About these terms
These Data Processing Terms ("DPT") form part of the Subscription Terms between Clear Path Digital Consulting Limited, a company incorporated in Nigeria with its office in Lagos ("ClearPath Digital", "we", the "Processor") and the customer organisation that accepts them ("you", the "Controller"). They apply to personal data that you and your users put into MyTribeERP for your estates.
1. Roles
1.1 You are the controller of personal data about your residents, owners, occupants, household members, officers, staff, vendors, visitors and other people recorded for your estates ("Customer Personal Data"). You decide why and how it is processed.
1.2 We are your processor. We process Customer Personal Data only to provide the platform to you and on your documented instructions.
1.3 Where you are a management company acting for a residents' association, you confirm that you have the association's authority to use the platform for its estate and to give us these instructions.
1.4 For our own account, sign-in, security, application and billing data, we act as a controller. Our Privacy Notice covers that.
2. Your confirmations as controller
By accepting these terms you confirm that:
- you have a lawful basis under the NDPA for every category of personal data you upload or collect through the platform;
- you have told the people concerned, in a privacy notice of your own, that their data is held on MyTribeERP and stored outside Nigeria (see section 8);
- where you rely on consent, you have it and can show it;
- you will get a parent's or guardian's consent where the NDPA requires it before recording data about a child;
- you will collect only the data you need, and keep it accurate; and
- you will not upload sensitive personal data (for example health, religious or biometric data) unless you have a specific lawful basis and need for it.
3. Your instructions
3.1 Your instructions are these terms, the Subscription Terms, and the way you configure and use the platform: for example the data you enter, the roles you give, the exports you request, and the retention settings you choose.
3.2 We will tell you if we believe an instruction breaks the NDPA, unless the law prevents us.
3.3 We will not use Customer Personal Data for our own purposes, sell it, or use it to market to your residents.
4. Details of the processing
| Item | Description |
|---|---|
| Subject matter | Providing the MyTribeERP estate management platform |
| Duration | The subscription term, plus the post-termination export and deletion periods in section 11 |
| Nature and purpose | Storing, organising, retrieving, displaying, calculating, exporting, sending messages about, backing up and deleting records for estate administration |
| People concerned | Property owners, residents, occupants and household members; officers and committee members; estate staff and security personnel; vendors and contractors; visitors; meeting attendees and voters |
| Types of personal data | Names, contact details, property and occupancy records, household relationships, charges, invoices and payment records, governance roles, attendance and votes (secret ballots are stored so that votes cannot be linked to voters), visitor and access records, service requests, documents you upload, and audit records |
| Sensitive data | None is required by the platform; only what you choose to upload under section 2 |
5. Confidentiality and our staff
5.1 Only staff who need access to provide the service may access Customer Personal Data, and they are bound by confidentiality obligations.
5.2 Our staff have no standing access to your data. Support access happens only through a support session that:
- has a stated purpose, ticket reference, scope (which estates, read-only or read-write) and a fixed end time;
- starts only after your administrator approves it, or in a declared emergency after approval by a second senior member of our staff, with you told promptly; and
- records every action, so your administrator can review it.
6. Security measures
We keep appropriate technical and organisational measures in place, including:
- Tenant separation: every record carries its customer and estate, and the database enforces row-level security so one customer's data cannot be read by another. Your users' access comes from their authenticated membership, never from a value they can change. We test this before every release.
- Encryption of data in transit and at rest.
- Access control: role-based permissions, least privilege, and separation of duties for key finance actions.
- Sign-in security: email and password or passkey, with an optional second step (authenticator app or SMS code). We recommend you require it for officers and finance and administrator roles.
- Audit: a tamper-protected record of privileged actions (access changes, approvals, financial postings, exports and support sessions) that cannot be changed through the application.
- Data minimisation in operations: no secrets or personal data in web addresses or logs, and no sensitive account details in SMS.
- Files: uploaded files are scanned for malware, stored privately, and downloaded only through checked, expiring links.
- Backups and recovery: automated encrypted backups with point-in-time recovery and regular restore testing.
- Operations: restricted production access, monitoring and alerting, dependency and vulnerability scanning, change control and incident response procedures.
We may update these measures, but we will not reduce the overall level of protection.
7. Sub-processors
7.1 You authorise us to use these sub-processors:
| Sub-processor | Service | Location |
|---|---|---|
| Google Cloud (Google LLC and its affiliates) | Hosting, database, file storage, backups | africa-south1 region, Johannesburg, South Africa |
| Infobip | Email and SMS message delivery | Infobip's data centres, which may be outside Nigeria |
7.2 Payment providers are not our sub-processors. You choose and contract with your own payment providers for each estate. Payments settle directly into accounts your organisation controls, and we never hold your funds. The provider processes payer data under its contract with you.
