Privacy Policy

Last Updated:

Saturday, March 1, 2025

Introduction

Welcome to Circula (“We”, “Us”, “Our”) Circulahq Technologies Limited is the operator of the website (www.circulahq.com) and software product (CirculaOps) which is accessible through a web browser and mobile application. Our product is designed to improve resource efficiency for waste management stakeholders in Africa first, and across the world.

At Circulahq, we are deeply committed to protecting your privacy. We handle your personal information with care, ensuring compliance with all applicable data protection laws. Your trust is important to us, and we take our legal and ethical responsibilities seriously while providing our Services to you.

This Privacy Policy outlines:

How we collect, use, manage, and disclose your information
How we handle personal information obtained from you.
Your rights regarding your personal information.

Purpose Of This Privacy Policy

This Privacy Policy is designed to inform you of how we collect and process your personal data. It is intended to complement our existing Terms of Use available on our website and any additional notices we may provide when collecting or processing your personal data.

Furthermore, whenever we make updates to this Privacy Policy or our Terms of Use, we will notify you promptly to ensure you are updated on all necessary information.

The Information We May Collect

When you use our Services, we may collect various types of information, including:

Personal Information provided by users while accessing the Service.
Information shared when making inquiries about the Service.
Details submitted when reporting issues or providing feedback about the Service.

The specific types of personal Information that we may collect, use and store are as follows:

Identity Data: This includes your first name, last name, title, date of birth, photographic identification.
Contact Data: This includes your email address and telephone number.
Account Information: This includes information such as usernames and passwords, authentication methods and similar data.
Financial Data: This includes details such as your bank account name, account number, Bank Verification Number (BVN), financial institution, and other relevant financial information that facilitates seamless transactions and payments.
Operational Data: This includes data related to your inventory, transaction records, market activities, and other operational metrics to facilitate efficient management and analytics.
Usage Data: This includes information collected such as your IP address, browser type, operating system, access times, device information which our servers automatically collect when you visit our website, or use our web browser or software product.
Marketing and Communication Data: This includes information collected that helps us relate with you, promote products, services and manage our communication efforts effectively. This extends to records of your discussions with us, if we contact you and if you contact us.

Why We Collect Information

Service Provision and Improvement: To deliver, maintain, and continuously improve our product and services.
Account Management and Customer Support: To manage user accounts and provide timely support and communications.
Data Analytics: To analyze operational trends and user behavior, enabling us to optimize our services and develop new features.
Compliance and Security: To meet our legal obligations and safeguard your data in line with applicable data protection laws.

How We Collect Your Personal Data

We use different methods to collect data from and about you including through:

Direct collection: You may give us your data by filling in forms (e.g., the contact form on our website); creating your profile; by correspondence and conversations (including via email and telephone); or through contracts we may enter with you.
Automated technologies: As you interact with our website or application, we will automatically collect data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We collect such data to be able to properly provide you with our Services.

Disclosure Of Your Information

We may share information we have collected about you in certain situations. Your information may be disclosed as follows:

Required by Law or to Protect Rights:
We may share your information as permitted or required by any applicable law, rule, or regulation if we believe it is necessary to respond to legal process, investigate or remedy potential violations of our policies, or protect the rights, property, or safety of others. This includes exchanging information with other entities for the purposes of preventing fraud.
Third-Party Service Providers:
We may share your information with third parties that perform services for us or on our behalf, including payment processing, data analysis, email delivery, hosting services, customer service, and marketing assistance.
Marketing Communications:
With your consent, or with an opportunity for you to withdraw consent, we may share your information with third parties for marketing purposes, as permitted by law.
Interactions with Other Users:
When you engage with other users within your organization’s CirculaOps platform, they may be able to see your name, profile photo, and activity details, such as sending invitations or collaborating on shared tasks.
Online Postings:
When you post comments, contributions or other content to the CirculaOps platform [web browser or mobile application], your posts may be viewed by all users of your organization’s CirculaOps platform.
Third-Party Advertisers:
We may use third-party advertising companies to serve ads when you use our CirculaOps platform [web browser or mobile application]. These companies may use information about your visits to our CirculaOps platform [web browser or mobile application]. and other websites that are contained in web cookies to provide advertisements about goods and services of interest to you.
Affiliates:
We may share your information with our affiliates, in which case we will demand that they adhere to this Privacy Policy. Our affiliates may include advertisers and investors.
Business Partners:
We may share your information with our business partners to offer you certain products, services or promotions.
Other Third Parties:
We may share your information with such third parties for marketing purposes, as permitted by law. However, such information would be de-identified so as not to be traceable to you.
Sale or Bankruptcy:
If we reorganize or sell all or a portion of our assets, undergo a merger, or are acquired by another entity, we may transfer your information to the successor entity. If we go out of business or enter bankruptcy, your information would be an asset transferred oracquired by a third party. You acknowledge that such transfers may occur, and that the transferee may decline to honor commitments we made in this Privacy Policy.

