At Nocveel, we understand that privacy is foundational to trust — both with our tool users and with the individuals whose data powers our capabilities. This Privacy Policy explains how Nocveel Limited ("Nocveel," "We," "Us," or "Our") collects, uses, discloses, and protects personal data in connection with our Services.

This Policy applies to:

• Registered users and administrators of the Nocveel tool ("Tool Users")

• Individuals whose data is processed as part of Nocveel's audience data ("Audience Data Subjects")

• Visitors to our website and marketing channels

Please read this Policy carefully. By using our Services, you acknowledge that you have read and understood this Policy.

Nocveel Limited is the data controller for personal data collected from our Tool Users, website visitors, and related individuals. With respect to Audience Data — the data (information) of people living in specific regions — Nocveel acts as a data controller or data processor depending on the context and jurisdiction.

Our tool is designed for use by real estate companies and professionals. When our customers use Nocveel data to conduct outreach, they may independently act as data controllers under applicable law and assume responsibility for their own compliance obligations.

A — Account & User Data

When you register for or use the Nocveel tool, we may collect:

• Name, job title, and professional role

• Business name and real estate license details

• Email address and phone number

• Billing information (processed via secure third-party payment processors)

• Account credentials and authentication data

• Communication preferences

B — Usage & Behavioral Data

• Tool activity logs (searches conducted, profiles viewed, exports made)

• IP addresses, device type, browser information, and operating system

• Session duration, click paths, and feature usage patterns

• API request logs and integration activity

C — Audience Data

Nocveel collects data relating to third-party individuals (people living in specific regions). This data is sourced from publicly available information and licensed third-party data providers. It may include:

• Name, professional title, and business affiliation

• Publicly reported financial or investment activity

• Geographic or property interest signals

• AI-inferred intent/confidence scores and behavioral indicators

• Publicly available contact or professional profile information

D — Communications Data

• Content of messages sent to our support or sales teams

• Feedback, survey responses, and product reviews

Directly from you: Account registration, form submissions, support requests, onboarding questionnaires.

Automatically: Cookies, server logs, analytics tools when you visit our website or use our tool.

Third-party data providers: Licensed commercial data aggregators that supply business intelligence and public record information.

Publicly available sources: Business directories, professional networks, public filings, news sources, property records.

Integration partners: CRM systems and third-party tools you connect to Nocveel via our API or integrations.

Tool Users

• To provide, operate, and maintain the Nocveel tool and Services

• To authenticate your identity and manage your account

• To process payments and manage subscriptions

• To personalize your experience and improve tool performance

• To send transactional communications (invoices, system alerts, security notices)

• To send marketing communications where you have opted in

• To conduct analytics and develop new features

• To investigate and prevent fraud, abuse, and violations of our Terms

• To comply with legal obligations

Audience Data (Third-Party Individuals)

• To enable our customers to find high-quality prospects

• To generate profiles and insights for our customers

• To train and improve Nocveel's AI and machine learning models

We do not use Audience Data to make automated decisions that produce legal or similarly significant effects on data subjects without human review. Our audience data are intended to assist, not replace, human professional judgment.

Where applicable data protection laws (including the GDPR and Nigeria Data Protection Act) require a legal basis for processing personal data, we rely on the following:

#1

• PROCESSING PURPOSE: Providing the Services under contract

• LEGAL BASIS: Performance of a contract

#2

• PROCESSING PURPOSE: Billing and payment processing

• LEGAL BASIS: Performance of a contract

#3

• PROCESSING PURPOSE: Security and fraud prevention

• LEGAL BASIS: Legitimate interests

#4

• PROCESSING PURPOSE: Tool analytics and improvement

• LEGAL BASIS: Legitimate interests

#5

• PROCESSING PURPOSE: Marketing communications (opted in)

• LEGAL BASIS: Consent

#6

• PROCESSING PURPOSE: Audience data collection for prospecting

• LEGAL BASIS: Legitimate interests

#7

• PROCESSING PURPOSE: Compliance with legal obligations

• LEGAL BASIS: Legal Obligation

Nocveel does not sell personal data. We share data only in the following circumstances:

Service Providers

We share data with trusted third-party vendors who provide services on our behalf, including cloud hosting, payment processing, analytics, email delivery, and customer support platforms. These providers are contractually bound to process data only as instructed and in compliance with applicable law.

Customers

Audience Data is shared with our customers as the core function of the Services. Customers who receive Audience Data assume independent responsibility for their compliance with applicable data protection laws in how they use that data.

