Privacy Policy

Hi! We've created this Privacy Policy (the “Privacy Policy”) to describe your privacy rights regarding how we collect, use, process, disclose and protect your information; including any non-public, personal information (“Personal Data”).

Consent to Installation of the App

Under data protection laws, we are required to provide you with certain information about who we are, how we process your Personal Data and for what purposes, and your rights in relation to your Personal Data. This information is provided here and it is important that you read this information.

Before registration on this App, please indicate your consent to our processing of your Personal Data (including your name, contact details, financial and device information) as described in the policy.

How You Can Withdraw Consent

Once you provide consent by selecting "YES", you may change your mind and withdraw consent at any time by contacting us at tech@circlefundsapp.com but that will not affect the lawfulness of any processing carried out before you withdraw your consent.

Introduction

This policy applies to your use of:

• Circle Funds Technologies mobile application software ( App ) hosted on Google Play Store or App Store ( App Site ), once you have downloaded a copy of the App onto your mobile telephone or handheld device ( Device ).
• Any of the services accessible through the App ( Services ) that are available on the App Site or other sites of ours ( Services Sites ). This policy sets out the basis on which any Personal Data we collect from you, or that you provide to us, will be processed by us. This App is not intended for children and we do not knowingly collect data relating to children. Please read the following carefully to understand our practices regarding your Personal Data and how we will treat it.

By accessing or using our Services, you agree to this Privacy Policy.

Important Information and Who We Are

Circle Funds Technologies Inc is the controller and is responsible for your Personal Data (collectively referred to as "Circle Funds", "we", "us" or "our" in this policy).

If you have any questions about this privacy policy, please contact us using the details set out below.

Contact Details

Our full details are:

• Full name of legal entity: Circle Funds Technologies Inc.
• Email address: tech@circlefundsapp.com

Changes to the Privacy Policy and Your Duty to Inform Us of Changes

We keep our privacy policy under regular review.

This version was last updated in July 2024. It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you by email. The new policy may be displayed on-screen and you

may be required to read and accept the changes to continue your use of the App or the Services. It is your responsibility to check this Privacy Policy from time to time to verify such updates.

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 our relationship with you.

Third Party Links

Our Sites may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any Personal Data that may be collected through these websites or services, such as Contact and Location Data**.** Please check these policies before you submit any Personal Data to these websites or use these services.

The Data We Collect About You

We may collect, use, store and transfer different kinds of Personal Data about you as follows:

• Identity Data.
• Contact Data.
• Financial Data.
• Transaction Data.
• Device Data.
• Content Data.
• Profile Data.
• Usage Data.
• Marketing and Communications Data.
• Location Data.

We explain these categories of data in our Glossary which can be found at the end of this document.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your Personal Data but is not considered Personal Data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific App feature. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes 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). Nor do we collect any information about criminal convictions and offences.

How is Your Personal Data Collected?

We will collect and process the following data about you:

• Information you give us. This is information (including Identity, Contact, Financial, and Marketing and Communications Data) you consent to giving us about you by filling in forms on the App Site and the Services Sites (together Our Sites ), or by corresponding with us (for example, by email or chat). It includes information you provide when you register to use the App Site, download or register an App, subscribe to any of our Services, search for an App or Service, share data via our App's social media functions, enter a competition, promotion or survey, register to attend a Circle Funds event, volunteer information to us, and when you report a problem with an App, our Services, or any of Our Sites. If you contact us, we will keep a record of that correspondence.

• Location Data. We may also use GPS technology or other technology to determine your current location. Some of our location-enabled Services may require your Personal Data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by disabling Location Data in your settings.

