Last Updated October 7, 2022
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.
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.
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.
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.
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.
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.
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 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.
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.
DotCircle Labs’ websites and applications are not directed at persons under the age of eighteen (18) and we do not collect any Personal Information knowingly or directly from minors who fall within this category. Where you have any belief that DotCircle Labs has mistakenly or unknowingly collected information from a minor, please contact us using the information provided under the Contact Us section to enable investigate and restrict such data.
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 Nigerian Data Protection Regulation.
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.
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 NDPR requirements. The DPO is knowledgeable on data privacy and protection principles and is familiar with the provisions of the NDPR.
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.
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