Legal & Regulatory Authorities

We may disclose data when required by law, court order, or government request, or where disclosure is necessary to protect our rights, prevent fraud, or respond to an emergency.

Business Transfers

In the event of a merger, acquisition, or sale of all or substantially all of our assets, personal data may be transferred as part of that transaction. We will notify you of any such change and your options.

With Your Consent

We may share data for other purposes with your prior consent.

The Nocveel tool collects data on individuals who have not directly interacted with Nocveel. This section specifically addresses the rights and protections applicable to those individuals.

Sources of Audience Data

Audience Data is sourced from publicly available information and licensed commercial data providers. We apply data quality controls to help ensure accuracy, but we cannot guarantee that all information is fully current or complete.

Purpose Limitation

Audience Data is compiled solely for the purpose of enabling real estate companies and professionals to find potential high-quality. It must not be used for purposes unrelated to this legitimate commercial objective.

Opt-Out Mechanism

Individuals who appear in Nocveel's audience database and wish to be removed may submit a removal request at hello@nocveel.com. We will process such requests within 30 days, subject to verification, and will remove or suppress the individual's data from active use.

Nocveel operates globally and may transfer personal data to countries outside your jurisdiction, including countries that may not offer the same level of data protection as your home country.

Where we transfer data internationally, we rely on appropriate safeguards, including:

• Standard contractual clauses approved by relevant data protection authorities

• Adequacy decisions where applicable

• Binding corporate rules or other recognized transfer mechanisms

For questions about international data transfers, contact us at hello@nocveel.com.

We retain personal data for as long as necessary to fulfill the purposes described in this Policy, or as required by law. Our general retention practices are as follows:

#1

• DATA CATEGORY: Account and profile data

• RETENTION PERIOD: Duration of active account + 3 years post-closure

#2

• DATA CATEGORY: Billing records

• RETENTION PERIOD: 7 years (tax and regulatory requirements)

#3

• DATA CATEGORY: Usage logs and analytics

• RETENTION PERIOD: 24 months from collection

#4

• DATA CATEGORY: Support communications

• RETENTION PERIOD: 3 years from last interaction

#5

• DATA CATEGORY: Audience Data

• RETENTION PERIOD: Refreshed regularly; retained until opt-out or inaccuracy removal

When data is no longer required, we securely delete or anonymize it.

Nocveel implements industry-standard technical and organizational measures to protect personal data from unauthorized access, disclosure, alteration, or destruction. These measures include:

• Encryption of data in transit (TLS/HTTPS) and at rest

• Access controls, multi-factor authentication, and role-based permissions

• Regular security audits and penetration testing

• Employee training on data security and privacy practices

• Incident response procedures for data breaches

In the event of a data breach affecting your personal data, we will notify you and any applicable regulatory authorities within the timeframes required by law.

No security system is impenetrable. We cannot guarantee absolute security, but we are committed to continuous improvement of our safeguards.

Depending on your jurisdiction, you may have the following rights regarding your personal data:

#1

• RIGHT: Access

• DESCRIPTION: Request a copy of the personal data we hold about you

#2

• RIGHT: Rectification

• DESCRIPTION: Request correction of inaccurate or incomplete data

#3

• RIGHT: Erasure

• DESCRIPTION: Request deletion of your data where there is no legitimate reason for us to continue processing it

#4

• RIGHT: Restriction

• DESCRIPTION: Request that we limit the processing of your data in certain circumstances

#5

• RIGHT: Portability

• DESCRIPTION: Receive your data in a structured, machine-readable format

#6

• RIGHT: Objection

• DESCRIPTION: Object to processing based on legitimate interests, including profiling

#7

• RIGHT: Withdraw consent

• DESCRIPTION: Withdraw consent for processing where consent is the legal basis

To exercise any of these rights, submit a request to hello@nocveel.com. We will respond within 30 days. We may need to verify your identity before processing your request. If you are unsatisfied with our response, you have the right to lodge a complaint with your local data protection supervisory authority.

Nocveel's Services are intended solely for business professionals and are not directed at individuals under the age of 18. We do not knowingly collect personal data from minors. If we become aware that we have inadvertently collected such data, we will take immediate steps to delete it. If you believe we may have data relating to a minor, please contact us at hello@nocveel.com.

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or tool features. When we make material changes, we will notify you by email or by displaying a prominent notice on our website prior to the changes taking effect.

The "Last Updated" date at the top of this Policy reflects the most recent revision. We encourage you to review this Policy periodically.