamlet platform is designed for adult property owners, tenants, and facility administrators. We do not knowingly solicit or collect personal information directly from children under the age of 13 (or under 18 without parental supervision).

Any dependent profile (such as a child's name or photo added to a family household pass) may only be created and managed by an adult primary account holder who warrants that they are the legal parent or guardian. If we learn that personal data of a minor has been collected without verified parental authorization, we will promptly delete that information.

12. Your Statutory Legal Rights

Under the Nigeria Data Protection Act (NDPA) 2023, the NDPR, and international data protection laws, you possess the following rights regarding your personal data:

13. Cross-Border Data Transfers

To ensure global scalability, zero-downtime reliability, and high-speed delivery, our cloud infrastructure (Google Cloud / Firebase) leverages secure data centers located internationally. Where personal data is transferred across international boundaries, Pentfield ensures compliance with Section 41-43 of the NDPA 2023, ensuring data is hosted in jurisdictions with adequate legal protections or protected under enforceable Standard Contractual Clauses (SCCs) and enterprise data processing addenda.

14. Policy Updates & Notifications

Pentfield Technologies reserves the right to modify or update this Privacy Policy at our sole discretion to reflect enhancements in our software, operational requirements, or changes in statutory data privacy regulations. When updates are published, we will revise the "Effective Date" at the top of this document.

In the event of material changes, we will notify users through prominent notice banners within the Hamlet Mobile App, via email to registered account holders, or via our web portal. Your continued use of the Pentfield Hamlet platform after any revisions signifies your acceptance of the updated Privacy Policy.

15. Contact & Grievance Redressal

If you have questions, inquiries, concerns, or requests regarding this Privacy Policy, our data protection practices, or wish to exercise any of your statutory data rights, please contact our designated Data Protection team:

Pentfield Technologies Privacy & Data Protection Office
Entity: Pentfield Technologies Limited
Support Email: support@pentfieldtechnologies.com
Privacy & DPO Inquiries: privacy@pentfieldtechnologies.com
Official Website: pentfieldtechnologies.com
Hamlet Hub: hamlets-hub.com

By using Pentfield Hamlet, you affirm your commitment to maintaining estate safety, accuracy of provided information, and respect for community guidelines.

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