PRIVACY POLICY

Last Updated: 13 January 2026

INTRODUCTION

The Circular Net Limited (we, us or our) are committed to protecting and respecting your privacy in accordance with applicable data protection laws and regulations such as the Nigeria Data Protection Act, the EU General Data Protection Regulation (GDPR), the UK GDPR and any other applicable laws.

This policy (together with any other documents referred to in it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us in connection with this website, all features, functionality, applications, communications and other services offered from time to time (the “Services”).

If you are a visitor to our website, or you sign up to our Services, this Privacy Policy applies to you.

Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

1. Your Consent

By accessing and using this website and applying for or using our services, you are accepting and consenting to the practices described in this policy and agree to be bound by this policy. If you do not wish to be bound by this policy, you must immediately cease use of our website and services, however, this will not affect the lawfulness of any processing of your personal data that we have undertaken based on your consent prior to the withdrawal of your consent.

When collecting information either through this website or when you access any of our services, we will be the controller of your personal data, which means that we determine the purposes for which, and the manner in which, your personal data is processed. You may contact us as follows:

By writing to us at The Circular Net Limited, 3 Agu Close, Joint Estate  Lagos or Info@thecircularnet.com; or

By telephone at+234(0703 347 3123)

2. Information We Collect
   • We will collect and process the following information about you:
     • Information you give us.
       • This is information about you that you give us when engaging with you including when:
         • You create an account on our platform.
         • you fill in forms on or submit information through our website including, when you report a problem with our website or submit any other complaint to us.
         • you provide information when corresponding with us, whether by phone, letter, email or otherwise.
         • you engage with us on social media, including on blogs and forums.
         • your representatives or agents (Agents) engage with us on your behalf in the ways described above.
       • If you wish to use our Services you must provide us with at least the following information: your legal name, any other names that you use, your address, date of birth, place of birth, e-mail address, phone number, payment transaction information (excluding full payment card details) and nationality.
     • Information we collect about you.
       • With regard to your use of our Services and each of your visits to our site we will automatically collect the following information:
         • Information about your activity on the Services, including your frequency of use, content and posts, groups and communities that you are part of, your interactions with content of other users, such as reposts, shares, likes, bookmarks, tags, your interactions with others on the platforms such as people you follow and who follow you, your messages, including the content of the messages, date and time of the messages, payment transaction information (excluding full payment card details).
         • technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, browser type and version, time zone setting, browser plug-in types and versions, and your geographical location;
         • information about your visit, including your full Uniform Resource Locators (URL), clickstream to, through and from our website (including date and time), page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.
       • Information we receive from other sources.
         • This is information we receive about you if you use other websites we operate or the other services we provide.
         • We may also receive information about you from our ad partners, affiliates, or other third parties who help us evaluate the safety and quality of content on our platform such as browser cookie IDs, mobile device IDs, hashed user information like email addresses, demographic or interest data, and content viewed or actions taken on a website or app. Our ad partners also enable us to collect similar information directly from their website or app by integrating our advertising technology. We will notify you when we receive information about you from them and the purposes for which we intend to use that information.

3. Uses Made of The Information
   • Information you give to us.
     • General Uses. In general, we will use personal data you give us:
       • to provide you with information about other services that we or our affiliates offer that are similar to those that you have already purchased or enquired about.
       • to provide you, or permit selected third parties (including our business partners) to provide you, with information about products or services that may interest you.
       • to notify you about changes to our services.
       • to ensure that content from our website is presented in the most effective manner for you and for your computer.
       • to improve and personalize our products and services so that you have a better experience on our platform, including by showing you more relevant content and ads, suggesting people and topics to follow, enabling and helping you discover affiliates, third-party apps, and services. 
       • to inform you of matters concerning your subscriptions.
       • to carry out mandatory or other regulatory checks.
       • to comply with our legal and regulatory obligations.
       • to carry out statistical analysis and market research and testing.
     • Specific Uses. Without affecting the generality of paragraph 1(a)we also use personal data:
       • to verify your identity and the other information you have provided to us.
       • to create an account for you with us when you register your interest in our services.
       • to fulfil our contractual obligations to you in order to provide the Services to you.
       • to respond to your question or query, if you send us personal data in the context of asking us a question or query. In some cases, it may be necessary to share your details with our business partners to adequately respond to your question.
     • Information we collect about you.
       • We use the information about you that we collect from third parties as described in paragraph 1(b)(i)in the same way as information that you give us.
         • We use the information that we collect about your visits to our site:
         • to administer our website and services and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
         • to improve our website to ensure that content is presented in the most effective manner for you and for your computer.
         • to improve our services.
         • to allow you to participate in any interactive features of our services, when you choose to do so.
         • as part of our efforts to keep our website and services safe and secure, including preventing and detecting criminal activity, misuse of or damage to our systems and prosecuting and pursuing those responsible.
         • to make suggestions and recommendations to you and other users of our services about products or services that may interest you or them.
       • Information we receive from other sources. We will combine this information with information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive) and any other purposes that we inform you of in accordance with paragraph 2(b).