Lawful Basis For Our Use Of Your Personal Data

We will use your personal data only to the extent permitted by law. Under the Nigeria Data Protection Regulation 2019 (NDPR) and the Nigeria Data Protection Act (NDPA) 2023 and the General Data Protection Regulation (GDPR). Our processing activities are based on one or more of the following legal grounds:

Consent: Where required by law, we obtain your explicit consent to collect and process your personal data for specific purposes.
Contractual Necessity: We process your data to fulfill our contractual obligations to you, such as providing products and services you have requested.
Legal Obligations: We process your data when necessary to comply with applicable laws, regulations, or legal processes.
Vital Interest: Where we need to protect your vital interest or the vital interest of another individual.
Legitimate Interests: We may process your data for purposes that are in our legitimate interests—such as improving our services and marketing communications—provided that these interests are not overridden by your fundamental rights and freedoms. Further, where it is in the interest of the general public to process your data.

While we mostly collect and process your data with your consent, we may collect and process your data under any of the identified lawful bases depending on the circumstance. We do not always need your consent to process your data. However, we do need your consent before we can process your data for purposes such as direct marketing communications. You are at liberty to withdraw your consent to such kinds of processing at any time. Where such withdrawal makes us unable to proceed with providing you with certain Services, we will inform you accordingly.

By using our services, you acknowledge that we rely on these legal basis to process your personal data and that we have taken appropriate measures to ensure the security and confidentiality of your information in compliance with the NDPA, NDPR, and GDPR.

Our Role As Data Controller

A “controller” is a person or organization who alone or jointly determines the purposes for which, and the way any personal data is, or is likely to be, processed. With respect to any information provided to us by any users of CirculaOps, Circulahq Technologies Limited is the Data Controller.

Disclosure Of Your Information

We may disclose your personal information to any of our affiliates. We may also disclose your personal information to third parties if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms ofUse and other agreements; or to protect our rights, property, or safety or those of other users our clients or others.

Data Security

We implement reasonable safeguards to protect personal information disclosed to us from loss, alteration, misuse, unauthorized access, or disclosure. While we are committed to maintaining the security of your data, we acknowledge that no method of transmission over the internet is entirely secure. As such, any transmission of data is at your own risk.

Upon receipt of your information, we apply strict security protocols and industry-standard measures to prevent unauthorized access. Our security framework aligns with internationally recognized standards and best practices in information and cybersecurity, which we continuously review and update in response to emerging threats and regulatory requirements.

Data Retention

We retain your data for such a period as is necessary for the purpose for which it was collected. Storage of your data is also determined by legal, regulatory, administrative, or operational requirements. We only retain information that allows us to comply with legal and regulatory requests for certain data, meet business and audit requirements, respond to complaints and queries, or address disputes or claims that may arise. When data is no longer required for the purposes for which it was collected, we securely destroy it.

Third Party Sites

Our website, and Services may contain links to third-party websites, products, and services. Our products and Services may also use or offer products or services from third parties. Information collected by third parties, which may include such things as location data or contact details are governed by their privacy practices and we will not be liable for any breach of confidentiality or privacy of your information on such third-party websites. We encourage you to learn about the privacy practices of those third parties.

Privacy Policy Change

We may modify this Privacy Policy from time to time without prior notice by publishing a new version of the Privacy Policy on our website. Any changes to the Privacy Policy will be reflected on the website and will become effective immediately upon publication. We encourage you to periodically review this Privacy Policy to stay informed about how we are protecting the personally identifiable information we collect. If changes to the Privacy Policy are material, we will notify you via email or through a notification on our website or software products.

Access, Consent And Correction

We will take reasonable steps to ensure that the personal information we collect remains accurate, up to date and complete. We will also provide you with access to your personal information held by us on your request unless we are otherwise permitted by applicable laws. If you wish to access or correct personal information that we hold about you, please contact us through the contact details provided below. You have the right to withdraw consent previously given for processing your data or restrict the processing of your personal data. We might however continue to process your data if there are valid legal or operational reasons.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us. Furthermore, if you discover any inaccuracies in your personal information, please promptly notify us by contacting us through the contact details provided below.

Your Legal Rights

In addition to being able to control the data you directly provide to us, you may exercise any of the below rights with respect to your data:

1. Request information about any of your personal data which we are processing, and request access to your personal information which we process.

2. Request correction of personal information that we hold about you to make them more accurate or to reflect change in circumstances.

3. Request us to refrain from doing certain things with your data or restrict the extent of our collection or processing of your data.

4. Request partial or complete erasure of your personal information.

5. Object to our processing of your personal information where we are processing your personal information for direct marketing purposes.

6. Object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you.

7. Request the transfer of your personal information to another party. If you wish to exercise any of the rights set out above, please contact us using the contact details provided below.