TRUSTCLAN PRIVACY POLICY

1. Introduction

Trustclan, a product of A-Overwatch Ltd ("we," "our," or "us") is committed to protecting the privacy of its users. This Privacy Policy explains how we collect, use, store, share, and protect your information when you use the Trustclan mobile application, website, and related services (collectively, the "Platform").

By using Trustclan, you agree to the practices described in this Privacy Policy.

2. Information We Collect

When you use Trustclan, we collect information necessary to provide our services, ensure security, comply with legal obligations, and improve your overall experience on the Platform. This information may be provided directly by you, collected automatically through your use of the Platform, or obtained from trusted third-party partners where applicable.

2.1 Information You Provide

We collect information that you voluntarily provide when you create an account, participate in ajo or cooperative activities, interact with other users, or contact our support team.

This includes personal information such as your full name, phone number, email address, date of birth, and residential address. In order to comply with regulatory requirements, we may also request identification documents such as your National Identification Number (NIN), Bank Verification Number (BVN), passport, or other government-issued ID. Where applicable, you may also choose to upload a profile photo or provide additional personal details.

To facilitate financial transactions on Trustclan, we collect certain financial information, including your bank account details and records of your activity on the Platform, such as contributions, payouts, savings, and any cooperative loan interactions. Payment-related data is securely processed through licensed third-party provider in jurisdiction we operate, and Trustclan does not store full debit card details.

Because Trustclan enables group-based financial activities, we also collect data related to your participation in ajo and cooperative groups. This includes your group memberships, contribution schedules, payment performance, roles within groups (such as admin or member), and any relevant activity within those groups. This information helps ensure transparency, accountability, and proper functioning of group operations.

Additionally, we collect information you provide when you communicate with us. This may include messages sent to customer support, feedback, complaints, survey responses, or any other content submitted through forms or within the Platform. We retain this information to assist you, resolve disputes, and improve our services.

Where you choose to connect third-party services to your Trustclan account, we may receive certain information from those services, such as identity verification data or payment confirmations. The information shared depends on your permissions and the third party's policies.

2.2 Information We Collect Automatically

When you access or use Trustclan, we automatically collect certain technical and usage information to maintain the security, functionality, and performance of the Platform.

This includes device and connection information such as your IP address, device type, operating system, browser type, and network details. We also collect data about how you interact with the Platform, including the pages you visit, features you use, time spent on the Platform, and general navigation patterns. This helps us understand user behavior and continuously improve our services.

For security and fraud prevention purposes, we monitor login activity, including timestamps, device usage, and general location patterns. We may also detect and analyze unusual behavior, failed login attempts, or suspicious transactions to protect both users and the Platform from unauthorized access or fraudulent activity.

In some cases, we may collect approximate location information derived from your IP address or device settings to enhance security and comply with regulatory requirements. We do not collect precise GPS location without your explicit consent.

We also use cookies and similar tracking technologies to maintain your session, remember your preferences, and gather analytics data. These technologies help improve functionality, enhance user experience, and ensure the Platform operates efficiently.

This information collectively allows us to operate Trustclan effectively, facilitate ajo and cooperative activities, comply with Know Your Customer (KYC) and Anti-Money Laundering (AML) requirements, prevent fraud, and deliver a secure and seamless user experience.

3. How We Use Your Information

We use your personal data to operate, maintain, and improve the Trustclan Platform, as well as to deliver secure and efficient financial services to our users. The information we collect is essential for enabling ajo contributions, cooperative savings, and related financial activities, while also ensuring compliance with applicable laws and regulations.

One of the primary ways we use your information is to verify your identity. This includes carrying out Know Your Customer (KYC), Anti-Money Laundering (AML), and other regulatory checks required under Nigerian law. These processes help us confirm that users are who they claim to be and reduce the risk of fraud, financial crime, or misuse of the Platform.

We also use your information to create, manage, and maintain your Trustclan account. This includes enabling you to join or create ajo groups, participate in cooperative savings, track your contributions, and access other features available on the Platform. Your financial and transactional information is used to facilitate payments, process contributions and payouts, and ensure that all activities are accurately recorded and securely executed.

In addition, we continuously monitor activity on the Platform to detect, prevent, and investigate fraud, unauthorized transactions, and other suspicious behavior. This helps us protect both individual users and the overall integrity of Trustclan. Where necessary, we may use your information to enforce our Terms of Service, investigate potential violations, and take appropriate action.

Your information is also used to communicate with you. This includes sending important service-related notifications such as transaction confirmations, payment reminders, updates to your ajo or cooperative groups, security alerts, and changes to our policies or features. We may also send you product updates, promotional messages, or other relevant information, subject to your communication preferences.

