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PALM & CLAY HAUS PRIVACY POLICY

Effective Date: February 20, 2026
Last Updated: February 20, 2026

1. INTRODUCTION

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Welcome to Palm & Clay Haus. We respect your privacy and are committed to protecting your personal information. This Privacy Policy explains how we collect, use, store, and share your information when you interact with our hotel, website, and services.

By using our services, booking a stay, or joining our membership program, you consent to the practices described in this policy.

 

2. WHO WE ARE

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Palm & Clay Haus
Lagos, Nigeria

Contact Us:
Email: info@palmandclayhaus.com
Website: www.palmandclayhaus.com

For privacy-related inquiries, please contact our Data Protection Officer at the email address above.

 

3. INFORMATION WE COLLECT

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3.1 Information You Provide Directly

Reservation & Booking:

  • Name, contact details (email, phone number)

  • Billing address and payment information

  • Passport/ID information (as required by law)

  • Special requests, preferences, dietary requirements

  • Arrival and departure dates

Membership Applications:

  • Personal details (name, date of birth, nationality)

  • Contact information

  • Professional background (optional)

  • Social media profiles (if provided)

  • Preferences and interests

Communications:

  • Email correspondence

  • Phone call records (when you contact us)

  • Feedback, reviews, and survey responses

  • Event registration details

On-Property Services:

  • Spa and wellness bookings

  • Dining reservations and preferences

  • Concierge requests

  • Room preferences and stay history

3.2 Information We Collect Automatically

Website & Digital Interactions:

  • IP address and device information

  • Browser type and version

  • Pages visited and time spent on site

  • Referring website addresses

  • Cookies and similar tracking technologies

Property Technology:

  • CCTV footage in public areas (for security)

  • Wi-Fi usage data (connection logs, not browsing history)

  • Door access logs (for security and service)

3.3 Information from Third Parties

  • Travel agents and booking platforms (e.g., Booking.com, Expedia)

  • Payment processors

  • Social media platforms (if you connect your account)

  • Background check providers (for certain membership applications)

  • Marketing partners and analytics providers

 

4. HOW WE USE YOUR INFORMATION

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4.1 To Provide Our Services

  • Process reservations and manage your stay

  • Facilitate payment and billing

  • Provide requested amenities and services

  • Communicate about your booking (confirmations, updates, changes)

  • Manage membership accounts and benefits

4.2 To Improve Your Experience

  • Personalize your stay based on preferences

  • Remember your choices for future visits

  • Provide tailored recommendations

  • Respond to inquiries and requests

  • Conduct satisfaction surveys

4.3 For Marketing & Communications

  • Send newsletters and promotional offers (with your consent)

  • Inform you about events, new services, and updates

  • Share exclusive member benefits and opportunities

  • Conduct market research

4.4 For Safety & Security

  • Verify identity and prevent fraud

  • Maintain property security through CCTV

  • Comply with legal obligations (immigration, tax, etc.)

  • Protect against misuse of our services

  • Respond to emergencies

4.5 For Business Operations

  • Analyze trends and improve our services

  • Train our staff

  • Maintain accurate records

  • Enforce our terms and conditions

  • Manage legal claims and disputes

 

5. LEGAL BASIS FOR PROCESSING (GDPR)

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We process your personal data based on:

  • Contract Performance: To fulfill our obligations under your booking or membership agreement

  • Legitimate Interests: To improve our services, conduct marketing, and ensure security

  • Legal Obligation: To comply with Nigerian law, tax regulations, and immigration requirements

  • Consent: For marketing communications and optional services (you may withdraw consent anytime)

 

6. HOW WE SHARE YOUR INFORMATION

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

6.1 Service Providers

  • Payment processors (for transactions)

  • IT and cloud hosting providers

  • Marketing and analytics platforms

  • Customer service platforms

  • Professional advisors (lawyers, accountants)

6.2 Business Partners

  • Travel agencies and booking platforms

  • Concierge service providers

  • Event partners and vendors

  • Wellness and spa service providers

6.3 Legal & Regulatory Authorities

  • Nigerian Immigration Services (as required by law)

  • Tax authorities

  • Law enforcement (when legally required)

  • Courts and dispute resolution bodies

6.4 Corporate Transactions

In the event of a merger, acquisition, or sale of assets, your information may be transferred to the new entity, subject to this Privacy Policy.

 

7. INTERNATIONAL DATA TRANSFERS

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Palm & Clay Haus is based in Nigeria. If you are located outside Nigeria, your information may be transferred to and processed in Nigeria and other countries where our service providers operate.

We ensure appropriate safeguards are in place, including:

  • Standard Contractual Clauses approved by the European Commission

  • Adequacy decisions by relevant data protection authorities

  • Your explicit consent where required

 

8. HOW WE PROTECT YOUR INFORMATION

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We implement robust security measures:

Technical Safeguards:

  • Encryption of sensitive data (SSL/TLS)

  • Secure payment processing (PCI DSS compliant)

  • Firewalls and intrusion detection systems

  • Regular security audits and updates

Organizational Safeguards:

  • Staff training on data protection

  • Access controls (need-to-know basis)

  • Confidentiality agreements with employees and vendors

  • Incident response procedures

Physical Safeguards:

  • Secure storage of physical records

  • Controlled access to property systems

  • CCTV monitoring of facilities

Despite our efforts, no system is 100% secure. We cannot guarantee absolute security but will notify you promptly if a data breach occurs.

