Privacy Policy

Cirkle is an event marketplace that connects event organisers, attendees, and vendors. This Privacy Policy explains how TEETECH LIMITED ("Cirkle", "we", "us", "our") collects, uses, stores, shares, and protects personal information when you use our website at cirkl3.com, our mobile application, and related services.

We handle personal information in accordance with the Nigeria Data Protection Act (NDPA) 2023 and other applicable data protection law.

For any privacy question or request, contact privacy@cirkl3.com.

Account information

Accounts on Cirkle are created and secured through our authentication provider, Clerk. Through Clerk we receive:

• Your name
• Your email address
• Your profile image, where you provide one

We do not store your password. Authentication credentials are held by Clerk and are never visible to Cirkle.

Ticket and order information

When you buy a ticket, stall, or vendor package we collect and store:

• The items purchased, quantities, and amounts, in Nigerian Naira
• Your order and payment reference, payment status, and payment channel
• The digital passes issued to you, including their check-in status and time of scan

Organiser information

If you create or join a planner organisation we collect:

• Organisation name, description, logo, and categories
• Social media links you choose to publish
• Settlement details used to receive payouts, being your bank code, account number, and account name

Settlement details are used to create a payout account with our payment provider. Cirkle stores the bank code, account number, and account name you supply.

Vendor information

If you apply to be a vendor at an event we collect:

• Your business name
• Your WhatsApp number
• Your answers to the application questions that the event organiser has created, which vary by organiser
• Your acceptance of that organiser's vendor terms, with the date and time
• Your business logo, category, and any social media links you add to your vendor profile

Application answers are shared with the organiser of the event you applied to. Please do not include information in a free text answer that you do not want that organiser to see.

If you use the vendor stock tools, we store the products, prices, stock levels, and sales movements you record. This information is private to your vendor account.

Content you upload

Images and files you upload, such as event banners, organisation logos, and product or vendor images, are stored with our file storage provider.

Technical information

We collect limited technical information necessary to operate and secure the service, including IP address, device and browser information, and server log data recording requests to our systems. We keep audit records of significant actions on the Platform, such as approvals, payments, suspensions, and check-ins.

What we do not collect

• We do not collect or store complete payment card details. Card data is entered on Paystack's own hosted payment page and is handled by Paystack.
• We do not currently collect government identification documents or company registration documents from vendors or organisers. If we introduce verification of this kind in future, we will update this Policy first.
• We do not currently run advertising or third party analytics tracking on the Platform.

We use personal information to:

• Create and operate your account
• Process orders and issue passes
• Present vendor applications to the relevant organiser for their decision
• Enable entry management and check-in at events
• Process payments, commission, subscriptions, and payouts through our payment provider
• Provide customer support
• Send service messages such as order confirmations, approvals, and event changes
• Detect and prevent fraud, abuse, and unauthorised access
• Maintain records required for accounting, tax, and dispute resolution
• Improve the reliability and performance of the Platform
• Comply with legal obligations

We do not sell your personal information.

Legal bases

Depending on the activity we rely on: performance of a contract with you; compliance with a legal obligation; our legitimate interests in operating a secure and functioning marketplace; and your consent, where consent is required.

Event organisers

When you purchase a ticket, the organiser of that event can see the order and the name associated with it, so they can manage attendance and admission.

When you apply as a vendor, the organiser of that event can see your business name, WhatsApp number, your answers to their application questions, your vendor profile details, and your payment status.

Other users, where you choose

Where you are an approved and paid vendor at an event, your business name, logo, and social links may be displayed publicly on that event's page. Organisation profiles and published events are public by design.

Service providers

We use the following providers to operate the Platform. Some of them store or process data outside Nigeria, which means your information may be transferred internationally.

Where personal data is transferred outside Nigeria we take steps intended to ensure it remains protected to a standard consistent with the NDPA.

Legal and safety

We may disclose information where required by law, regulation, court order, or a competent authority, or where necessary to investigate fraud, protect our rights, or protect the safety of users.

We apply technical and organisational measures appropriate to the risk, including:

• Transport encryption for all traffic to and from the Platform
• Authentication handled by a specialist provider, with no passwords stored by Cirkle
• Cryptographically signed entry passes, so that passes cannot be forged
• Verification of the authenticity of payment notifications received from our payment provider
• Separation of data between organisations, so one organiser cannot access another's records
• Role based access controls and audit logging of significant actions
• Credentials and secrets held in managed configuration, not in our source code

No online platform can guarantee absolute security. Please protect your own email account, since access to it can allow access to your Cirkle account.

We keep personal information only as long as necessary for the purposes described in this Policy.

• Account and profile information is kept while your account is active.
• Order, payment, and commission records are retained after account closure, because we are required to keep financial records for accounting, tax, and dispute purposes, and to defend legal claims. Where we retain such records after a deletion request, we remove or replace the personal identifiers so that the records are no longer linked to you by name or email.
• Audit and security logs are kept for a limited period appropriate to their purpose.

Under the NDPA and other applicable law you may have the right to:

• Ask what personal information we hold about you and obtain a copy
• Ask us to correct inaccurate or incomplete information
• Ask us to delete your information, subject to the retention rules above
• Object to, or ask us to restrict, certain processing
• Withdraw consent where we rely on consent
• Complain to the Nigeria Data Protection Commission

To exercise any of these rights, contact privacy@cirkl3.com. We will respond within the period required by applicable law. We may need to verify your identity first.

You can request deletion of your account from within the Cirkle app and website, in your account settings. You do not need to email us, although you may do so at privacy@cirkl3.com if you prefer.

When you request deletion:

• If you have no outstanding financial activity, we schedule your account for deletion and you can cancel the request during the grace period.
• If you are an organiser with paid orders, or a vendor with paid bookings, we cannot delete the account immediately. We will contact you so that outstanding obligations to attendees, vendors, or organisers can be resolved first.
• When deletion is completed, we remove or replace your personal identifiers. Financial records are retained in anonymised form as described in section 6.

Cirkle is not intended for children. You must be at least 18 years old to create an account, purchase tickets, publish events, or apply as a vendor. We do not knowingly collect personal information from children. If you believe a child has provided us with personal information, contact privacy@cirkl3.com and we will take appropriate steps.

See our Cookie Policy. In summary, we currently use only strictly necessary cookies, principally to keep you signed in and to keep your session secure.

We may update this Policy. The current version is always published on the Platform with its revision date. Where changes are material we will give notice through the Platform or by email before they take effect.

Privacy and data protection: privacy@cirkl3.com General support: hello@cirkl3.com

TEETECH LIMITED (RC 9838377) No. 10 Abdulkareem Adisa Close, Guzape, FCT, Nigeria Data Protection Officer: [[PENDING APPOINTMENT]]