Privacy Policy

This Privacy Policy is a collection of documents of how we collect, use, and process your account data when you use our website. Sed ut perspiciatis unde omnis iste natus error sit voluptatem accusantium doloremque laudantium, totam rem aperiam, eaque ipsa quae ab illo inventore veritatis et quasi architecto beatae vitae dicta sunt explicabo. Nemo enim ipsam voluptatem quia voluptas sit aspernatur aut odit aut fugit, sed quia consequuntur magni dolores eos qui ratione voluptatem sequi nesciunt. Neque porro quisquam est, qui dolorem ipsum quia dolor sit amet, consectetur, adipisci velit, sed quia non numquam eius modi tempora incidunt ut labore et dolore magnam aliquam quaerat voluptatem.

This Privacy Policy contains the following sections

  • 1. Data Protection
  • 2. Information Security
  • 3. Privacy Choices and Rights
  • 4. How We Process Your Information
  • 5. Privacy Policy Retention
  • 6. Contact
This website operates only in Nigeria for now, with an overarching view to African. For our Users, this Privacy Policy is part of our Terms of Use. This Privacy Policy applies to your use of (regardless of means of access) our Services. You may access or use our Services through a desktop, laptop, mobile phone, tablet, or other consumer electronic device (each, a "Device") inclusive of offline operations. By accessing or using our Services, you agree to this Privacy Policy.
 

Information We Collect and How We Collect It

Non-Public Information you share with us. When you visit us and interact with our services via account setup, inquiry, event registration, promo and referral bonus, social service information sharing and all general visitation on our website or mobile, we collect non-public personal information you provide to us. The types of information we may collect include your name, address, phone number, email address, date of birth, bank account information, BVN, username, password, and any other information you choose to provide (collectively, "Personal Information").
By providing your Personal Information and any other kind of information or data to us, you expressly agree to our collection, use, storage, and disclosure of such information as described in this Privacy Policy.
Transactional Information: which includes details about your transactions, including transaction time, Naira amount and merchant details. We may also collect photos, memos, or other information that you attach to your transactions. We collect Personal Information about your transactions with us and others.
Contact Information: which includes non-public information including your billing address, delivery address, email address and telephone numbers.
Device Information: Information about the computer or mobile device you use to access our Services, including the hardware model, operating system and version, unique device identifiers and mobile network information.
Log Information: Information about your use of our Services, including the type of browser you use, access times, pages viewed, your IP address and the page you visited before navigating to our Services.
Profile Information: Information which includes your username and password, picture, transaction history, your interests, preferences, feedback, and survey responses.
Usage Information: which includes details of your use of our Services. We may aggregate your usage information to calculate the percentage of Users accessing a specific Website feature.
Marketing Information: which includes your preferences in receiving marketing from us and our third parties and your communication preferences.
Location Information: We may collect your location information from your mobile device with your prior consent which includes your current location disclosed by GPS technology or any other location territory. We may also collect, use and share aggregated data such as statistical or demographic data for any purpose.

Information From other Sources and third Parties

We also collect Personal Information about you from other and sources, third parties companies.
Situation where we may receive Personal Information about you from a consumer reporting agency or we may collect Personal Information from your employer where your employer is providing a service to myCircle.
Situations where we may receive Personal Information from third party connector request initiated by you or services you applied for.
Situations where we may receive Personal Information from a User where your Personal Information is filled in a Next-of-Kin form.

Information Automatically Collected

We (or our service providers acting on our behalf) may collect information about your use of our Services. This information may include Personal Information as well as statistical information that does not identify you ("Analytics"). Some Analytics may be correlated with Personal Information. When Analytics are, directly or indirectly, associated or combined with Personal Information, such Analytics will be considered Personal Information for purposes of this Privacy Policy.

Information that we automatically collect in connection with your access or use of our Services may include:

We use various technologies to collect information on our Services and other websites, and this may include sending cookies to your computer or mobile device. Cookies are small data files stored on your hard drive or in device memory that help us to improve our Services and your experience, see which areas and features of our Services are popular and count visits. We use cookies for record-keeping purposes and to enhance the quality of your use of our Services. The cookies assign random, unique numbers to your Devices to enable our systems to recognize your Devices and to allow us to see how you use our Services. Additional general information about cookies and how they work is available at www.allaboutcookies.org.

The cookies we use in connection with our Services include:

