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CirclePlug Privacy
Our Privacy Policy
Welcome to Circleplug! This privacy Policy statement provides information about the personal information that CirclePlug (‘we, us’) collects and how we use and protect your personal information. By using the app/website, you agree to the practices described in this policy. 
Definitions
‘Data’ means collectively all information that you submit to CirclePlug Limited via the Website/App. This definition incorporates, where applicable, the definitions provided in the applicable Data Protection Laws.
‘Cookies’ means a small text file placed on your computer by this Website when you visit certain parts of the Website/App and/or when you use certain features of the Website/App. Details of the cookies used by this Website are set out in the Cookies Policy
‘Data Protection Laws’ means any applicable law relating to the processing of personal Data, including but not limited to the NDPR, and any national implementing and supplementary laws, regulations, and secondary legislation.
‘NDPR’ means the Nigeria Data Protection Regulation.
‘Circleplug’ / we or us means Circleplug a flagship product of Shypes Integrated Services Limited, a company incorporated in Nigeria with registered number 1199010.
‘User or you’ means any third party that accesses the Website and is not either (i) employed by Circleplug Limited and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to Circleplug Limited and accessing the Website in connection with the provision of such services; and
‘Website/App’ means the website that you are currently using, www.circleplug.com, and any sub-domains of this site unless expressly excluded by their own terms and conditions.
Personal information collection
CirclePlug may collect and use the following kinds of personal information:
information about your use of this website [Including] 
Account Information: We collect information you provide when you create an account, such as your name, username, email address, and profile picture.
User Content: We collect content you post, share, or interact with on our app, including posts, comments, messages, and media files.
Usage Data: We collect information about how you use the app, such as your interactions, preferences, and device information.
Location Data: With your permission, we may collect your device's location data to provide location-based features.
information about transactions carried out on this website. 
information that you provide for the purpose of subscribing to the website services (including, bank account details, card details, pin, or passcode
any other information that you send to CirclePlug.
Use of personal information
CirclePlug may use your personal information to: 
  • Administer this website/app.
  • Aersonalise the website/app for you.
  • Send you app-related updates and notifications.
  • Share your content with other users based on your privacy settings.
  • Enable your access to and use of the website services
  • Publish information about you on the website
  • Send to you products that you purchase.
  • Supply to your services that you purchase.
  • Send to your statements and invoices.
  • Collect payments from you.
  • Send you marketing communications.
Where CirclePlug discloses your personal information to its agents or third-party administrators for these purposes, the agent or third-party administrator in question will be obligated to use that personal information in accordance with the terms of this privacy statement.
In addition to the disclosures reasonably necessary for the purposes identified elsewhere above, CIRCLEPLUG may disclose your personal information to the extent that it is required to do so by law, in connection with any legal proceedings or prospective legal proceedings, and to establish, exercise or defend its legal rights.
Securing your data
CirclePlug will take reasonable technical and organisational precautions to prevent the loss, misuse, or alteration of your personal information.
CirclePlug will store all the personal information you provide on its secure servers.
All Information relating to electronic transactions entered via this website will be protected by encryption technology.
We implement security measures to protect your information from unauthorised access and data breaches. However, no method of data transmission over the internet is completely secure, and we cannot guarantee absolute security.
Cross-border data transfers
Information that CirclePlug collects may be stored and processed in and transferred between any of the countries in which CirclePlug operates to enable the use of the information in accordance with this privacy policy.
In addition, personal information that you submit for publication on the website will be published on the internet and may be available around the world.
You agree to such cross-border transfers of personal information.
Data Retention
Unless a longer retention period is required or permitted by law, we will only hold your Data on our systems for the period necessary to fulfil the purposes outlined in this privacy policy or until you request that the Data be deleted. Even if we delete your Data, it may persist on backup or archival media for legal, tax or regulatory purposes.
Your rights
You have the following rights in relation to your Data:
a. Right to access - the right to request (i) copies of the information we hold about you at any time, or (ii) that we modify, update, or delete such information. If we provide you with access to the information we hold about you, we will not charge you for this, unless your request is "manifestly unfounded or excessive." Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.
b. Right to correct - the right to have your Data rectified if it is inaccurate or incomplete.
c. Right to erase - the right to request that we delete or remove your Data from our systems.
d. Right to restrict our use of your Data - the right to "block" us from using your Data or limit the way in which we can use it.
e. Right to data portability - the right to request that we move, copy, or transfer your Data.
f. Right to object - the right to object to our use of your Data including where we use it for our legitimate interests.
To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Data (where consent is our legal basis for processing your Data), please contact us via this e-mail address: dpo@shypes.com.

If you are not satisfied with the way a complaint you make in relation to your Data is handled by us, you may be able to refer your complaint to the relevant data protection authority. For Nigeria, this is the Nigeria Data Protection Regulation (NDPR)).
It is important that the Data we hold about you is accurate and current. Please keep us informed if your Data changes during the period for which we hold it.
Other websites
This website contains links to other websites.
CirclePlug is not responsible for the privacy policies or practices of any third-party.
Children's Privacy
Our app/website is not intended for users under the age of 13years. We do not knowingly collect personal information from children.
Changes to This Policy
We may update this Privacy Policy. We'll notify you of significant changes through app notifications or other means.
Our Contact:
info@shypes.com
If you have any questions about this privacy policy or wish to report use of your personal information, please write by email to:
info@circleplug.com,
dpo@shypes.com
General
You may not transfer any of your rights under this privacy policy to any other person. We may transfer our rights under this privacy policy where we reasonably believe your rights will not be affected. If any court or competent authority finds that any provision of this privacy policy (or part of any provision) is invalid, illegal, or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this privacy policy will not be affected.
Unless otherwise agreed, no delay, act, or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy. This Policy will be governed by and interpreted according to the law of Nigeria. All disputes arising under the Policy will be subject to the exclusive jurisdiction of the Chartered Institute of Arbitration Nigeria (UK Branch).