Privacy Policy

1. Introduction

Hustle 360 Ltd ("we," "us," or "our") operates Garder, a community finance, wallet, support, savings, and trust platform for Community+, Circles, Susu, Funds, Wallet, support plans, and trust-history features. 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.

Garder is designed to help members request structured support, give structured support, participate in savings-style communities, manage wallet activity, and build a visible trust history. We are not a bank, deposit-taking institution, investment adviser, or traditional loan provider.

2. Information We Collect

2.1 Information You Provide

• Account Information: Name, email address, phone number, username, profile photo, password, and account preferences
• Identity Verification: National Identification Number (NIN), Bank Verification Number (BVN), date of birth, and other verification details where required
• Financial and Wallet Information: Bank account details, wallet activity, top-ups, withdrawals, payment references, payout details, support-plan information, Funds activity, Susu activity, and Circle participation
• Community Information: Posts, comments, reactions, reports, profile activity, support requests, support offers, and public trust indicators
• Trust-History Information: Completed commitments, missed commitments, return schedules, wallet records, participation history, verification status, and platform behavior used to calculate trust indicators
• Support Information: Messages, attachments, support tickets, dispute details, account-deletion requests, and privacy/data requests sent to our support team

2.2 Information Collected Automatically

• Device Information: IP address, browser type, operating system, device identifiers, app version, and crash or diagnostic information
• Usage Data: Pages visited, features used, time spent on the Platform, click patterns, wallet actions, and community interactions
• Cookies: Session cookies, preference cookies, analytics cookies, and security cookies

2.3 Information from Third Parties

• Identity Verification Services: Data from NIMC, iCheck, or similar services to verify your identity
• Payment Processors: Transaction confirmations, wallet-credit status, transfer status, and payment references from Flutterwave, Paystack, Monnify, or other payment partners
• Platform Safety Sources: Fraud-prevention, abuse-prevention, or dispute-related information where needed to protect users and the Platform

3. How We Use Your Information

We use your information to:

• Create, secure, and manage your account
• Verify your identity and comply with KYC, fraud-prevention, and platform-safety requirements
• Operate wallet features, top-ups, withdrawals, payouts, payment references, and transaction confirmations
• Facilitate structured support requests, support offers, support-plan tracking, Funds, Circles, and Susu activity
• Calculate and display trust scores, trust indicators, badges, and platform activity summaries
• Send reminders about upcoming commitments, wallet activity, support plans, Susu contributions, and account security
• Review reports, disputes, suspicious activity, and potential platform abuse
• Improve our Platform and develop new features
• Communicate with you about your account, support requests, privacy requests, and Platform updates
• Comply with legal obligations and respond to lawful requests

4. How We Share Your Information

4.1 Service Providers

4.2 Other Platform Users

Some information may be visible to other users where required for trust, safety, and informed participation. This may include your username, display name, profile photo, trust indicators, badges, Community+ activity, Circle participation, public support requests, support-plan summaries, Fund/Susu participation, and return-history summaries. Your full contact information, sensitive identity data, private wallet details, and detailed financial information remain private unless you choose to share them or disclosure is required by law, safety, dispute resolution, or platform rules.

4.3 Legal, Safety, and Compliance

We may disclose information if required by law, court order, lawful government request, payment-partner requirement, fraud investigation, dispute review, or to protect the rights, safety, property, or integrity of users, Hustle 360 Ltd, or the Platform.

5. Data Security

We implement reasonable administrative, technical, and organizational safeguards to protect your information:

• Encryption: Sensitive data is encrypted where appropriate
• Secure Transmission: Data transmitted between your device and our servers uses TLS/SSL encryption
• Access Controls: Access to personal information is limited to authorized personnel and service providers
• Monitoring: We monitor for suspicious activity, abuse, and unauthorized access
• Secure Infrastructure: Data is stored using managed infrastructure, backups, and reasonable security controls

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

6. Your Rights

Subject to applicable law, you may 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, fraud-prevention, transaction, dispute, KYC, and compliance retention requirements
• Right to Data Portability: Receive your data in a machine-readable format where applicable
• Right to Object: Object to certain types of processing
• Right to Withdraw Consent: Withdraw consent where processing is based on consent

To exercise your rights, contact us at [email protected] or visit garder.app/support.

7. Data Retention

We retain your information for as long as necessary to:

• Provide Platform services
• Maintain accurate wallet records, transaction records, support-plan records, Susu records, Fund records, community-safety records, and trust history
• Comply with legal, tax, audit, KYC, fraud-prevention, and payment obligations
• Resolve disputes, investigate abuse, and enforce our Terms of Service

If you close your account, we will delete or anonymize your data where possible, except where retention is required for legal, compliance, fraud-prevention, tax, KYC, dispute, wallet, transaction, support-plan, Susu, Fund, community-safety, 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. Disabling certain cookies may affect Platform functionality.

9. Children's Privacy

Garder 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 take appropriate steps to delete it.

10. Changes to This Policy

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

11. Contact Us