Privacy Policy

1. Who We Are

COHCASEL Limited is a professional home management and domestic staffing company incorporated in Nigeria, with principal operations in Lagos. We connect families with trained, certified, and background-checked home managers, caregivers, and domestic professionals.

For the purposes of applicable data protection law — including the Nigeria Data Protection Act 2023 (NDPA), the Nigeria Data Protection Regulation 2019 (NDPR), and the EU General Data Protection Regulation (GDPR) where applicable — COHCASEL is the Data Controller.

Our Data Protection Officer (DPO) can be reached at privacy@cohcasel.com.

2. Information We Collect

2.1 Information You Provide Directly

• Identity data: full name, date of birth, gender, nationality
• Contact data: email address, phone number, postal address
• Account credentials: username and encrypted password
• Profile data: profile photo, biography, professional experience
• Service request data: type of care needed, household size, special requirements
• Payment data: billing address, payment method details (processed by Paystack — we never store raw card data)
• Communications: messages sent through our platform, support tickets, feedback
• Verification data: government-issued ID, guarantor information (for staff applicants)

2.2 Information We Collect Automatically

• Device and browser information (IP address, browser type, operating system)
• Usage data (pages visited, features used, time spent, clicks)
• Location data (approximate location derived from IP; precise location only with explicit consent)
• Cookies and similar tracking technologies (see Section 9)
• Log data (server logs, error reports, performance data)

2.3 Information from Third Parties

• Social login providers (Google, Microsoft) if you choose to sign in that way
• Background check agencies (for home manager applicants)
• Police clearance certificates (provided by applicants)
• Referral information when a client refers you to us

3. How We Use Your Information

We use your personal data for the following purposes:

• Creating and managing your account
• Matching clients with suitable home managers based on stated needs
• Processing payments and issuing invoices
• Verifying the identity and credentials of staff applicants
• Communicating service updates, scheduling, and reports to clients and staff
• Sending transactional emails (booking confirmations, payment receipts, alerts)
• Sending marketing communications — only with your consent, and you may withdraw at any time
• Improving our platform through analytics and user feedback
• Complying with legal and regulatory obligations
• Preventing fraud, abuse, and other harmful activity
• Resolving disputes and enforcing our agreements

4. Lawful Basis for Processing

Under the NDPA 2023 and GDPR, we process your personal data only where we have a lawful basis to do so:

5. Sharing Your Information

We do not sell your personal data. We may share it with:

• Home managers assigned to your household (limited to what is necessary for service delivery)
• Clients who request a home manager (limited profile information shared after acceptance)
• Payment processors (Paystack) — subject to their own privacy policy
• Background check agencies — only for staff applicants, with their written consent
• Cloud infrastructure providers (hosting, database, storage) under strict data processing agreements
• Email and SMS service providers for transactional communications
• Analytics providers (PostHog, Google Analytics) — in anonymised or pseudonymous form
• Legal authorities — when required by Nigerian law, court order, or to protect our legal rights
• Successor entities — in the event of a merger, acquisition, or sale of assets (you will be notified)

All third-party processors are contractually required to handle your data in accordance with applicable law and may not use it for their own purposes.

6. International Data Transfers

Some of our service providers may be located outside Nigeria. Where we transfer personal data internationally, we ensure appropriate safeguards are in place, including:

• Standard Contractual Clauses (SCCs) approved by the relevant authority
• Adequacy decisions where available
• Binding corporate rules with data processors
• Your explicit consent where required

We will never transfer your data to a country that does not provide an adequate level of protection without implementing the above safeguards.

7. Data Retention

We retain personal data only for as long as necessary to fulfil the purposes outlined in this policy, unless a longer retention period is required by law.

8. Your Rights

Under the NDPA 2023, NDPR, and GDPR (where applicable), you have the following rights regarding your personal data:

• Right of access — obtain a copy of the personal data we hold about you
• Right to rectification — request correction of inaccurate or incomplete data
• Right to erasure ("right to be forgotten") — request deletion of your data where there is no lawful ground to retain it
• Right to restriction — ask us to limit how we process your data in certain circumstances
• Right to data portability — receive your data in a structured, machine-readable format
• Right to object — object to processing based on legitimate interests or for direct marketing
• Right to withdraw consent — withdraw any consent you have given at any time, without affecting prior processing
• Right not to be subject to automated decisions — including profiling that produces legal or significant effects
• Right to lodge a complaint — with the Nigeria Data Protection Commission (NDPC) or your local supervisory authority

To exercise any of these rights, contact our DPO at privacy@cohcasel.com. We will respond within 30 days. Identity verification may be required.

9. Cookies & Tracking

We use cookies and similar technologies to operate and improve our platform. You can manage your cookie preferences at any time through your browser settings or our consent manager.

• Strictly necessary cookies — required for the site to function (cannot be disabled)
• Functional cookies — remember your preferences (language, currency, region)
• Analytics cookies — measure how visitors use our site (PostHog, Google Analytics)
• Marketing cookies — track effectiveness of advertising campaigns (only with your consent)

You may withdraw consent for non-essential cookies at any time. Doing so will not affect the functionality of core features.

10. Children's Privacy

Our services are not directed at children under 18 years of age. We do not knowingly collect personal data from children. If you believe a child has provided us with their data without parental consent, please contact us immediately at privacy@cohcasel.com and we will delete it promptly.

Where our services involve care for children (e.g., childcare services), data about minors is collected only from their parent or legal guardian, and processed solely for service delivery purposes with the guardian's explicit consent.

11. Security

We implement industry-standard technical and organisational security measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction, including:

• TLS/SSL encryption for all data in transit
• AES-256 encryption for sensitive data at rest
• Role-based access controls limiting data access to authorised personnel only
• Regular security audits and penetration testing
• Multi-factor authentication for internal systems
• Staff training on data protection and security practices

Despite these measures, no system is completely secure. In the event of a personal data breach that poses a risk to your rights and freedoms, we will notify the NDPC within 72 hours and inform affected individuals without undue delay.

12. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by email (if you have an account) or by a prominent notice on our website at least 30 days before the change takes effect. The updated policy will display the new effective date at the top of this page.

Continued use of our services after the effective date of any changes constitutes acceptance of the revised policy.

13. Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or your personal data, please contact us: