Privacy Policy

Introduction

We are DotCircle Labs Ltd (“DotCircle Labs” or “DotCircle”), with offices at Sam Olukayode Street, Alagbaka, Akure, Ondo State, Nigeria with company registration number 1849017.

For any access request, questions, or inquiries about how we use your Personal Information, please contact us at [email protected].

DotCircle Labs does not take your trusting us with your information for granted. The privacy of our Users is important to us and we are committed to safeguarding it. Hence, this Privacy Policy explains your Personal Information which we collect, why we collect it, and what we do with it.

Overview

This Privacy Policy describes your privacy rights regarding how and when we collect, use, store, share and protect your information across our website, mobile platforms (“Platforms”), APIs, Software Applications, (“Apps”), email notifications and tools regardless of how you use or access them.

This Privacy Policy is applicable to all of the Website, software applications (“Apps”) and/or mobile platforms (“Platforms”) offered by DotCircle Labs or affiliated companies collectively referred to as DotCircle Labs “services”.

DotCircle Labs is a registered company in Nigeria and is working towards expansion to become a part of a group to be made up of a number of local operating entities in a number of markets across the globe. “DotCircle Labs”, “we” “us” or “our” in this privacy statement means the DotCircle Labs entity that is responsible for processing your personal information.

Definition

Account: means an account opened in relation to any of DotCircle Labs’ services.

Cookies: A cookie is a small data file that is transferred to your computer or mobile device. It enables us to remember your account log-in information, IP addresses, web traffic, number of times you visit, browser type and version, device details, date and time of visits.

DotCircle Labs: means DotCircle Labs Limited.

Personal Information: Any information that can be used to identify a living person including email address, company name, password, payment card, financial information such as Bank Verification Number (BVN), bank account number, etc., Government- issued Identity card, and/or taxpayer identification it may also include anonymous information that is linked to you, for example, your internet protocol (IP), log-in information, address, location, device or transaction data.

Sites: means any platform including but not limited to mobile applications, websites and social media platforms.

User: means an individual who uses the Services or accesses the Sites and has agreed to use the end services of DotCircle Labs.
Special Categories of Personal Information means details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data.

Objective

This Privacy Policy statement is to provide all persons and organizations whose Personal Information we hold with description of the types of Personal Information we collect, the purposes for which we collect that Personal Information, the other parties with whom we may share it and the measures we take to protect the security of the data.
Accordingly, we have developed this privacy policy in order for you to understand how we collect, use, communicate, disclose and otherwise make use of personal information. We have outlined our privacy policy below.

Our Privacy Principle

DotCircle Labs focuses on the following core principles:

To Empower the individual: DotCircle Labs wants you to be in charge of your personal information and to make your own voluntary choices about your Personal Information;
To keep and secure personal information: DotCircle Labs does not take your trusting us with your information for granted. We take responsibility to ensuring that appropriate security measures are put in place and your personal information is protected;
To be transparent and to educate users: For you to know what personal information is, how we collect personal information, for what purpose and how we secure personal information;
To abide by local laws: DotCircle Labs is a global company with local privacy expertise. Our privacy practices may vary among the countries in which we operate to reflect local practices and legal requirements. Specific privacy notices may apply to some of our products and services.
To collect and store personal information on the “need to collect” basis: DotCircle Labs collects personal information to perform its services for you. We work to have measures in place to prevent collecting and storing Personal Information beyond what we need.

1. Personal Information We May Collect About You

We may collect, use, process, store, or transfer personal information such as:

Identity Data: Information such as, your full name(s), your government-issued identity number, and your date of birth. This data is to enable us to verify your identity in order to offer our services to you;
In order to experience the full range of our services, we would require your consent granting access to your geo-location and your contacts. You have the right to withdraw your consent allowing us access to your contacts at any time.

Identification documents (such as your passport or any Government-issued identity card), a photograph (if applicable) and any other registration information you may provide to prove you are eligible to use our services and in compliance with regulatory requirements on Know Your Customer (KYC);

Log/Technical information: When you access DotCircle Labs services, our servers automatically record information that your browser sends whenever you visit a website, links you have clicked on, length of visit on certain pages, unique device identifier, log-in information, location and other device details.

Marketing and Communications Data: This includes both a record of your decision to subscribe or to withdraw from receiving marketing materials from us or from our third parties.

Records of your discussions with us, if we contact you and if you contact us.
We may also collect, store, use and transfer non-personal information or anonymized data such as statistical or demographic data.
As a principle, we do not collect any Special Categories of Personal Information. If we do collect Special Categories of Personal Information, we will ensure compliance with applicable law.

