GILLO Multisuite — Privacy Policy

Effective Date: July 11, 2026

Website: gillomultisuite.com

 

GILLO Multisuite (“Gillo Multisuite,” “we,” “us,” or “our”) operates gillomultisuite.com (the “Site”), a platform for booking luxury shortlet apartments and vacation stays. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit the Site or make a booking with us, and describes your rights under the Nigeria Data Protection Act, 2023 (“NDPA”) and other applicable data protection laws.

By using the Site or making a booking, you agree to the collection and use of information in accordance with this Privacy Policy. If you do not agree with the terms of this Privacy Policy, please do not access or use the Site.

1. Information We Collect

1.1 Information You Provide to Us

  • Identity information: full name, date of birth, government-issued ID (where required for check-in verification)
  • Contact information: email address, phone number, mailing address
  • Booking information: check-in/check-out dates, number of guests, apartment selected, special requests
  • Payment information: billing name, billing address, and payment details processed through our payment partner, PAYONUS (see Section 4)
  • Account information: username and password if you create a My Account profile
  • Communications: messages you send us via the Contact page, email, phone, or WhatsApp, including any information you choose to include in those messages

1.2 Information We Collect Automatically

  • Device and usage data: IP address, browser type, device type, operating system, pages visited, time spent on pages, referring website
  • Cookies and similar tracking technologies (see Section 7, Cookies Policy)
  • Approximate location data derived from your IP address, used to improve search relevance and currency/language defaults

1.3 Information from Third Parties

  • Confirmation of payment status from PAYONUS (we do not receive or store your full card number, CVV, or banking credentials)
  • Information from identity verification services, where used for guest screening

2. How We Use Your Information

We use the information we collect to:

  • Process and manage your apartment bookings, including availability checks, confirmations, and modifications
  • Process payments and issue receipts through PAYONUS
  • Communicate with you about your booking, including confirmations, check-in instructions, and support requests
  • Verify guest identity and eligibility where required by law or for property security
  • Respond to enquiries submitted through our Contact form
  • Improve the Site, our apartments, and our services, including analyzing usage trends
  • Detect, investigate, and prevent fraudulent bookings, chargebacks, or misuse of the Site
  • Comply with legal obligations, including tax, immigration, and law enforcement requirements applicable to short-term accommodation providers in Nigeria
  • Send you marketing communications where you have opted in, which you may unsubscribe from at any time

3. Legal Basis for Processing (NDPA 2023)

Under the Nigeria Data Protection Act, 2023, we process your personal data on one or more of the following legal bases:

  • Consent: where you have given clear consent, such as opting in to marketing emails
  • Contractual necessity: processing required to fulfil your booking and provide the accommodation service you have requested
  • Legal obligation: processing required to comply with Nigerian law, including guest registration and tax obligations
  • Legitimate interests: processing necessary for fraud prevention, Site security, and improving our services, provided this does not override your fundamental rights and freedoms

4. Payment Processing — PAYONUS

All online payments made through the Site are processed by PAYONUS, our designated third-party payment processor. When you make a payment:

  • Your card and payment details are entered directly into PAYONUS’s secure payment interface and are not stored on GILLO Multisuite’s servers
  • PAYONUS processes your payment in accordance with its own privacy policy and applicable card network security standards (PCI-DSS)
  • We receive confirmation of successful or failed payment, a transaction reference, and the last four digits of the card used (where provided by PAYONUS), which we retain for booking records and dispute resolution

We encourage you to review PAYONUS’s privacy policy for further details on how it handles your payment data.

5. How We Share Your Information

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

  • PAYONUS, for payment processing
  • Hosting, website, and booking-management service providers who support the technical operation of the Site (e.g., our web host, WooCommerce Bookings infrastructure)
  • Cleaning, maintenance, and on-site staff, limited to the information necessary to prepare for your stay (e.g., name, check-in/check-out dates, guest count)
  • Professional advisors, such as accountants or legal counsel, where necessary
  • Regulatory authorities or law enforcement, where required by Nigerian law or in response to a valid legal request
  • A successor entity, in the event of a merger, acquisition, or sale of some or all of YES Properties’ assets, subject to equivalent privacy protections

6. Data Storage and Security

We implement reasonable administrative, technical, and physical safeguards designed to protect your personal information from unauthorized access, disclosure, alteration, or destruction, including SSL encryption on the Site and restricted access to booking and guest records. However, no method of transmission or storage is 100% secure, and we cannot guarantee absolute security.

Your data may be stored on servers located within or outside Nigeria. Where data is transferred outside Nigeria, we take steps to ensure it receives an adequate level of protection consistent with NDPA requirements.

7. Cookies Policy

The Site uses cookies and similar tracking technologies to operate correctly, remember your preferences, and understand how visitors use the Site. Types of cookies we use include:

  • Strictly necessary cookies: required for core Site functions such as maintaining your cart and completing checkout
  • Performance and analytics cookies: help us understand Site traffic and usage patterns
  • Functionality cookies: remember your preferences, such as currency or previously viewed apartments

You can control or disable cookies through your browser settings. Disabling certain cookies may affect the functionality of the booking process.

8. Data Retention

We retain your personal information for as long as necessary to fulfil the purposes described in this Policy, including:

  • Booking and payment records: retained for the duration required by Nigerian tax and financial regulations, typically up to 6 years after the transaction
  • Account information: retained for as long as your account remains active, plus a reasonable period thereafter
  • Marketing preferences: retained until you withdraw consent or unsubscribe

When personal information is no longer needed, we securely delete or anonymize it.

9. Your Rights Under the NDPA

As a data subject, you have the right to:

  • Access the personal data we hold about you
  • Request correction of inaccurate or incomplete data
  • Request deletion of your personal data, subject to our legal and contractual retention obligations
  • Object to or restrict certain processing of your data
  • Withdraw consent at any time, where processing is based on consent
  • Request a copy of your data in a portable format
  • Lodge a complaint with the Nigeria Data Protection Commission (NDPC) if you believe your data protection rights have been violated

To exercise any of these rights, contact us at reservations@yespropertiesltd.com. We will respond within the timeframe required by the NDPA.

10. Children’s Privacy

The Site and our booking services are not directed at, and are not intended for use by, individuals under the age of 18. We do not knowingly collect personal information from children. If you believe a child has provided us with personal information, please contact us so we can delete it.

11. Third-Party Links

The Site may contain links to third-party websites, including social media platforms and PAYONUS’s payment interface. We are not responsible for the privacy practices of third-party sites, and we encourage you to review their privacy policies independently.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. The updated version will be posted on this page with a revised “Effective Date.” Continued use of the Site after changes take effect constitutes acceptance of the revised Policy.

13. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or your personal information, please contact us:

Email: booking@gillomultisuite.com

Address: Lagos, Nigeria

Website: gillomultisuite.com