Privacy Policy

1. Who we are

NairaCircle is a digital savings platform designed to help people organise and participate in community savings circles inspired by Nigerian practices such as Ajo, Esusu, and Adashe. The platform is being developed to support the organisation of savings circles, management of contributions, and coordination of payouts.

NairaCircle's business registration with the Corporate Affairs Commission (CAC) is currently in progress. The legal name and details of the entity that will operate the service must be confirmed and published before launch. Until those details are confirmed, this policy does not represent that NairaCircle has completed its business registration.

For privacy-related questions, requests, or complaints, you can contact us at contact@nairacircleweb.com. The identity of the legal entity responsible for processing personal data and any required business address should be confirmed and published before the service launches.

2. Information we may collect

Depending on the features you use and how the service is configured, NairaCircle may collect the following categories of information:

• Identity and profile information: such as your name and information you provide for your profile.
• Contact and account information: such as your email address, account identifiers, and account-related records.
• Savings-circle information: such as the circles you create or join, membership information, and relevant circle activity.
• Financial and transaction information: such as contribution records, payment status, payout records, transaction references, and related financial activity.
• Identity-verification information: where verification is required, information submitted or generated during identity checks, subject to the verification process and applicable law.
• Banking and payout information: such as information needed to support an applicable payout or payment feature.
• Technical and security information: such as device and connection information, diagnostic records, and security events where these are collected by the service.
• Communications: such as messages, enquiries, complaints, and other information you provide when communicating with us.

We should collect only personal information that is relevant and reasonably necessary for identified purposes. The information actually collected will depend on the features made available and the technologies used to provide them.

3. Identity verification information

Certain features may require identity verification to help establish identity, protect accounts, reduce fraud, and meet applicable legal or regulatory requirements.

Depending on the verification method actually used, this information may include details from government-issued identity records, identification numbers, verification results, photographs, biometric information, or liveness-check information. Not every verification method will involve every category of information.

Some identity or biometric information may receive additional protection under applicable data-protection law. Before collecting such information, NairaCircle must establish and communicate an appropriate lawful basis, meet any additional legal requirements that apply, and provide relevant information about the purpose, recipients, retention, and available rights.

Where external verification providers are used, the information processed will depend on the selected provider, the verification method, and the information needed for the requested service. The final policy and related notices should identify the providers and describe their roles accurately before verification is made available to users.

4. How we use information and our lawful bases

Depending on the feature and circumstances, personal information may be used to:

• Create, authenticate, and manage user accounts.
• Help users create, join, and manage savings circles.
• Maintain contribution, membership, payment, and payout records.
• Support payment or payout processes made available through the service.
• Conduct identity, account-security, and fraud-prevention checks where appropriate.
• Send necessary account, contribution, payout, service, and security communications.
• Investigate suspected fraud, misuse, security incidents, or unauthorised activity.
• Maintain, troubleshoot, and improve the security and functionality of the service.
• Respond to enquiries, privacy requests, and complaints.
• Establish, exercise, or defend legal claims and meet applicable legal obligations.

The lawful basis for processing depends on the particular purpose and applicable law. Depending on the circumstances, this may include taking steps requested by a user before entering into a contract, performing a contract, complying with a legal obligation, pursuing a legitimate interest where permitted, or obtaining valid consent where consent is required or relied upon.

We must identify the appropriate lawful basis for each processing purpose before processing begins. Where consent is relied upon, it must meet the applicable legal requirements, and withdrawal must be handled in accordance with the law. Withdrawing consent does not make earlier lawful processing unlawful, and other lawful grounds may apply independently.

We will not use personal information for a materially incompatible purpose without an appropriate legal basis and any information or consent required by law.

5. How we share information

NairaCircle does not intend to sell personal information. Personal information may be shared where necessary and lawful to provide the service, fulfil a requested transaction, protect users, or meet applicable obligations.

Depending on the features actually offered, recipients may include payment or financial-service providers, identity verification providers, hosting and infrastructure providers, communications providers, security providers, and customer support providers. Each provider's access should be limited to what is appropriate for its role and the relevant purpose.

We may also disclose information when required or permitted by applicable law, a valid legal process, a competent authority, or where disclosure is reasonably necessary to establish, exercise, or defend legal claims or protect the rights and safety of users or others.

Before launch, NairaCircle should document its actual providers, the information shared with each provider, their respective responsibilities, and the safeguards governing those arrangements. This policy should be updated if the actual arrangements differ materially from the description above.

6. Information visible to circle members

Because NairaCircle supports community savings circles, some information may need to be visible to other members or authorised circle organisers to support membership, contribution tracking, payout coordination, and transparency.

