Privacy Policy for The Challenge Circle Limited

Last Updated: 10-02-2026

Introduction

THE CHALLENGE CIRCLE LIMITED (“Company,” “we,” “us,” or “our”) operates the website https://thecircle.ng (the “Site”). This Privacy Policy informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Site and the choices you have associated with that data.

We are committed to protecting your privacy and handling your data in an open and transparent manner. This policy complies with the Nigeria Data Protection Regulation (NDPR) and reflects international best practices.

Information We Collect

We collect several types of information from and about users of our Site, including:

Personal Data You Provide to Us

While using our Site, we ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). This information is provided voluntarily when you create an account, make a purchase, or join our community:

· Identity and Contact Information:
· Full name
· Email address
· Phone number (including WhatsApp)
· Telegram ID
· Physical address
· Profile picture
· Membership Information:
· What you hope to learn
· What you currently do professionally or personally
· Your reasons for joining our community

Cookies and Usage Data

· Cookies: Our Site uses cookies to enhance your experience. Cookies are small files stored on your device (computer or mobile device) that help us understand how you interact with our Site. We use cookies to:
· Keep you logged into your account
· Remember your preferences
· Understand which pages are most popular
· Improve site functionality
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Site.
· Google Analytics: We use Google Analytics to understand how visitors interact with our Site. Google Analytics uses cookies to collect anonymous information such as the number of visitors, which pages they visit, and how long they spend on the site. This data helps us improve our content and user experience. Google’s ability to use and share information collected by Google Analytics is restricted by the Google Privacy Policy.

Payment Data

We do not store financial information like credit card details. All payments are processed securely through third-party payment processors. When you make a purchase, you will provide your payment information directly to:

· Paystack
· Flutterwave

These processors handle your data in accordance with their own privacy policies. We receive confirmation of successful payments but never see your full financial details.

How We Use Your Information

THE CHALLENGE CIRCLE LIMITED uses the collected data for various purposes:

· To Provide and Maintain Our Service:
· Creating and managing your membership account
· Verifying your identity as a member
· Granting you access to exclusive Telegram and WhatsApp groups
· To Facilitate Community Networking:
· Connecting you with other members based on shared interests or goals
· Enabling internal communication within our community platforms
· To Communicate With You:
· Sending important updates, announcements, and administrative information
· Responding to your inquiries via email or contact form
· Providing customer support
· To Improve Our Site and Services:
· Analyzing how users interact with our Site (via Google Analytics)
· Understanding member demographics and preferences
· Developing new features and offerings based on member feedback and goals
· To Process Transactions:
· Managing membership subscriptions
· Processing product purchases (facilitated by Paystack and Flutterwave)
· To Protect Our Legal Interests:
· Detecting, preventing, and addressing fraudulent or unauthorized access
· Enforcing our terms and conditions

Legal Basis for Processing (NDPR Compliance)

If you are located in Nigeria, our legal basis for collecting and using your personal information depends on the specific context. We typically process your data where:

· Consent: You have given us permission to do so for a specific purpose (e.g., joining our community).
· Contract: The processing is necessary for the performance of a contract with you (e.g., providing membership access you’ve paid for).
· Legitimate Interests: The processing is necessary for our legitimate interests (e.g., improving our Site, ensuring network security) and is not overridden by your rights.
· Legal Obligation: The processing is necessary for compliance with the law.

Third-Party Service Providers

We may employ third-party companies and individuals to facilitate our Site (“Service Providers”), to provide services on our behalf, or to assist us in analyzing how our Site is used. These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

· Payment Processors:
· Paystack: Handles payment transactions. View their privacy policy at paystack.com/privacy
· Flutterwave: Handles payment transactions. View their privacy policy at flutterwave.com/ng/privacy-policy
· Analytics:
· Google Analytics: Tracks and reports website traffic. View their privacy policy at policies.google.com/privacy
Community Platforms (Telegram & WhatsApp)

Please be aware that our community interaction occurs on third-party platforms: Telegram and WhatsApp. While we maintain strict admin policies to govern conduct and access within these groups:

· Your activities on these platforms are also subject to their own Terms of Service and Privacy Policies.
· We encourage you to review the privacy settings and policies of Telegram and WhatsApp to understand how they handle your information.

Data Security

The security of your data is important to us. We have implemented appropriate technical and organizational measures to protect your personal information against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access. These measures include:

· SSL Encryption: All data transmitted between your browser and our Site is encrypted using Secure Sockets Layer (SSL) technology.
· Strict Access Controls: We enforce strict administrative policies governing who has access to member data and community platforms.
· Limited Data Retention: We only retain your data for as long as necessary to fulfill the purposes outlined in this policy.

However, please remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

Your Data Protection Rights

THE CHALLENGE CIRCLE LIMITED aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data. You have the following rights concerning your data:

· The Right to Access: You have the right to request copies of your personal data held by us.
· The Right to Rectification: You have the right to request that we correct any information you believe is inaccurate or complete information you believe is incomplete. You can do this directly by logging into your account settings.
· The Right to Erasure (The “Right to be Forgotten”): You have the right to request that we erase your personal data, under certain conditions.
· The Right to Restrict Processing: You have the right to request that we restrict the processing of your personal data, under certain conditions.
· The Right to Object to Processing: You have the right to object to our processing of your personal data, under certain conditions.
· The Right to Data Portability: You have the right to request that we transfer the data we have collected to another organization, or directly to you, under certain conditions.

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us using the information provided in the “Contact Us” section below.

Children’s Privacy

Our Site is not directed to children under the age of 18 (or the applicable age of majority in your jurisdiction). We do not knowingly collect personally identifiable information from anyone under this age. If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from a child without verification of parental consent, we take steps to remove that information from our servers.

International Data Transfers

Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction. Specifically, our third-party service providers (like Google Analytics, Paystack, and Flutterwave) may store and process data in countries other than Nigeria.

If you are located outside Nigeria and choose to provide information to us, please note that we transfer the data, including Personal Data, to Nigeria and process it there. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Refund Policy

At THE CHALLENGE CIRCLE LIMITED, we provide primarily digital services including memberships, trainings, webinars, seminars, and access to online platforms.

All payments made to Challenge Circle through bank transfer, Paystack, Flutterwave, card payment, Selfany store, or any other approved channel are final and non-refundable.

Once payment is made, no refund, reversal, or cash return will be issued except if duplicate transaction is identified or product/service is not gotten after payment

If you experience a payment issue such as a failed transaction or double payment, kindly contact us through our official communication channels for support and verification.

By making payment for any of our services, you agree to this Refund Policy.

Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the “Last Updated” date at the top of this policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page. In the case of material changes, we may provide a more prominent notice (such as an email notification).

Contact Us

If you have any questions about this Privacy Policy, or if you wish to exercise any of your data protection rights, please contact us:

· By Email: challengecirclecore@gmail.com
· Through Our Website: Visit https://thecircle.ng and use the “Contact Us” form.
· By Mail: THE CHALLENGE CIRCLE LIMITED, Abuja, Nigeria.