Privacy Policy

1. Introduction

This Privacy Policy sets out how Neighbourly Hub ("Neighbourly Hub", "we", "our", "us") processes personal data in connection with the provision of its software platform for residential complex, strata, and homeowners' association (HOA) management.

Neighbourly Hub is committed to processing personal data in accordance with Jamaica's Data Protection Act ("DPA").

2. Data Protection Roles

2.1 Data Controller

The residential complex, strata corporation, or homeowners' association ("Complex") using Neighbourly Hub is the Data Controller. The Data Controller determines the purpose of processing, the lawful basis for processing, and the retention period for personal data.

2.2 Data Processor

Neighbourly Hub acts as a Data Processor. Neighbourly Hub shall:

• Process personal data only on documented instructions from the Data Controller
• Not determine the purposes or means of processing
• Implement appropriate technical and organisational safeguards

2.3 No Independent Control

Neighbourly Hub does not independently control or determine the use of personal data submitted to the platform by Complexes.

3. Categories of Personal Data

Neighbourly Hub may process the following categories of personal data on behalf of Complexes:

3.1 Resident Data

• Full name
• Contact details (email, telephone number)
• Unit or apartment identification
• Account balances and payment history
• Maintenance requests and service records
• Booking and facility usage data

3.2 Administrator Data

• Name
• Email address
• Role and permissions

3.3 System and Technical Data

• Login activity and timestamps
• IP address and device/browser information
• Audit logs and system activity records

4. Purpose of Processing

Personal data is processed strictly for the purpose of:

• Providing and maintaining the Neighbourly Hub platform
• Managing complex administration workflows
• Recording and tracking financial obligations and payments
• Generating statements, reports, and summaries
• Facilitating communication within Complexes
• Ensuring system security, integrity, and monitoring
• Providing technical support

Neighbourly Hub shall not process personal data for its own independent marketing purposes.

5. Lawful Basis for Processing

The lawful basis for processing is determined by the Data Controller. Neighbourly Hub processes personal data on behalf of the Data Controller in accordance with:

• Contractual necessity (platform use)
• Legitimate interests of the Data Controller
• Legal obligations applicable to the Data Controller

Neighbourly Hub does not assume responsibility for establishing lawful basis.

6. Data Minimisation

Neighbourly Hub is designed to process only personal data that is necessary for the operation of the platform and relevant to complex management activities. Data Controllers are responsible for ensuring that excessive or unnecessary personal data is not uploaded to the platform.

7. Sub-processors

Neighbourly Hub may engage third-party service providers ("Sub-processors") to support the operation of the platform, including hosting providers such as Render. Neighbourly Hub shall ensure that Sub-processors are subject to appropriate contractual obligations, implement adequate security measures, and comply with applicable data protection laws.

8. International Data Transfers

Personal data may be processed outside of Jamaica through Sub-processors. Where such transfers occur, Neighbourly Hub shall ensure that appropriate safeguards are implemented and that transfers are limited to what is necessary for service delivery.

9. Security Measures

Neighbourly Hub implements appropriate technical and organisational measures to protect personal data.

9.1 Technical Measures

• Encryption in transit (HTTPS)
• Secure authentication mechanisms
• Role-based access controls

9.2 Organisational Measures

• Restricted administrative access
• Controlled system deployment
• Monitoring and logging of user activity

Notwithstanding the above, no system is completely secure, and residual risk remains.

10. Data Retention

Personal data shall be retained only for as long as necessary to fulfil the purposes of processing, comply with legal and contractual obligations, and support audit and security requirements. Retention periods are determined by the Data Controller.

Neighbourly Hub shall delete or return personal data upon termination of services, subject to legal and operational requirements.

11. Data Subject Rights

Data subjects may exercise rights under the Data Protection Act, including:

• Right of access
• Right to rectification
• Right to erasure (where applicable)
• Right to restrict processing
• Right to object to processing
• Right to withdraw consent (where applicable)

Requests should be directed to the Data Controller. Neighbourly Hub shall assist the Data Controller, where reasonably required, in responding to such requests.

12. Data Breach Notification

In the event of a personal data breach, Neighbourly Hub shall notify the Data Controller without undue delay and provide relevant details regarding the nature of the breach, its likely impact, and remedial actions taken.

The Data Controller is responsible for notifying affected individuals and reporting to regulatory authorities.

13. Confidentiality

Neighbourly Hub shall ensure that all personnel authorised to process personal data are subject to confidentiality obligations and process data only as necessary for their role.

14. Limitation of Liability

To the maximum extent permitted by law, Neighbourly Hub shall not be liable for:

• The accuracy or completeness of data provided by the Data Controller
• Decisions made by the Data Controller based on platform data
• Financial disputes between residents and Complexes
• Unauthorized access resulting from user credential misuse
• Any indirect, incidental, or consequential damages

15. Use of Platform by Third Parties

Neighbourly Hub shall not be responsible for actions taken by administrators, residents, or other authorised users, or for the misuse of data by individuals granted access by the Data Controller.

16. Updates to this Policy

Neighbourly Hub may update this Privacy Policy from time to time. Updated versions will be published on the platform with a revised "Last Updated" date. Continued use of the platform constitutes acceptance of the updated policy.

17. Contact Information

For privacy-related inquiries, contact us at support@neighbourlyhub.com.