Cirrden Privacy Policy

Cirrden is operated by Cirrden Innovation Services, a business registered in Nigeria under the Companies and Allied Matters Act 2020 (Business Name Registration No. 7975540). Under data protection law, we are the controller of your personal data. You can reach us about anything in this policy at privacy@cirrden.com.

Cirrden is for users aged 18 and older. We do not knowingly collect data from anyone under 18. If we learn an account belongs to someone under 18, we close the account and delete its data.

Account information. Your name, username, email address, phone number, country, and password (stored hashed, we cannot read it).

Profile information. Photo, bio, and any links you add.

Your content and activity. Videos, clips, posts, comments, likes, saves, reshares, the Circles you create or join, and what you watch.

Topics and preferences. The topics you pick and the creators you follow. This is what powers your home feed.

Wallet and payment data. Your wallet balance, transaction history, billing country, and currency. For creators, payout details such as your bank account. Card payments are processed by our payment partners. We never see or store your full card number.

Identity verification. Where required for creator payouts or by law, we collect verification information.

Usage and device data. IP address, browser type, device information, and how you move through the platform.

Communications. Emails you send us, replies to our emails, and support conversations.

• To run the platform: your account, your feed (built from your topics and activity), Circles, and everything you signed up for.
• To process payments to and from your wallet, and payouts to creators.
• To keep Cirrden safe: detecting fraud, abuse, spam, and impersonation.
• To communicate with you: transaction confirmations, product updates, and, only if you consent, marketing. You can unsubscribe from marketing at any time.
• To improve the product, using aggregated or anonymized data wherever possible.
• To meet our legal obligations.

• We do not sell your personal data. To anyone. Ever.
• We do not alter or manipulate your data. What you put in is what is there.
• We do not read your private Circles or private content for advertising.
• We do not use your content to train general-purpose AI models. Features that use AI to help you, like analytics or pricing suggestions, work on your own data, for your benefit.

• Payment processors (currently Paystack, Stripe, and Transfaar) to process transactions and payouts.
• Infrastructure providers that host the platform and deliver content.
• Email and analytics providers that help us send messages and understand product usage.
• Authorities, when legally required. We review every request and push back on requests that are overbroad.
• A buyer or successor, if Cirrden is ever acquired or merged. You would be notified before your data changes hands.

We never share your data with data brokers or sell audience lists to advertisers.

Cirrden operates from Nigeria and serves users in multiple countries. Your data may be processed outside your home country. When it is, we use recognized safeguards such as standard contractual clauses or transfers to jurisdictions with adequate protection.

When you delete your account, it enters a 30-day deletion window. During those 30 days your account is deactivated and invisible to other users. If you change your mind, contact our support team within the window and we will restore your account. After 30 days, your account and personal data are permanently deleted.

One exception, because the law requires it: records of financial transactions (payments, payouts, and wallet activity) are retained for as long as financial regulations require, even after account deletion. These records are kept for legal compliance only and are never used for anything else.

Wherever you are, you can:

• Access the personal data we hold about you.
• Correct data that is wrong.
• Delete your account and data (see the 30-day window above).
• Export your data in a portable format.
• Object to or restrict certain processing.
• Withdraw consent for anything that runs on consent, like marketing.
• Complain to your data protection regulator.

To exercise any of these, email privacy@cirrden.com. We respond within one calendar month.

Nigeria. We comply with the Nigeria Data Protection Act 2023 (NDPA). Our regulator is the Nigeria Data Protection Commission (NDPC).

European Economic Area and the United Kingdom. We process personal data under the GDPR and UK GDPR on these legal bases: performance of our contract with you (running your account), your consent (marketing), our legitimate interests (product improvement and safety), and legal obligation. You may lodge a complaint with your local supervisory authority.

United States. Residents of states with privacy laws (including California) have rights to know, delete, and correct their data, and to opt out of the sale of personal data. We do not sell personal data.

Kenya. We comply with the Data Protection Act 2019, regulated by the Office of the Data Protection Commissioner.

Ghana. We comply with the Data Protection Act 2012, regulated by the Data Protection Commission.

South Africa. We comply with the Protection of Personal Information Act (POPIA), regulated by the Information Regulator.

Data is encrypted in transit. Passwords are hashed. Access to personal data inside Cirrden is restricted to people who need it to do their jobs. We vet the providers we share data with. No system is perfectly secure, and if a breach affects your data we will notify you and the relevant regulator within the timelines the law requires.

If we make material changes, we will email you before they take effect. The latest version always lives at cirrden.com/privacy.

Cirrden Innovation Services (Business Name Registration No. 7975540)
43 Emmaco House, Back of Happiness Eatery, Zarmaganda - Rayfield Road, Jos, Plateau State, Nigeria
privacy@cirrden.com