Session cookies: Temporary cookies that expire and are automatically erased whenever you close your browser window. We use these cookies 0to grant users access to content as they access our services.
Persistent cookies: Persistent cookies usually have an expiration date in the distant future and remain in your browser until they expire or you manually delete them. We use persistent cookies to better understand usage patterns so we can improve our Services. For example, we may use a persistent cookie to associate you with your myCircle account or to remember your choices for our Services.
Third-party cookies: We permit certain third parties to place cookies through our Services to provide us with better insights into the use of our Services and user demographics and to advertise our Services to you. These third parties may collect information about your online activities over time and across different websites when you access or use our Services.
For example, we utilize Google Analytics to analyze usage patterns for our Services. Google Analytics generates a cookie to capture information about your use of our Services, which Google uses to compile reports on website activity for us and to provide other related services. Google may use a portion of your IP address to identify its cookie, but this will not be associated with any other data held by Google. We may also permit third-party service providers to place cookies for our Services, as indicated above, to perform analytic or marketing functions where you are notified of them and you have consented to the usage. We do not control the use of such third-party cookies or the resulting information, and we are not responsible for any actions or policies of such third parties.
By accessing or using our Services, you consent to the placement of cookies on your Devices as described in this Privacy Policy. If you prefer not to receive cookies through our Services, you may control how your browser responds to cookies by adjusting the privacy and security settings of your web browser. Unless you set your browser settings to refuse all cookies, our system may issue cookies when you access or use our Services. If you set your browser settings to refuse all cookies, the performance of certain features of our Services may be limited or not work at all.

Do-Not-Track Signals

Do Not Track ("DNT") is an optional browser setting that allows you to express your preferences regarding tracking by advertisers and other third parties. We do not use technology that recognizes DNT signals from your web browser.

How We Use Information

We may use Analytics as described elsewhere in this Privacy Policy and for research and commercial purposes, such as to improve our Services.
We may use Personal Information for the purposes described elsewhere in this Privacy Policy and internally for our general commercial purposes, including, among other things, to offer our products and services and products and services of third parties that we think you might find of interest. Only MyCircle and our third-party service providers involved in distributing the offers or providing the products or services will have access to your Personal Information. Our third-party service providers will only be permitted to use Personal Information for that intended purpose.
We may use your email address to respond to your inquiries and to provide information about our Services. You may elect not to receive promotional emails from us either by "unsubscribing" to an email you receive from us or by contacting us as indicated below. As a User, if you unsubscribe from receiving emails from us, we may still send you non-promotional emails, such as emails about your myCircle account or our ongoing business relations, unless you withdraw your consent to receive electronic communications as provided in our Terms of Use.

How We Share Information

You agree that we have the right to share your Personal Information, and other information that you share with us:
if you request or authorise it;
if the information is provided to help complete a transaction for you; with any of our affiliated companies and service providers;
with financial service providers, including the financial institutions identified in your cardholder bank agreement that provide banking services in connection with your myCircle account;
with another user, when you sign up for our services via a referral link. The user that referred you may receive information indicating that you have enrolled with us;
with non-financial companies, such as email service providers that perform marketing services on our behalf, and fraud prevention service providers that use the information to provide services to us;
with a non-affiliated third-party to access and transmit your personal and financial information from a relevant institution. You grant the third-party the right, power, and authority to access and transmit this information according to terms of their privacy policy;
with selected third parties including business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
with third parties to whom we may choose to sell, transfer or merge parts of our business or our assets or alternatively, acquire all or parts of their businesses;
in response to a request for information, if we are required by, or we believe disclosure is in accordance with applicable laws, rules, regulations, governmental and quasi-governmental requests, court orders, or subpoenas or legal process;
for our everyday business purposes;
for publication of our events and competitions on digital and print media;
protect our rights, property, or safety or the rights, property, or safety of our users or others; or with relevant law enforcement officials or other third parties, such as investigators or auditors, if we believe it is appropriate to investigate fraud.
We do not share your Personal Information with: (1) other companies for joint marketing purposes without your consent; or (2) any other third parties so they can market to you.
If you provide us with bank account or debit card information, or any other payment information, through our Services, we may share that information with third-party payment processors and other third-party service providers, solely to the extent necessary to provide you with the relevant Services.
When you are no longer our User, we may continue to share your information as described in this Privacy Policy.
We may disclose Analytics with third parties as described elsewhere in this Privacy Policy and for our commercial purposes.

Opt-Out Rights

If you do not wish to receive offers or other notices from us in the future, you can "opt out" by contacting us as indicated at the end of this Privacy Policy or by following the "unsubscribe" instructions in any communication you receive from us. Please be aware that if you are a User, you are not able to opt out of receiving communications about your myCircle account or related transactions with us.

Other Rights to Your Personal Information with Us

Beyond your right to opt out of our processing Personal Information, you also have the option of exercising any of the below rights with respect to your Personal Information:

Request Correction to your Personal Information

We respect your wishes to correct inaccurate information and as such you must notify us of any change in your Personal Information. If you are a User, you can change some of your Personal Information by updating your myCircle account profile through our Services. Changes to financial details will require you to contact us directly. If you are not a User, you can contact us as indicated at the end of this Privacy Policy to make any changes or request on Personal Information we hold about you. Any changes will affect only future uses of your Personal Information and we may need to verify the accuracy of the new data you provide to us.

Request Access to your Personal Information

You can ask us whether we are storing your Personal Information and you can ask to receive a copy of that Personal Information. Before sending you any Personal Information, we will ask you to provide proof of your identity. If you are not able to provide proof of your identity, we reserve the right to refuse to send you any Personal Information. We will respond as quickly as we can to your requests for details of Personal Information, we hold about you.
Request us to refrain from doing certain things with your data or restrict the extent of our collection or processing of your data
You may object to the processing of your personal data where you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request partial or complete erasure of your Personal Information

You may request for us to delete or remove personal data where there is no good reason for us to continue to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing, where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note however that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Request the transfer of your Personal Information to another party We will provide to you, or a third party you have chosen, your Personal Information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent Where we are relying on consent to process your Personal Information, you may withdraw your consent to the processing of Personal Information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain Services to you. We may advise you if this is the case at the time you withdraw your consent.
Object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you This right is subject to applicable law.