4. Cookies
   • Our website uses cookies to distinguish you from other users of our website. However, we cannot identify you personally through our use of cookies. Cookies help us to:
     • provide you with a good experience when you browse our website and/or use our services.
     • recognise you as a unique visitor when you return to our website for the purposes of analysis.
     • tailor content or adverts to match your preferred interests, and to avoid showing you the same adverts repeatedly.
     • compile anonymous, aggregated statistics that allow us to understand how users use our website and/or services and to help us improve our website and/or services.
   • You have the ability to accept or decline cookies by modifying the settings in your browser. However, if cookies are disabled, you may not be able to use all the interactive features of our website and/or we may be unable to provide our services to you.
5. Web Beacons
   • Some of our website pages may contain web beacons or page tags that allow us to count users who have visited these pages. However, these web beacons do not collect personally identifiable information and are only used to track the effectiveness of particular content on our site.
   • Because web beacons are the same as any other content request included in the recipe for a web page, you cannot opt out or refuse them. However, where they are used in conjunction with cookies, which they sometimes are, they can be rendered ineffective by either opting out of cookies or by changing the cookie setting on your browser.
6. Disclosure of your personal data
   • You agree that we have the right to share your personal data:
     • with the public as content on our platform, such as your name, username and/or profile picture may be viewed by the general public without being signed in.
     • with other users. We may share your interactions with the content of other users such as your likes, shares, reposts, messages.
     • any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries.
     • with selected third parties including:
       • your Agents, if you are represented by Agents;
       • business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
       • analytics and search engine providers that assist us in the improvement and optimisation of our website and/or services.
     • We will disclose your personal data to third parties if:
       • we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
       • Circular Net or substantially all of our assets are acquired by a third party, in which case personal data held by us about users of our services will be one of the transferred assets.
       • we are under a duty to disclose or share your personal data to:
         • comply with any legal obligation;
         • enforce or apply our terms of service of this website and our services which you have accepted or are deemed to have accepted and other agreements; or
         • protect the rights, property, or safety of the platform, our customers, or others.
       • you provide us with your prior consent to do so or ask us to share it with a particular third party.

