Privacy Policy

1. Introduction

Hustle 360 Ltd ("we," "us," or "our") operates Urgent2K, a community finance, wallet, support, and trust platform for Community+, Circles, Susu, Funds, Wallet, support plans, and trust history. This Privacy Policy explains how we collect, use, disclose, and protect your personal information in compliance with the Nigeria Data Protection Regulation (NDPR) 2019 and other applicable laws.

2. Information We Collect

2.1 Information You Provide

• Account Information: Name, email address, phone number, password
• Identity Verification: National Identification Number (NIN), Bank Verification Number (BVN), date of birth
• Financial Information: Bank account details, monthly income, employment status, wallet activity, and support-plan information
• Transaction Data: support-plan amounts, return rates, return schedules, wallet history, Funds, Susu activity, and completed or missed commitments

2.2 Information Collected Automatically

• Device Information: IP address, browser type, operating system, device identifiers
• Usage Data: Pages visited, features used, time spent on the Platform, click patterns
• Cookies: Session cookies, preference cookies, analytics cookies (see Cookie Policy below)

2.3 Information from Third Parties

• Identity Verification Services: Data from NIMC, iCheck, or similar services to verify your identity
• Payment Processors: Transaction confirmation and payment status from Flutterwave, Paystack, Monnify

3. How We Use Your Information

We use your information to:

• Create and manage your account
• Verify your identity and comply with KYC regulations
• Facilitate support-plan transactions between supporters and members requesting support
• Calculate and display trust scores, trust indicators, and platform activity summaries
• Process payments and send transaction confirmations
• Send reminders about upcoming payments
• Detect and prevent fraud, abuse, and illegal activity
• Improve our Platform and develop new features
• Communicate with you about your account and Platform updates
• Comply with legal obligations and respond to law enforcement requests

4. How We Share Your Information

4.1 Service Providers

4.2 Other Platform Users

Public / Platform-visible Information: Your trust score, trust indicators, Community+ activity, Circle participation, support-plan summary, Fund/Susu participation, and return-history summaries are visible to other users to facilitate informed lending decisions. Your full name, contact information, and detailed financial data remain private.

4.3 Legal Requirements

We may disclose your information if required by law, court order, or government request, or to protect our rights, property, or safety.

5. Data Security

We implement industry-standard security measures to protect your information:

• Encryption: All sensitive data (NIN, BVN, passwords) is encrypted using AES-256 encryption
• Secure Transmission: Data transmitted between your device and our servers uses TLS/SSL encryption
• Access Controls: Strict access controls limit who can view your personal information
• Regular Audits: We conduct security audits and vulnerability assessments
• Secure Infrastructure: Data is stored on secure servers with regular backups

Note: No system is 100% secure. While we take extensive precautions, we cannot guarantee absolute security.

6. Your Rights (NDPR Compliance)

Under the Nigeria Data Protection Regulation, you have the following rights:

• Right to Access: Request a copy of your personal data
• Right to Rectification: Correct inaccurate or incomplete data
• Right to Erasure: Request deletion of your data (subject to legal requirements)
• Right to Data Portability: Receive your data in a machine-readable format
• Right to Object: Object to certain types of processing
• Right to Withdraw Consent: Withdraw consent for data processing at any time

To exercise your rights, contact our Data Protection Officer at [email protected]

7. Data Retention

We retain your information for as long as necessary to:

• Provide Platform services
• Maintain accurate trust history, wallet records, support-plan records, Susu records, Fund records, and compliance records
• Comply with legal obligations (e.g., tax records, KYC documents)
• Resolve disputes and enforce our Terms of Service

If you close your account, we will delete or anonymize your data within 30 days where possible, except where retention is required for legal, compliance, fraud-prevention, tax, KYC, dispute, wallet, support-plan, Susu, Fund, or trust-history obligations.

8. Cookies & Tracking

We use cookies and similar technologies to:

• Essential Cookies: Keep you logged in and remember your preferences
• Analytics Cookies: Understand how you use the Platform and improve performance
• Security Cookies: Detect fraudulent activity and protect your account

You can manage cookie preferences through your browser settings. Note that disabling certain cookies may affect Platform functionality.

9. Children's Privacy

Urgent2K is not intended for users under 18 years of age. We do not knowingly collect information from minors. If we discover we have collected data from a minor, we will delete it immediately.

10. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of significant changes via email or in-app notification. Your continued use of the Platform after changes indicates acceptance of the updated policy.

11. Contact Us