7.3 Mobile network operators and recipients' email services carry messages after Infobip hands them on. They act independently and are not our sub-processors.
7.4 We impose data protection obligations on each sub-processor that are no less protective than these terms, and we remain responsible to you for their performance.
7.5 We will give you at least 30 days' notice before adding or replacing a sub-processor, by email to your administrator or in-app notice. You may object on reasonable data protection grounds. If we cannot resolve the objection, you may end the affected service and receive a pro-rata refund of prepaid fees.
8. Transfers outside Nigeria
8.1 Customer Personal Data is stored in South Africa (Google Cloud africa-south1). This is a transfer of personal data out of Nigeria.
8.2 We make this transfer only as sections 41 to 43 of the NDPA and the GAID allow, with contractual and technical safeguards in place with each sub-processor. We keep records of each transfer and its safeguards and will give you a summary on request.
8.3 We will not copy Customer Personal Data to a new country without first updating these terms and giving notice under section 7.5.
9. Helping you meet your obligations
9.1 Rights requests. If a person asks us directly to access, correct, delete or move data that you control, we will pass the request to you within 5 working days and will not answer it ourselves unless you ask us to. The platform lets your administrators find, correct and export a person's records, and handle account deletion requests. We will give reasonable further help when asked.
9.2 Impact assessments and consultation. We will give reasonable help with your data protection impact assessments and any consultation with the Nigeria Data Protection Commission, using the information available to us.
9.3 Records. We keep a record of our processing activities for you as the NDPA requires.
10. Personal data breaches
10.1 If we become aware of a breach of security that leads to accidental or unlawful loss, change, disclosure of or access to Customer Personal Data, we will tell you without undue delay and in any event within 48 hours of becoming aware of it.
10.2 Our notice will describe, as far as we know at the time: what happened; the categories and approximate number of people and records affected; the likely consequences; what we have done and propose to do; and a contact person. We will send updates as we learn more.
10.3 We will take reasonable steps to contain the breach, preserve evidence and prevent it happening again.
10.4 You are responsible for deciding whether to notify the Nigeria Data Protection Commission (which the NDPA requires within 72 hours where a breach is likely to result in a risk to people's rights and freedoms) and the people affected. We will give you the information you need. We will not notify your residents directly unless you ask us to or the law requires it.
11. Export, return and deletion
11.1 During the subscription, your administrators can export your estates' data at any time, free of charge. The export includes your records and audit trail in CSV and JSON, plus original files. Provider credentials and other secrets are never exported. Download links expire and work only for the person who requested them.
11.2 At the end of the subscription, your administrators keep read-only access to request and download a full export for 30 days.
11.3 After that, we delete Customer Personal Data within 90 days, except where Nigerian law requires us to keep it. Data kept for that reason stays protected under these terms and is deleted when the requirement ends. Our periods for audit records are in Annex A.
11.4 Deleted data may remain in encrypted backups until those backups expire (currently about 7 days). We will not restore it except to recover from a disaster, and then we will delete it again.
11.5 On request, we will confirm in writing that deletion is complete.
12. Retention during the subscription
12.1 You set retention periods for categories of estate data (for example visitor records, resident contacts after move-out, and survey responses) in the platform's retention settings. Deletion runs only after an authorised user approves it, and is recorded by category and count, not by the deleted content.
12.2 The platform sets minimum periods for financial and audit records that you cannot reduce (Annex A).
13. Audits
13.1 We will make available the information you reasonably need to show that we comply with these terms, such as a security overview and a summary of our controls and tests.
13.2 If that is not enough, you (or an independent auditor bound by confidentiality) may audit our compliance once every 12 months, with at least 30 days' notice, during business hours, and without access to other customers' data. You bear your own costs.
15. Liability and order of precedence
15.1 Liability under these terms is subject to the limits in the Subscription Terms.
15.2 If these terms conflict with the Subscription Terms on the processing of personal data, these terms apply.
16. Contact
Our Data Protection Officer: hello@mytribeerp.com, Lagos, Nigeria.
Annex A: retention of audit records
| Class | Examples | Period |
|---|---|---|
| Financial and governance | Postings, approvals, period close, statements, rule versions, appointments, resolutions | 6 years after the end of the financial year concerned, or the estate's own longer requirement |
| Access and support | Role grants, support sessions, exports | 6 years |
| Authentication | Sign-ins, failures, second-step changes, recoveries | 24 months |
| Security events | Refused attempts and similar | 24 months |
Audit records hold identifiers rather than copies of personal details. When a person's details are erased from the registry, the audit trail keeps only a pseudonymous reference.