To improve our services, we analyze user behavior, feedback, and usage patterns. This allows us to enhance existing features, develop new products, and optimize the overall user experience. Your data may also be used for internal business operations such as performance monitoring, data analysis, research, and reporting.

We use your information to provide customer support and resolve disputes. For example, we may review transaction histories, communications, or account activity to investigate issues, respond to complaints, and ensure fair outcomes between users in group-based financial arrangements.

Finally, we use your data to comply with legal and regulatory obligations. This includes maintaining records, responding to lawful requests from authorities, conducting audits, and fulfilling requirements imposed by financial regulators. In certain situations, your information may also be used to protect our legal rights, manage risk, or support business transactions such as mergers or acquisitions.

Overall, we only use your personal data for legitimate and lawful purposes, and we do not use it in ways that are inconsistent with this Privacy Policy without your consent.

4. Sharing of Information

Trustclan respects your privacy and is committed to protecting your personal data. We do not sell, rent, or trade your personal information to third parties for their marketing or commercial purposes.

However, in order to operate our Platform effectively and provide our services, we may share your information in certain limited and controlled circumstances.

We may share your information with trusted third-party service providers who perform services on our behalf. These include payment infrastructure provider, identity verification partners, cloud storage providers, and analytics services. These third parties are only given access to the information necessary to perform their functions and are required to handle your data securely and in accordance with applicable data protection laws.

Because Trustclan facilitates group-based financial activities such as ajo and cooperative savings, certain limited information may be visible to other users within your group. For example, your name, credit score, contribution status, payment history within the group, and role (such as admin or member) may be accessible to other members for transparency and accountability. We ensure that only the minimum necessary information is shared in these contexts.

We may also disclose your information where required to comply with applicable laws and regulations in Nigeria. This includes responding to lawful requests from government authorities, regulators, or law enforcement agencies, as well as fulfilling obligations related to financial compliance, fraud prevention, and anti-money laundering requirements. In addition, we may use or share your information to enforce our Terms of Service, investigate potential violations, or protect the rights, property, and safety of Trustclan, our users, or others.

In the event that Trustclan undergoes a business transaction such as a merger, acquisition, restructuring, or sale of assets, your information may be transferred as part of that transaction. In such cases, we will ensure that appropriate safeguards are in place to protect your data and that any new entity continues to process your information in a manner consistent with this Privacy Policy.

In all circumstances, we take reasonable steps to ensure that any party with whom we share your data maintains appropriate security standards and complies with applicable privacy and data protection laws.

5. Cookies and Tracking Technologies

Trustclan uses cookies and similar tracking technologies to enhance your experience, improve the performance of our Platform, and ensure the security of user accounts. These technologies allow us to recognize your device, understand how you interact with our services, and provide a more personalized and efficient experience.

Cookies are small data files that are stored on your device when you visit a website or use an application. They enable the Platform to remember your actions and preferences over time, so you do not have to re-enter information each time you return.

5.1 How We Use Cookies

We use cookies for several important purposes related to the functionality and security of Trustclan. For example, cookies help keep you logged into your account during a session and allow you to navigate the Platform without interruption. They also enable us to remember your preferences, such as language settings or previously selected options, so that your experience remains consistent and personalized.

In addition, cookies allow us to better understand how users interact with the Platform. By analyzing usage patterns—such as which features are most frequently used or how long users spend on certain pages—we are able to improve performance, optimize design, and develop new features that better meet user needs.

Cookies also play a critical role in maintaining security. They help us detect unusual activity, prevent unauthorized access, and reduce the risk of fraud by identifying suspicious behavior or irregular login patterns.

5.2 Types of Cookies We Use

Trustclan may use different categories of cookies, including those that are strictly necessary for the operation of the Platform, as well as those used for analytics and performance monitoring. Some cookies are temporary and expire when you close your browser (session cookies), while others remain on your device for a longer period to remember your preferences (persistent cookies).

5.3 Third-Party Cookies

In some cases, we use cookies provided by trusted third-party service providers. These may include analytics tools that help us understand how users engage with Trustclan and identify areas for improvement. These third-party cookies may collect information such as how long you spend on the Platform, the pages you visit, and how you navigate through the application.

We ensure that any third-party providers we work with are reputable and are required to process your data in accordance with applicable data protection laws.

5.4 Your Choices and Control

You have the ability to control how cookies are used on your device. Most web browsers allow you to manage cookie settings, including blocking or deleting cookies entirely. However, please note that disabling cookies may affect the functionality of Trustclan and limit your ability to access certain features, such as staying logged in or using secure areas of the Platform.

By continuing to use Trustclan without adjusting your browser settings, you consent to our use of cookies and similar tracking technologies as described in this Privacy Policy.