This Privacy Policy applies to DotCircle Labs services only. We do not exercise control over the sites displayed or linked from within our various services. These other sites may place their own cookies, plug-ins or other files on your computer, collect data or solicit personal information from you. DotCircle Labs does not control these third-party websites and we are not responsible for their privacy statements. Please consult such third parties’ privacy statements and set appropriate controls from your setting when using any third- party services.

2. How we get your Personal Information and why we have it

The Personal Information we have about you is directly made available to us when you:

• Sign up for a DotCircle Labs Account
• Use any of our services
• Contact our customer support team
• Fill our online forms
• Contact us

Your consent: Where you agree to us collecting your Personal Information by using our Services.

We have a contractual obligation: Without your Personal Information, we cannot provide our Services to you.

We have a legal obligation: To ensure we are fully compliant with all applicable Financial legislations such as Anti-Money Laundering and Counter Terrorist Financing Laws, we must collect and store your Personal Information. We protect against fraud by checking your identity with your Personal Information.

3. How We May Use Your Personal Information

We may use your Personal Information we collect to:
Create and manage any accounts you may have with us, verify your identity, provide our services, and respond to your inquiries;
Process your transactions with us (including authorization, clearing and other related dispute resolution activities);
Protect against and prevent fraud, unauthorized services, claims and other liabilities;
Provide, administer and communicate with you about products, services, offers, programs and promotions of DotCircle Labs and our partners;
Evaluate your interest in employment and contact you regarding possible employment with DotCircle Labs;
Evaluate and improve our business, including developing new products and services;
To target advertisements, newsletter and service updates;
As necessary to establish, exercise and defend legal rights;
As may be required by applicable laws and regulations, including for compliance with Know Your Customers and risk assessment, Anti-Money Laundering, anti-corruption and sanctions screening requirements, or as requested by any judicial process, law enforcement or governmental agency having or claiming jurisdiction over DotCircle Labs or DotCircle Labs’ affiliates;
To use data analytics to improve our website, products or services, user experiences and to optimize service.
For other purposes for which we provide specific notice at the time of collection.

4. Data Security and Retention

The security of your Personal Information is important to DotCircle Labs. We are committed to protecting the information we collect. We maintain administrative, technical and physical controls designed to protect the Personal Information you provide, or we collect against loss or theft, as well as against any unauthorized access, risk of loss, disclosure, copying, misuse or modification.

Other security measures include but not limited to, secure servers, firewall, data encryption and granting access only to employees in order to fulfil their job responsibilities.

Where you use a password for any of your Accounts, please ensure you do not share this with anyone, and the password is kept confidential at all times.

We are committed to conducting our business in accordance with these principles in order to ensure that the confidentiality of your Personal Information is protected and maintained. Transmitting information online is not entirely secure. As such, we cannot guarantee that all information provided online is secure. We would take all reasonable steps to ensure that your Personal Information is secured and well protected.

We will only retain personal information on our servers for as long as is reasonably necessary as long as we are providing Services to you. Where you close your Account, your information is stored on our servers to the extent necessary to comply with regulatory obligations and for the purpose of fraud monitoring, detection and prevention. Where we retain your Personal Information, we do so in compliance with limitation periods under the applicable law.

5. Disclosing your Personal Information

We may disclose or share your Personal Information with third parties which include our affiliates, employees, officers, service providers, agents, suppliers, subcontractors as may be reasonably necessary for the purposes set out in this policy. DotCircle Labs only shares personal information with External Third parties in the following limited circumstances:

We have your consent. We require opt-in consent for the sharing of any personal information; We share Personal Information with third parties directly authorized by you to receive Personal Information, such as when you authorize a third-party application provider to access your account. The use of your Personal Information by an authorized third party is subject to the third party's privacy policy and DotCircle Labs shall bear no liability for any breach which may arise from such authorization by you.

We provide such information to our subsidiaries, affiliated companies or other trusted businesses or persons for the purpose of processing personal information on our behalf. We require that these parties agree to process such information based on our instructions and in compliance with this Privacy Policy and any other appropriate confidentiality and security measures. We have a good faith belief that access, use, preservation or disclosure of such information is reasonably necessary to:

• satisfy any applicable law, regulation, legal process or enforceable governmental request,
• enforce applicable Terms of Service, including investigation of potential violations thereof,
• detect, prevent, or otherwise address fraud, security or technical issues, or
• protect against imminent harm to the rights, property or safety of DotCircle Labs, its users or the public as required or permitted by law.

If DotCircle Labs becomes involved in a merger, acquisition, or any form of sale of some or all of its assets, we will provide notice before personal information is transferred and becomes subject to a different privacy policy.

6. Marketing

We may process your Personal Information in order to contact you or send you marketing content and communication about our products, services or surveys. You may exercise your right to object to such contact from us or opt out from the marketing content. Please note however that if you opt-out of marketing content, we may still send you messages relating to transactions and our Services related to our ongoing business relationship.