7. Third party websites

Our website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

8. Processing of Your Personal Data
   • We will process your personal data in accordance with applicable laws and the principles set out therein, a summary of which is below.
   • We will collect and process in accordance with specific, legitimate and lawful purposes which you have consented to, provided that:
     • we may undertake further processing of your personal data without seeking further consent from you for the purposes of archiving, scientific research, historical research, or statistical purposes or if it is in the public interest; and
     • if we or our representatives undertake such further processing, we will not transfer any personal data to any third party without your prior consent.
   • We will ensure that our processing of your personal data is lawful. Besides obtaining your consent to process your personal data for specific purposes, our processing of your personal data will be lawful if it is necessary for:
     • compliance with a legal obligation to which we are subject;
     • the protection of your vital interests, our vital interests or those of another individual; or
     • the performance of a task carried out in the public interest.
   • We will use our reasonable efforts to ensure that your personal data that we collect and process is adequate, accurate and is not detrimental to your dignity as a human person.
   • Your personal data will be stored only for the period within which it is reasonably required and we will use our reasonable efforts to keep it secure against foreseeable hazards and breaches such as theft including by way of a cyber attack or viral attack, and unauthorised dissemination and manipulations.
   • As data controller in possession of your personal data, we owe you a duty of care, and therefore we will use reasonable care in processing your personal data to avoid acts or omissions which we can reasonably foresee will cause you to suffer loss or damage. We will be accountable for such acts and omissions.
9. Security
   • We will take all steps reasonably necessary to ensure that your personal data is kept confidential and treated securely and in accordance with this privacy policy. All personal data is subject to restricted access to prevent unauthorised access, modification, misuse or disclosure.
   • Where we have given you (or where you have chosen) a password which enables you to access certain parts of our services, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
   • Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access and improper or accidental disclosure.
10. Retention of Information
    • How long we keep your personal data depends on how we use that information. In some cases, we are required by law to keep information for a minimum period.
    • Unless required by law, we will keep information no longer than is necessary for the purpose we collected or processed the information.
11. Transfers of your personal data to a foreign country
    • The Circular Net Limited is based in Nigeria. Personal data we collect is processed in Nigeria. In order to carry out our business activities and functions in the most efficient manner possible, we may enter into transactions with our affiliates in other foreign countries. This means that we may transfer your personal data to, or your personal data may be accessible in, any location in which we do business.
    • We may also transfer your information to other countries, including those outside the Federal Republic of Nigeria, either for storage purposes or if we engage suppliers, sub-contractors or third-party data processors who are based or have operations overseas.
    • When transferring personal data overseas, we will always apply appropriate safeguards in accordance with applicable privacy laws and regulations to ensure that your personal data is protected.
    • Any transfer made pursuant to this paragraph 11will usually be required either:
      • in performance of a contract between you and us or to take steps at your request prior to entering into such contract; or
      • for the purposes of concluding or performing a contract concluded in your interest between us and our affiliate.

12. Withdrawal of your consent
    • At any time, you may withdraw your consent to our processing of your personal data by writing to us at [INSERT EMAIL ADDRESS].
    • Please note however, such withdrawal will not affect the lawfulness of any processing of your personal data that we have undertaken based on your consent prior to the withdrawal or restriction.
13. Use of your personal data for marketing
    • You have the right to ask us not to use your personal data for marketing purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your personal data, or by clicking the unsubscribe link in any marketing emails we send you. You can also exercise the right at any time by contacting us at Info@thecircularnet.com.
    • Please note that if you opt out as described in paragraph 1, this will apply to marketing messages from us only. We will not be able to remove your personal data from the database of any other users with whom you have shared such information or from third parties to whom you have previously authorised us to share such information (i.e., to which we have already provided your personal data as of the date that we implement your opt-out request).
14. Access To Information
    • If you believe the information that we hold about you is inaccurate or outdated, you may write to us at Info@thecircularnet.com to request that we correct or update it.
    • If you wish to access the information that we hold on you, you may also write to us at the above email address.
    • We will respond to your requests for correction or access free of charge unless in our reasonable opinion, any of your requests is manifestly unfounded or excessive, in particular because of its repetitive nature. In such case, we will either:
      • charge you a fee to cover our costs in complying with your request; or
      • write a letter to you confirming our refusal to act on your request and copy the Nigeria Data Protection Commission.

15. Deletion of your Personal Data and Restrictions on its use
    • You may write to us at any time at Info@thecircularnet.com to request that we delete your personal data or to restrict the purposes for which we may use or process your personal data
    • We will consider your request and if there is a valid ground for deletion or restriction in accordance with applicable laws, we will comply with your request within a reasonable time, otherwise we will inform you of the reasons why we are unable to comply.
16. Portability of your personal data

If you wish us to transmit your personal data directly to another data controller, please write to us at Info@thecircularnet.com. We will do so within a reasonable time, unless such transmission is not technically feasible, in which case we will notify you.

17. Complaints
    • If you believe that the personal data that we hold on you has been unlawfully processed or improperly or accidentally disclosed, or you have any other complaint regarding our processing of your personal data including if we breach this policy, please write to us at Info@thecircularnet.com and we will investigate the matter, inform you of the results of our investigation, and any steps that we will take to remedy the situation.
    • In the unlikely event that we do not respond to your complaint within 30 days of you lodging your complaint, or if you are dissatisfied with the response that we give to your complaint you may lodge a complaint with the Nigeria Data Protection Commission.
18. Changes To Our Privacy Policy  

Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.

19. Contact

Questions, comments and requests regarding this privacy policy are welcome and should be addressed to our Data Protection Officer at Info@thecircularnet.com.