• Information we receive from other sources including third parties and publicly available sources. We also receive Personal Data about you from other companies. For instance, we may receive Personal Data about you from a consumer reporting agency or we may collect Personal Data from your employer where your employer is providing a service to Circle Funds. We may collect Personal Data 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 Data as well as statistical information that does not identify you (“analytics”). Some analytics may be correlated with Personal Data. When analytics are, directly or indirectly, associated or combined with Personal Data, such analytics will be considered Personal Data for the purposes of this privacy policy. Information that we automatically collect in connection with your access or use of our Services may include: o Device Information: We may collect device-specific information (such as hardware model, operating system version, unique device identifiers, and mobile network information including your mobile phone number). We may associate your device identifiers or mobile phone number with your Circle Funds account. o Log Information: We may record or log information from your devices, their software, and your activity accessing or using our Services. This information may include: - The device’s Internet Protocol (“IP”) address - Identification numbers associated with your devices. - Device event information such as crashes, system activity and hardware settings - Location preferences - Date and time stamps of transactions - System configuration information - Other interactions with our Services

Cookies

We use cookies and/or other tracking technologies to distinguish you from other users of the App, App Site, the distribution platform (Appstore) or Services Sites and to remember your preferences. A cookie is a text file or other local storage identifier provided by your browser or associated applications. This helps us to provide you with a good experience when you use the App or browse any of Our Sites and also allows us to improve the App and Our Sites. Most cookies are ‘session cookies’, meaning that they are automatically deleted from your hard drive at the end of a session. You are always free to decline our cookies if your browser permits, although in that case you may not be able to use certain features on the Sites. Additional general information about cookies and how they work is available at http://www.allaboutcookies.org.

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 Your Personal Data

We will only use your Personal Data when the law allows us to do so. Most commonly we will use your Personal Data in the following circumstances:

• Where you have consented before the processing.
• Where we need to perform a contract we are about to enter or have entered with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

We may use Personal Data 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 we think you might find of interest. Only Circle Funds and our third-party service providers involved in distributing the offers or providing the products or services will have access to your Personal Data. Our third-party service providers will only be permitted to use Personal Data 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 using our contact details as indicated above. As a user, if you unsubscribe from receiving emails from us, we may still send you non-promotional emails, such as emails about your Circle Funds account or our ongoing business relations, unless you withdraw your consent to receive electronic communications.

Purposes For Which We Will Use Your Personal Data

Purpose/activity	Type of data	Lawful basis for processing
To install the App and register you as a new App user	Identity Contact Financial Device	- Your consent
To process and deliver Services including managing payments and collecting money owed to us	Identity Contact Financial Transaction Device Marketing and Communications Location	- Your consent - Performance of a contract with you - Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you including notifying you of changes to the App or any Services	Identity Contact Financial Profile Marketing and Communications	Your consent Performance of a contract with you Necessary for our legitimate interests (to keep records updated and to analyse how customers use our products/ Services) Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions)
To enable you to participate in a prize draw, competition or complete a survey	Identity Contact Device Profile Marketing and Communications	Your consent Performance of a contract with you Necessary for our legitimate interests (to analyse how customers use our products/Services and to develop them and grow our business)
To administer and protect our business and this App including troubleshooting, data analysis and system testing	Identity Contact Device	Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security)
To deliver content and advertisements to you To make recommendations to you about goods or services which may interest you To measure and analyse the effectiveness of the advertising we serve you To monitor trends so we can improve the App	Identity Contact Device Content Profile Usage Marketing and Communications Location	Consent Necessary for our legitimate interests (to develop our products/Services and grow our business)

Disclosures of your Personal Data

When you consent to providing us with your Personal Data, we will also ask you for your consent to share your Personal Data with the third parties set out below for the purposes set out in the table above - Purposes For Which We Will Use Your Personal Data :

• Internal Third Parties as set out in the Glossary.

• External Third Parties as set out in the Glossary.

• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your Personal Data in the same way as set out in this privacy policy.

We do not share your Personal Information with:

• Other financial companies for joint marketing purposes;
• Affiliated companies for their everyday business purposes; or
• Any third parties so they can market to you.

You agree that we have the right to share your Personal Data, and other information that you share with us:

• If you request or authorize 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 financial institutions identified in your cardholder bank agreement that provides banking services in connection with your Circle Funds 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 the information according to the terms of their privacy policy;
• With selected third parties including business partners, suppliers and subcontractors for the performance of any contract we enter into with them or you;
• For publication of our events and competitions on digital and print media;
• If the information is provided to: o Comply with applicable laws, rules, regulations, governmental and quasi-governmental requests, court orders, or subpoenas; o Enforce our terms of use or other agreements; or o Protect our rights, property, or safety or the rights, property, or safety of our users or others (e.g., to a consumer reporting agency for fraud protection, etc.); o If the information is provided to our third-party service providers to perform functions on our behalf (e.g., analyzing data, providing marketing assistance, providing customer service, processing orders, etc.); o For our everyday business purposes; or o As permitted by applicable law or otherwise described in this privacy policy.

