Effective date: [01/09/2025]
Who we are (Data Controller): (ReCircle Campus Ventures),(16 ENOBONG NYA STREET, IKOT-AKPANABIA, UYO, AKWA IBOM STATE, NIGERIA) ("ReCircle Campus", "we","us", "our").
Contact for privacy questions/DPO: privacy@recirclecampus.com (If/when we are classifies as a Data Controller/Processor of Major Importance under NDPA, we will publicly designate a DPO and publish their contact.)
This Privacy Policy explains how we collect, use, share, secure, and retain personal data when you use the ReCircle Campus mobile app and services (the “App” and “Service”). It applies to all users (including buyers, sellers, campus partners, and business sellers) in Nigeria and across Africa. While grounded in the Nigeria Data Protection Act 2023, this Policy is also designed to align with applicable data protection laws in other African jurisdictions and international best practices, to ensure a consistent standard of transparency, accountability, and user protection.
We process personal data in line with the NDPA principles (fairness, lawfulness, transparency, purpose limitation, data minimization, storage limitation, accuracy, confidentiality/integrity/availability, accountability, duty of care).
We collect the minimum data necessary to run a safe, student-first marketplace.
Device identifiers, IP address, app version, crash logs, basic diagnostics
Approximate location (for campus pick-up zones if you enable it)
Notification and email preferences, survey responses, ratings/reviews
We do not intentionally collect special category data (e.g., health, religion). If such data appears in a chat or listing, we will delete it where feasible.
We rely on one or more lawful bases recognized by the NDPA (consent, contract, legal obligation, vital interests, legitimate interests). Examples:
We share only what's necessary, with:
We do not sell your personal data
Our service providers may host or process data outside Nigeria. When we transfer personal data cross-border, we use safeguards recognized under NDPA s.41 (e.g., adequacy via law, Binding Corporate Rules, standard/contractual clauses, approved codes of conduct or certifications) to ensure an adequate level of protection before any transfer.
We keep data only as long as necessary for the purposes above, including to meet legal/accounting/AML obligations and to resolve disputes.
Examples:
When data is no longer needed, we securely delete or anonymize it.
Under NDPA you may have the right to: be informed; access; rectification; erasure (“be forgotten”); restriction; data portability; object to processing; not be subject to solely automated decision-making; and to report to the supervisory authority (NDPC). We will respond within NDPA timelines. To exercise your rights, email privacy@recirclecampus.com (we may ask for verification).
We may use automated checks (e.g., fraud/risk signals, duplicate listing detection). You have the right not to be subject to a decision based solely on automated processing that has legal or similar significant effects, and you can request human review.
We use appropriate technical and organizational measures to protect personal data, including multi-factor authentication (MFA) for account and administrative access, encryption in transit, role-based access controls, least-privilege permissions, audit logging, and regular staff training. While no platform can guarantee absolute security, these safeguards significantly reduce the risk of unauthorized access. We also encourage you to enable MFA where available and to keep your device and credentials safe.
The Service is intended for users 18+. We do not knowingly collect data from minors. If you believe a minor has provided data, contact privacy@recirclecampus.com and we will take appropriate action (e.g., delete/limit processing).
Our App and site use privacy-respecting analytics SDKs/cookies to understand performance and improve features (e.g., crash analytics, session diagnostics). You can manage certain permissions in your device settings; some features may not work without them.
The App may link to third-party sites/services we don't control. Their privacy practices are governed by their own policies.
We may update this Policy to reflect new features, providers, or legal guidance (including NDPC directives/GAID). We'll notify you via the App/email when material changes occur and indicate the “Effective date” above.