Information You Share Socially

Our Services may allow you to connect and share your actions, comments, content, and information publicly or with friends. We are not responsible for maintaining the confidentiality of any information you share publicly or with friends.
Our Services may also allow you to connect with us on, share on, and use third-party websites, applications, and services. Please be mindful of your personal privacy needs and the privacy needs of others, as you choose whom to connect with and what to share and make public. We cannot control the privacy or security of information you choose to make public or share with others. We also do not control the privacy practices of third parties. Please contact those sites and services directly if you want to learn about their privacy practices.

Security and Storage of your Personal Information

We have suitable security measures in place to prevent your Personal Information from being accidentally lost or used or accessed in an unauthorised way by a third party. When your bank account information is transmitted via our Services, it will be protected by encryption technology, such as Secure Sockets Layer (SSL). In addition, we limit access to your personal data to those employees, employers, agents, contractors and other third parties who have a business need to know. They will only process your Personal Information on our instructions. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We have, and require our third-party service providers that receive Personal Information from us to have, a comprehensive written information security program that contains administrative, technical, and physical safeguards for our respective physical facilities and in our respective computer systems, databases, and communications networks that are reasonably designed to protect information contained within such systems from loss, misuse, or alteration.
No method of electronic transmission or storage is 100% secure. Therefore, we cannot guarantee absolute security of your Personal Information. You also play a role in protecting your Personal Information. Please safeguard your email address, username and password for your myCircle account and do not share them with others. If we receive instructions using your myCircle account login information or other myCircle account security information, we will consider that you have authorized the instructions. You agree to notify us immediately of any unauthorized use of your myCircle account or any other breach of security. We reserve the right, in our sole discretion, to refuse to provide our Services, terminate myCircle accounts, and to remove or edit content.

Promotional Communications

You may opt out of receiving promotional emails and text messages from Fundall by following the instructions in those messages. Please note that if you opt out, we may still send you transactional or relationship messages, such as those about your account or our ongoing business relations.

Social Sharing Features

Our Services include social sharing features for common social networks to let users share content. These features are served from third-party services that may serve their own cookies. The use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the entity that provides the social sharing feature. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of the entities that provide these features.
Subject to applicable law, which might, from time to time, oblige us to store your Personal Information for a certain period of time, we will retain your Personal Information for as long as necessary to fulfil the purposes we collected it for, including the purposes of satisfying any legal, accounting, or reporting requirements.

Protecting underage Privacy

We do not offer our services to under 18 and this not directed or intended to be used. We do not knowingly collect Personal Information from children under the age of 18. If you are under the age of 18, do not use our Services or submit any information to us.

Analytics and Advertising Services Provided By Others

We may allow others to provide analytics services on our behalf and to serve advertisements on our behalf across the Internet. These entities may use cookies, web beacons and other technologies to collect information about your use of the Services and other websites, including your IP address, web browser, pages viewed, time spent on pages, links clicked and conversion information. This information may be used by Fundall and others, to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising targeted to your interests and better understand your online activity.

Links to Third-Party Websites

When you use our Services, you may be directed to other websites that are beyond our control. We may also allow third-party websites or applications to link to our Services. We are not responsible for the privacy practices of any third parties or the content of linked websites, but we do encourage you to read the applicable privacy policies and terms and conditions of such parties and websites. This Privacy Policy only applies to our Services.

Data security and retention

myCircle takes reasonable measures to help protect all information about you from loss, theft, misuse and unauthorized access, disclosure, alteration, and destruction. Additionally, myCircle implements policies designed to protect the confidentiality and security of your nonpublic personal information, including a privacy protection policy. Akashi limits access to your nonpublic personal information to employees that have a business reason to know such information and implements security practices and procedures designed to protect the confidentiality and security of such information and prohibit unlawful disclosure of such information in accordance with its policies.

Changes to our Privacy Policy

Subject to applicable law, we may revise this Privacy Policy at any time and in our sole discretion. When we revise this Privacy Policy, we will post the revised version via our Services and will update the date at the top of this Privacy Policy. The revised Privacy Policy will be effective upon posting via our Services, unless otherwise set forth therein or as otherwise required by applicable law. You are free to decide whether or not to accept a revised version of this Privacy Policy, but accepting this Privacy Policy, as revised, is required for you to continue accessing or using our Services. If you do not agree to the terms of this Privacy Policy or any revised version of this Privacy Policy, your sole recourse is to terminate your access and use of our Services. Except as otherwise expressly stated by us, your access and use of our Services is subject to the version of this Privacy Policy in effect at the time of access or use.

How can I contact myCircle?

If you have any questions, comments, or concerns regarding these Terms or the Services, please contact us at info@myCircle.africa, 234 803 805 3478