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 customer, we 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.

International Transfers

We ensure your Personal Data is protected by requiring all our group companies to follow the same rules when processing your Personal Data. These rules are called "binding corporate rules".

Whenever we transfer your Personal Data out of Nigeria, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your Personal Data to countries that have been deemed to provide an adequate level of protection for Personal Data.
• Where we use certain service providers, we may use specific contracts approved by Nigeria which give Personal Data the same protection it has in Nigeria.

Data Security

All information you provide to us is stored on our secure servers. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be protected by encryption technology. Where we have given you (or where you have chosen) a password that enables you to access certain parts of Our Sites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Once we have received your information, we will use strict procedures and security features to try to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorised way.

Certain Services include social networking, chat room or forum features. Ensure when using these features that you do not submit any Personal Data that you do not want to be seen, collected or used by other users.

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 username and password for your Circle Funds account and do not share them with others. If we receive instructions using your Circle Funds account login information, we will consider that you have authorized the instructions. You agree to notify us immediately of any unauthorized use of your Circle Funds account or any other breach of security. We reserve the right, in our sole discretion, to refuse to provide our Services, terminate Circle Funds accounts, and to remove or edit content.

Data Retention

Subject to applicable law, which might, from time to time, oblige us to store your Personal Data for a certain period of time, we will retain your Personal Data for as long as necessary to fulfil the purposes we collected it for, including purposes of satisfying any legal, accounting or reporting requirements.

In some circumstances you can ask us to delete your data: see Your legal rights below for further information.

In some circumstances we will anonymise your Personal Data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

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 in our contact information above 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 Circle Funds account or related transactions with us.

Your Legal Rights

Under certain circumstances you have the following rights under data protection laws in relation to your Personal Data.

• Request access to your Personal Data: 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 correction of your Personal Data: 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 Circle Funds account profile on the App. Changes to financial details will require you to contact us directly. If you are not a user, you can contact us as indicated in our contact information 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 erasure of your Personal Data: 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 restriction of processing your Personal 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 transfer or your Personal Data: 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.
• Right to 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.

You also have the right to ask us not to continue to process your Personal Data for marketing purposes.

You can exercise any of these rights at any time by contacting us at tech@circlefundsapp.com.

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.

Protecting Children’s Privacy

Our Services are not directed or intended to be attractive to children under the age of 18. 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.

Glossary

Consent means processing your Personal Data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Data for our legitimate interests. We do not use your Personal Data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your Personal Data where it is necessary for compliance with a legal obligation that we are subject to.

Third parties

Internal third parties include:

Other companies in our company group acting as joint controllers or processors and who provide IT and system administration services and/or undertake leadership reporting.

External third parties include:

Service providers acting as processors who provide IT and system administration services.

Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.

Regulators and other authorities who require reporting of processing activities in certain circumstances.

Description of categories of Personal Data

• Identity Data : first name, last name, maiden name, username or similar identifier, marital status, title, date of birth, gender.

• Contact Data : billing address, delivery address, email address and telephone numbers.

• Financial Data : bank account and payment card details.

• Transaction Data : includes details about payments to and from you.

• Device Data: includes the type of mobile device you use, a unique device identifier (for example, your Device's IMEI number, the MAC address of the Device's wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser you use, time zone setting.

• Content Data: includes information stored on your Device, including friends' lists, login information, photos, videos or other digital content.

• Profile Data : includes your username and password, in-App history, your interests, preferences, feedback and survey responses.

• Usage Data : includes details of your use of any of our Apps or your visits to any of Our Sites including, but not limited to, traffic data and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.

• Marketing and Communications Data : includes your preferences in receiving marketing from us and our third parties and your communication preferences.

• Location Data : includes your current location disclosed by GPS technology or other technology.