We may ask you for permission to send notifications to you. Our Services will still work if you do not grant us consent to send you notifications.

7. Your Data Protection Rights and Choices

Based on your location and applicable laws, below are the rights you have as a user in relation to your Personal Information:

Right to be informed.

Right to request access or copies to your Personal Information by signing into your Account or contacting us.

Right to request that DotCircle Labs erase your Personal Information. You have the right to ask us to erase your Personal Information. Please note that this is a limited right which applies where the data is no longer required, or the processing has no legal justification. The exceptions to this right are where the applicable law requires DotCircle Labs to retain a historical archive or where we retain a core set of your Personal Information to ensure we do not inadvertently contact you in future where you object to your data being used for marketing purposes.

Right to correct or rectify any Personal Information that you provide which may be incorrect, out of date or inaccurate. You also have the right to ask us to complete information you think is incomplete.

Right to object to the processing of your Personal Information for marketing purposes. You have a right to ask us not to contact you for marketing purposes by adjusting your notification preference on the settings page or by opting out via the unsubscribe link in marketing emails we send you.

Right to object to processing: You have the right to object to the processing of your Personal Information in certain circumstances. Please note that where you object to us processing your Personal Information, we might be unable to provide the services to you.

The basis of we processing your Personal Information is your consent. You also have the choice at any time to withdraw consent which you have provided.

You also have a choice to deactivate your Account at any time. You may contact us should you wish to de-activate your Account at any time via the Contact Us segment below or send us an email at [email protected].

If you wish to exercise any of the rights set above, please contact us using the contact information provided in the Contact Us segment below. Where we are unsure of your identity, we might ask you for proof of your identity for security reasons before dealing with your request.

8. Cookies

Like many other websites, we use cookies to distinguish you from other users and to customize and improve our services.

Some browsers may automatically accept cookies while some can be modified to decline cookies or alert you when a website wants to place a cookie on your computer. If you do choose to disable cookies, it may limit your ability to use our website. For detailed information on the cookies and how we use them see our Cookie Policy.

9. Child or Person Lacking Legal Capacity

DotCircle Labs’ websites and applications are not directed at persons under the age of eighteen (18) or those lacking legal capacity, and we do not collect any Personal Information knowingly or directly from minors or person lacking legal capacity who fall within this category.

Where you have any belief that DotCircle Labs has mistakenly or unknowingly collected information from a child or person lacking legal capacity, please contact us using the information provided under the Contact Us section to enable investigate and restrict such data.

10. International Data Transfers

Where Personal Information is to be transferred to a country outside Nigeria, DotCircle Labs shall put adequate measures in place to ensure the security of such Personal Information and to ensure same is done securely and in accordance with the Nigeria Data Protection Act, 2023 (“NDPA”).

11. Data Protection Officer

DotCircle Labs has appointed a Data Protection Officer(s) (DPO) responsible for overseeing the Company's data protection strategy and its implementation to ensure compliance with the NDPA requirements. The DPO is knowledgeable on data privacy and protection principles and is familiar with the provisions of the NDPA.

12. Training

DotCircle Labs ensures that employees who collect, access and process Personal Information receive adequate data privacy and protection training in order to develop the necessary knowledge, skills and competence required to effectively manage the compliance framework under this Policy and the Nigerian Data Protection Regulation (NDPR) with regard to the protection of Personal Information. On an annual basis, DotCircle Labs develops a capacity building plan for its employees on data privacy and protection in line with the NDPR.

13. Data Protection Audit

DotCircle Labs shall conduct an annual data protection audit through a licensed Data Protection Compliance Organization (DPCOs) to verify DotCircle Labs’ compliance with the provisions of the NDPR and other applicable data protection laws.

The audit report will be certified and filed by the DPCO to the National Information Technology Development Agency (NITDA) as required under the NDPR.

14. Dispute Resolutions and Filing a Compliant

If you have any complaints regarding this Privacy Policy, please contact us at [email protected]. We will investigate and work on resolutions for complaints and disputes regarding use and disclosure of personal information within thirty (30) days in accordance with this Privacy Policy and in accordance with the Nigerian Data Protection Act.

15. Updates to our privacy policy

From time to time, we may change, amend or review this Privacy Policy from time to time to reflect new services or changes in our Privacy Policy and place any updates on this page. All changes made will be posted on this page and where changes will materially affect you, we will notify you of this change by placing a notice online or via mail. If you keep using our Services, you consent to all amendments of this Privacy Policy.

16. Contact us:

All access requests, questions, comments, complaints and other requests regarding the privacy policy should be sent to [email protected].

We may request additional details from you regarding your complaints and keep records of your requests and resolution.

This Privacy Policy was last updated in February 2024.