The information displayed should be limited to what is reasonably necessary for the relevant circle and its operation. Information such as identity documents, full identity-verification records, private contact details, and sensitive financial information should not be exposed to other members unless a specific disclosure is necessary and lawfully justified.

The final product should clearly explain which details other members can see before users join or participate in a circle.

7. Data security

NairaCircle should implement appropriate technical and organisational measures to protect personal information against unauthorised access, loss, misuse, alteration, or disclosure. The safeguards used should reflect the nature of the information, the risks associated with its processing, and applicable legal requirements.

No internet-based service can guarantee absolute security. Users should also take reasonable steps to protect their devices, email accounts, passwords, and other authentication credentials and should promptly report suspected account compromise.

Where a personal-data breach occurs, NairaCircle will assess and respond to it in accordance with applicable legal requirements, including any relevant obligations to notify the appropriate authority or affected individuals.

8. Data retention

Personal information should be retained only for as long as necessary for the purpose for which it was collected, subject to applicable legal, regulatory, accounting, security, and dispute-resolution requirements.

Retention periods may differ according to the category of information and the purpose for which it is processed. Where information is no longer needed, it should be securely deleted, anonymised, or otherwise handled as required by applicable law.

Before launch, NairaCircle should establish documented retention periods for account records, transaction records, identity-verification information, support communications, security logs, and other relevant categories. This policy should be updated to reflect those periods or the criteria used to determine them.

9. Your privacy rights

Subject to applicable law and any relevant exceptions, you may have rights concerning your personal information, including the right to:

• Receive information about how your personal information is collected and used.
• Request access to personal information held about you.
• Request correction of inaccurate or incomplete information.
• Request deletion or erasure where the applicable legal conditions are met.
• Request restriction of processing in circumstances recognised by law.
• Object to certain processing where the law gives you that right.
• Request portability of eligible information where applicable.
• Withdraw consent where processing is based on consent, without affecting the lawfulness of processing before withdrawal.
• Challenge certain decisions made solely through automated processing where applicable law provides that right.

These rights are not absolute and may be subject to legal conditions or exceptions. For example, certain records may need to be retained to comply with legal obligations or resolve disputes.

To submit a privacy request, contact contact@nairacircleweb.com. We may need to verify your identity before acting on a request. We will handle requests within the time limits and according to the procedures required by applicable law.

If you believe that your personal information has been processed unlawfully or that your privacy rights have been infringed, you may also have the right to lodge a complaint with the Nigeria Data Protection Commission (NDPC), subject to its applicable procedures.

10. Cookies and similar technologies

Our website may use cookies or similar technologies to support essential functionality, security, and performance. Analytics or other non-essential technologies may also be used if they are implemented in the live service.

Where required by law, we will provide appropriate information and obtain consent before using non-essential cookies or similar technologies. Available cookie controls and choices should be explained to users where applicable.

The final version of this policy should reflect the actual cookies, analytics tools, and tracking technologies deployed on the website and mobile application rather than describing tools that are not used.

11. Third-party services and international transfers

NairaCircle may rely on third-party services to provide hosting, infrastructure, communications, payments, identity verification, security, or other features. Depending on their role, these providers may process personal information on our behalf or determine certain processing purposes independently.

Third-party websites and services may have their own privacy policies and terms. Where you interact directly with a third-party service, its own terms may also apply to that interaction.

Some service providers may process or store information outside Nigeria. Before any such transfer takes place, NairaCircle must identify the relevant destinations and providers and implement the transfer requirements and safeguards applicable under Nigerian data-protection law. Where required, additional information about international transfers and the relevant safeguards will be provided to users.

12. Children's privacy

NairaCircle is intended for people who are legally eligible to use the relevant service. Age and eligibility requirements should be established for the product before launch.

We will handle personal information relating to children in accordance with applicable law, including any requirements concerning parental or guardian authorisation, consent, and safeguards. If we become aware that personal information has been collected in circumstances that violate applicable law, we will assess the matter and take appropriate steps.

13. Changes to this Privacy Policy

We may update this Privacy Policy as NairaCircle develops, our services or data-processing practices change, or legal requirements change.

The effective date at the top of this page indicates the planned effective date of this version. If material changes are made after publication, we will update the policy and provide notice through appropriate channels where required by law.

14. Contact us

If you have questions about this Privacy Policy, wish to exercise a privacy right, or want to raise a concern about how your personal information is handled, contact us using the email address below.

We will review privacy enquiries and requests and respond in accordance with applicable legal requirements. If your concern cannot be resolved, you may have the right to complain to the Nigeria Data Protection Commission.