Your information deserves care, too.

Encirkle ("Encirkle", "we", "us") is operated by [registered legal entity name], registered in Nigeria under RC number: 9977917. We are the data controller for the personal information described in this policy.

Privacy contact: Adedoyin Ajayi, dedoyinajayi@gmail.com

We aim to collect only what we need for the service you ask for.

When you register or make an enquiry

• Name, email address and phone number
• The Circle or service you are interested in
• Any message you choose to send us

When you join a Circle

• Contact details and a preferred display name
• Your agreement to the Circle's participation guidelines
• Information you choose to share during sessions (see section 8)

When you book Encirkle Care services

• Contact details, date of birth and location (city or state)
• Your reason for seeking support, as much as you choose to tell us
• Booking, scheduling and payment details
• Where applicable, information needed for clinical assessments, which is collected and held by the practitioner delivering that service

When you join our mailing list

• Name and email address, plus your subscription preferences

Automatically, when you use our website

• Device, browser and approximate location data, pages visited and how you arrived (see section 10)

Sensitive information

Much of what you share with us may relate to your mental health, emotional wellbeing, relationships or habits such as gambling or alcohol use. Under Nigerian law this can count as sensitive personal data and receives stronger protection. We process it only with your explicit consent or another basis the law permits. You never have to share more than you are comfortable with.

We do not sell your personal information. We do not use it for advertising profiles or make decisions about you through automated processing alone.

We use safeguards appropriate to the sensitivity of the information, including:

• Encryption of data in transit and, where possible, at rest
• Access limited to staff, facilitators and practitioners who need it for their role
• Confidentiality agreements and data protection training for those who handle your information
• Secure, access-controlled systems, with sensitive records kept separate from marketing data
• Regular review of our security practices

No system is completely secure. If a breach is likely to put your rights and freedoms at risk, we will notify you and the Nigeria Data Protection Commission (NDPC) as the law requires, including within the required timeframe.

Your information is stored on systems provided by [hosting and platform providers] located in [country or countries].

We keep information only as long as needed for the purpose it was collected, then delete or anonymise it.

We share information only where necessary, and only the minimum needed.

• Practitioners: therapists, assessors and facilitators engaged by Encirkle, so they can deliver your service.
• Service providers: companies that help us run Encirkle, such as hosting, video sessions, scheduling, payments, email delivery and analytics. They act on our instructions under written agreements.
• Referral partners: if we refer you to another practitioner or organisation, we share your details only with your consent.
• Authorities and advisers: where the law requires it, or to our professional advisers under confidentiality.
• Emergency situations: if we believe you or someone else is at serious and immediate risk of harm, we may share relevant information with emergency services or appropriate contacts.

If Encirkle is restructured or sold, your information may transfer to the new owner, who must honour this policy.

Transfers outside Nigeria

Some providers may process information outside Nigeria. Where that happens, we ensure the transfer meets Nigerian data protection requirements, through adequacy decisions, contractual safeguards or your consent as applicable.

Under the Nigeria Data Protection Act 2023, you may have the right to:

• Be informed about how your data is used
• Access the information we hold about you
• Correct information that is inaccurate or incomplete
• Request deletion of your information where we no longer need it
• Restrict or object to certain processing, including direct marketing
• Receive your information in a portable format
• Withdraw consent at any time, without affecting earlier processing
• Not be subject to decisions based solely on automated processing

To exercise any right, email [privacy email address]. We may need to confirm your identity first, and we will respond within [30 days]. Some records, such as clinical or financial records, may need to be kept for legal reasons, and we will explain if that applies.

If you are unhappy with how we handle your information, please tell us first. You also have the right to complain to the Nigeria Data Protection Commission (NDPC).

Circles are peer-support spaces. Please remember:

• Other participants and the facilitator will hear what you share in a session.
• Participants agree to keep what is shared confidential, but we cannot guarantee that every participant will.
• Share only what you are comfortable sharing, and avoid including identifying details about other people.
• [Sessions are not recorded / Sessions are recorded only with explicit consent for the following purpose: ...]

Facilitators may need to act if someone appears to be at serious risk of harm (see section 6).

Encirkle services are intended for adults aged 18 and over. We do not knowingly collect information from children. If you believe a child has given us information, contact us and we will delete it.

Our website uses:

• Essential cookies: needed for the site to work and stay secure. These cannot be switched off.
• Analytics cookies: help us understand how the site is used, using [analytics provider]. These run only with your consent.
• Preference cookies: remember your settings.

We may update this policy as our services or the law change. We will post the new version here with a revised date, and tell you directly about significant changes.

Questions or concerns about your privacy? Contact:

Encirkle Healthcare Services: hello@encirkle.org | +2349012646765