6. Data Security

Trustclan is committed to protecting the security and confidentiality of your personal and financial information. We implement a variety of technical, administrative, and physical measures to safeguard your data against unauthorized access, disclosure, alteration, or destruction.

Sensitive information, including your personal identification and financial data, is encrypted both in transit and at rest. Our servers are secured with firewalls and other protective technologies to prevent unauthorized access. Access to personal data within Trustclan is strictly limited to authorized personnel who require it to perform their job responsibilities, and all employees are trained in data privacy and security best practices.

We continuously monitor our systems to detect potential threats, suspicious activity, and security breaches. Any unusual activity is promptly investigated to prevent fraud and to maintain the integrity of the Platform.

Financial data, such as bank account details and payment information, is processed securely through licensed and regulated third-party providers. Trustclan staff do not have full access to this data, ensuring that your sensitive financial information is handled in compliance with applicable financial regulations and industry best practices.

By combining these measures, we aim to provide a safe and secure environment for all users while maintaining trust and compliance with relevant data protection standards.

7. Data Retention

Trustclan retains your personal information only for as long as it is necessary to provide services, comply with legal obligations, and protect both the Platform and its users. This includes retaining data for account management, facilitating ajo and cooperative transactions, and maintaining accurate records of user activity.

Your information may be retained while your account is active and for a reasonable period after account closure to allow for fraud prevention, dispute resolution, and enforcement of our Terms of Service. We are also required to retain certain records in accordance with applicable laws and regulations, including Anti-Money Laundering (AML) and financial compliance requirements.

Typically, personal data is retained for a minimum of five (5) years following account closure or the completion of regulatory obligations. After this period, we take appropriate measures to securely delete, anonymize, or de-identify your personal information so that it can no longer be associated with you.

By retaining information responsibly, we ensure the integrity of financial transactions, protect the Trustclan community from fraud, and comply with legal and regulatory standards in Nigeria.

8. Your Rights

As a user of Trustclan, you have certain rights regarding the personal information we collect and process. These rights are designed to give you greater control over your data and ensure that it is handled transparently and responsibly.

You have the right to access the personal information we hold about you. This allows you to review the data we maintain, understand how it is being used, and ensure its accuracy. If you believe that any information we hold is incorrect or outdated, you have the right to request correction or updating of that information.

In certain circumstances, you may request the deletion of your personal data. Please note, however, that we may need to retain specific information to comply with legal obligations, resolve disputes, or prevent fraud.

You also have the right to manage your communication preferences, including opting out of marketing or promotional messages. Additionally, you may request restrictions on certain processing activities, which allows you to limit how your personal information is used while still maintaining access to essential services.

To exercise any of these rights, you can contact Trustclan's support team via the designated support channels. We will respond to your request in a timely manner and take appropriate action in accordance with applicable laws and regulations.

9. Sharing and Disclosure of Aggregated Data

In addition to the limited sharing of personal data described earlier, Trustclan may use aggregated, anonymized, or de-identified information for analytical purposes. This data does not identify individual users and may be used to monitor trends, improve the Platform, develop new services, or provide insights to third-party partners.

For example, we may report statistics on overall ajo participation, contribution trends, or app usage patterns. Since this information cannot be linked back to any specific individual, it does not compromise your privacy.

10. Links to Other Websites

Trustclan may provide links to third-party websites or services. Please note that these websites have their own privacy policies and practices, which may differ from ours. Trustclan is not responsible for the privacy or security of information you provide to third parties. We encourage you to read the privacy policies of any websites or services you access through the Platform.

11. Third-Party Services and Payment Providers

Certain services on Trustclan, such as payment processing, identity verification, or cloud storage, are provided by licensed and trusted third-party partners. Your personal and financial information may be shared with these providers solely for the purposes of performing their services.

These third-party providers are required to protect your information in accordance with applicable data protection laws and are only authorized to use your information for the purposes outlined in their agreements with Trustclan. Notably, sensitive financial information is processed securely and is not fully accessible to Trustclan staff, minimizing risk of exposure.

12. Changes to This Privacy Policy

Trustclan may update this Privacy Policy from time to time to reflect changes in our practices, regulatory requirements, or new features. When we make updates, we will revise the "Last Updated" date at the top of the policy and, where appropriate, notify users through the Platform, email, or in-app notifications.

Your continued use of Trustclan after such updates constitutes your acceptance of the revised Privacy Policy. We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your information.

13. Contacting Trustclan

If you have any questions, concerns, or requests regarding this Privacy Policy, your personal information, or your rights as a user, you may contact our support team through the following channels:

• Email: support@trustclan.com
• In-app Support Chat: Accessible from your Trustclan account
• Phone: [Insert local support line]

We are committed to responding promptly to all inquiries and ensuring that your questions regarding privacy and data protection are addressed.