 

9. DATA RETENTION

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We retain your information only as long as necessary:

Active Reservations & Memberships:

  • Duration of your membership or until reservation is fulfilled

  • Plus 7 years for financial records (tax compliance)

Marketing Communications:

  • Until you unsubscribe or withdraw consent

CCTV Footage:

  • 30-90 days, unless required for investigation

Legal Requirements:

  • Immigration records: 2 years (Nigerian law)

  • Financial records: 7 years (tax law)

After retention periods expire, we securely delete or anonymize your data.

 

10. YOUR RIGHTS

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Depending on your location, you may have the following rights:

10.1 Access & Portability

  • Request a copy of your personal data

  • Receive your data in a portable format

10.2 Correction & Update

  • Correct inaccurate or incomplete information

  • Update your preferences

10.3 Deletion ("Right to be Forgotten")

  • Request deletion of your data (subject to legal obligations)

10.4 Restriction & Objection

  • Restrict processing of your data

  • Object to processing based on legitimate interests

  • Opt-out of marketing communications

10.5 Withdraw Consent

  • Withdraw consent for optional processing (doesn't affect prior processing)

10.6 Lodge a Complaint

  • File a complaint with the Nigerian Data Protection Bureau (NDPB) or your local data protection authority

To Exercise Your Rights:
Email: Info@palmandclayhaus.com
We will respond within 30 days of receiving your request.

 

11. COOKIES & TRACKING TECHNOLOGIES

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11.1 What Are Cookies?

Cookies are small text files stored on your device when you visit our website.

11.2 Types of Cookies We Use

Essential Cookies:

  • Required for website functionality

  • Enable secure login and payment processing

  • Cannot be disabled

Analytics Cookies:

  • Help us understand how visitors use our site

  • Collect anonymous data on pages visited and time spent

  • Examples: Google Analytics

Marketing Cookies:

  • Track your preferences and browsing behavior

  • Enable personalized advertising

  • Examples: Facebook Pixel, Instagram Ads

Preference Cookies:

  • Remember your settings (language, currency)

  • Enhance user experience

11.3 Managing Cookies

You can control cookies through:

  • Browser settings (block or delete cookies)

  • Our cookie consent banner

  • Opt-out tools (e.g., Google Analytics opt-out)

Note: Disabling essential cookies may affect website functionality.

 

12. THIRD-PARTY LINKS

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Our website may contain links to third-party sites (e.g., Instagram, booking platforms). We are not responsible for their privacy practices. Please review their policies before providing information.

 

13. CHILDREN'S PRIVACY

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Our services are not directed at individuals under 18. We do not knowingly collect data from children without parental consent. If you believe we have collected a child's information, contact us immediately.

 

14. MARKETING COMMUNICATIONS

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14.1 How We Use Your Information

With your consent, we may send:

  • Newsletters and updates

  • Exclusive offers and promotions

  • Event invitations

  • Membership benefits

14.2 Opt-Out Options

You can unsubscribe anytime by:

We will process opt-out requests within 10 business days.

 

15. CALIFORNIA RESIDENTS (CCPA)

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If you are a California resident, you have additional rights:

Right to Know:

  • Categories of personal information collected

  • Sources of information

  • Purposes for collection

  • Third parties with whom we share data

Right to Delete:

  • Request deletion of personal information (subject to exceptions)

Right to Opt-Out:

  • We do not sell personal information

Right to Non-Discrimination:

  • We will not discriminate for exercising your rights

To Exercise CCPA Rights:
Email: info@palmandclayhaus.com

 

16. EUROPEAN RESIDENTS (GDPR)

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If you are in the European Economic Area (EEA), you have rights under GDPR:

  • Right to access, rectification, and erasure

  • Right to restrict or object to processing

  • Right to data portability

  • Right to withdraw consent

  • Right to lodge a complaint with your supervisory authority

EU Representative:
N/A

 

17. CHANGES TO THIS POLICY

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We may update this Privacy Policy periodically. Changes will be posted on this page with an updated "Last Updated" date. Material changes will be communicated via:

  • Email notification (if you have an account)

  • Prominent website notice

  • In-app notification (if applicable)

Continued use of our services after changes constitutes acceptance of the updated policy.

 

18. CONTACT US

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For questions, concerns, or requests regarding this Privacy Policy:

Email: info@palmandclayhaus.com
 

 

19. JURISDICTION & GOVERNING LAW

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This Privacy Policy is governed by the laws of the Federal Republic of Nigeria and the Nigeria Data Protection Regulation (NDPR) 2019. Disputes shall be resolved in Nigerian courts.

 

20. ACKNOWLEDGMENT

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By using our services, you acknowledge that you have read, understood, and agree to this Privacy Policy.

 

Last Updated: February 20, 2026
Version: 1.0

 

APPENDIX: KEY DEFINITIONS

Personal Data: Any information relating to an identified or identifiable individual.

Processing: Any operation performed on personal data (collection, storage, use, disclosure, deletion).

Data Controller: Palm & Clay Haus (determines purposes and means of processing).

Data Processor: Third-party service providers acting on our behalf.

Consent: Freely given, specific, informed agreement to processing.

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