This Privacy Policy ("Policy") describes how BlackCircle Ltd, a company incorporated in the Federal Republic of Nigeria with RC number 8901137, trading as BlackCircle, and its registered office at Mansard Place, Plot 927/928 Bishop Aboyade Cole, Victoria Island, Lagos, Nigeria ("BlackCircle," "the Company," "we," "us," or "our"), collects, uses, discloses, and otherwise processes personal data in connection with the website located at blackcircle.africa (the "Site") and any related service, product, or engagement, whether now offered or introduced in the future (collectively, the "Services").
For the purposes of this Policy, "personal data," "processing," "data subject," "data controller," and "data processor" shall have the meanings ascribed to them under the Nigeria Data Protection Act 2023 ("NDPA") and its subsidiary regulations, and, where applicable to a data subject, any other data protection law of the jurisdiction from which the Site or Services are accessed.
This Policy is drafted to apply broadly across BlackCircle's current and future business activities. Where a specific Service involves the collection of additional categories of personal data not described in this Policy, BlackCircle will provide a supplementary notice or update this Policy prior to, or at the point of, that collection, to the extent required by applicable law.
For the purposes of the NDPA and any other applicable data protection law, BlackCircle Ltd is the data controller in respect of personal data processed through the Site and the Services, save where BlackCircle acts as a data processor on behalf of a client pursuant to a separate Service Agreement, in which case the terms of that Service Agreement shall govern the parties' respective data protection obligations.
We may collect and process the following categories of personal data:
We do not knowingly collect any special category of personal data (as defined under applicable data protection law) through the Site, and you should not submit any such data to us through our enquiry form or other general communication channels.
We process personal data for the following purposes, on the following legal bases under the NDPA and, where applicable, other data protection law:
We do not sell personal data, and we do not use personal data for automated decision-making that produces legal or similarly significant effects concerning you without appropriate safeguards and, where required, your explicit consent.
We may disclose personal data to the following categories of recipients, in each case only to the extent reasonably necessary for the purposes described in this Policy:
We require that any third party to whom we disclose personal data provides an appropriate level of protection for that data, consistent with our obligations under applicable data protection law.
Personal data we collect may be stored, processed, or transferred to countries other than Nigeria, including where our service providers or infrastructure are located outside Nigeria. Where such a transfer takes place, we will take steps required under the NDPA and applicable subsidiary regulations to ensure the personal data receives an adequate level of protection, including, where necessary, through the use of standard contractual clauses, data processing agreements, or other lawful transfer mechanisms recognized under applicable law.
We and our service providers use cookies, pixels, and similar tracking technologies to operate the Site, remember preferences, and understand how the Site is used, including through aggregated analytics. You may control or disable cookies through your browser settings; doing so may affect the availability or functionality of certain features of the Site. Where required by applicable law, we will obtain your consent before placing non-essential cookies on your device.
We retain personal data for no longer than is necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, regulatory, or reporting requirement, or to establish, exercise, or defend legal claims. In determining the appropriate retention period, we consider the amount, nature, and sensitivity of the personal data, the purposes for which it is processed, and applicable legal and regulatory requirements. Where personal data is no longer required, we will securely delete or anonymize it in accordance with our internal data retention practices.
We implement appropriate technical and organizational measures designed to protect personal data against unauthorized or unlawful processing, accidental loss, destruction, or damage, having regard to the state of the art, the costs of implementation, and the nature, scope, context, and purposes of processing, as well as the risk of varying likelihood and severity to the rights of data subjects. No system of transmission or storage can be guaranteed to be completely secure, and we cannot warrant the absolute security of any personal data transmitted to or by us.
Subject to applicable law, including the NDPA, you may have the right to: request confirmation of, and access to, the personal data we hold about you; request correction of inaccurate or incomplete personal data; request erasure of personal data, subject to applicable legal and contractual retention requirements; object to, or request restriction of, certain processing of your personal data; request a copy of certain personal data in a structured, commonly used, and machine-readable format; withdraw any consent you have previously given, without affecting the lawfulness of processing carried out before such withdrawal; and lodge a complaint with the Nigeria Data Protection Commission or another competent supervisory authority.
To exercise any of these rights, please contact us using the details in Section 14. We may request additional information reasonably necessary to verify your identity before responding to your request, and we will respond within the timeframe prescribed by applicable law.
The Site and Services are directed at businesses and individuals acting in a professional or adult capacity, and are not intended for, and should not be used by, individuals under the age of eighteen (18). We do not knowingly collect personal data from children. If we become aware that we have inadvertently collected personal data from a child, we will take reasonable steps to delete that data promptly.
The Site may contain links to third-party websites or services not operated or controlled by BlackCircle. This Policy does not apply to any third-party website or service, and we are not responsible for the privacy practices of any such third party. We encourage you to review the privacy policy of any third-party website or service before providing any personal data to it.
We may amend this Policy from time to time, in our sole discretion, to reflect changes in our data processing practices, Services, or applicable law. The amended Policy will be posted on this page together with a revised effective date, and, where the change is material, we will use reasonable efforts to provide additional notice through the Site. Your continued use of the Site or any Service following the posting of an amended Policy constitutes your acknowledgment of that amended Policy.
Questions, requests, or complaints regarding this Policy or our processing of your personal data may be directed to us at hello@blackcircle.africa, or by post at Mansard Place, Plot 927/928 Bishop Aboyade Cole, Victoria Island, Lagos, Nigeria. If you are not satisfied with our response, you may have the right to lodge a complaint with the Nigeria Data Protection Commission or another competent supervisory authority in your jurisdiction.
