Privacy Policy

Seed (the "Platform") is a startup discovery and ecosystem platform owned and operated by Africa Geek Circle Network, a company incorporated under the laws of the Federal Republic of Nigeria.

References in this Privacy Policy to "Seed", "we", "us" or "our" refer to Africa Geek Circle Network and the Seed platform as applicable.

For personal data processed for the purposes of operating Seed, Africa Geek Circle Network determines why and how that personal data is processed and acts as the data controller for those processing activities.

This Privacy Policy applies when you visit Seed, create or use an account, join a waitlist, create a founder, startup, investor or ecosystem profile, submit documents, request or receive access to information, subscribe to a service, make a payment, participate in a programme or event, communicate with us or otherwise interact with Seed.

"Personal data" means information relating to an identified or identifiable natural person. Information that has been properly anonymised so that an individual can no longer reasonably be identified is not treated as personal data for the purposes of this Policy.

The information we collect depends on how you interact with Seed, the type of account you hold and the features or services you choose to use.

• Identity and contact information: including your name, email address, telephone number, country, city or location, profile photograph, professional details and preferred communication information.
• Account and authentication information: including your account type, account identifier, verification status, authentication information, login records and information used to protect your account.
• Founder information: including your biography, professional background, founder role, employment or startup relationship, photographs, social media information, achievements and other information you choose to include in your founder profile.
• Startup and business information: including startup name, logo, industry, business description, website, location, stage, team information, traction, customers, products, funding history, fundraising goals, revenue or financial information, pitch information, photographs, videos and other business information you submit.
• Documents and restricted materials: including pitch decks, financial models, financial projections, cap tables, company registration documents and other documents or information that you choose to upload or make available through restricted Platform features.
• Investor and ecosystem information: including organisation name, job title, professional role, investment interests, preferred sectors, investment stages, geographical preferences, ticket size, portfolio interests, saved startups and other discovery preferences.
• Communications and support information: including enquiries, messages, feedback, complaints, survey responses, support requests and other correspondence you send to us.
• Subscription and transaction information: including subscription tier, billing cycle, transaction amount, currency, payment status, payment reference, invoice information and records relating to refunds, renewals or payment disputes.
• Payment information: payment card or bank information required to process a transaction may be collected directly by an authorised third-party payment provider. Seed may receive transaction confirmations and related payment records without receiving the complete payment credentials used by that provider.
• Technical and device information: including Internet Protocol address, browser type, operating system, device information, language, time zone, referring page and network information.
• Platform activity and usage information: including pages viewed, searches, clicks, profile views, bookmarks, saved startups, document requests, interactions, session activity, referral source, feature usage and diagnostic events.
• Verification, compliance and security information: including information reasonably required to verify a founder, startup, investor, organisation or authorised representative, investigate suspected fraud or misuse, protect users or comply with applicable law.

You should not upload sensitive personal data, passwords, identity documents, confidential personal information or personal data relating to another person unless the information is genuinely necessary for the relevant feature and you have a lawful basis and all required authority to provide it.

Where Seed specifically requests information that is considered sensitive personal data under applicable law, we will process it only where an appropriate legal basis exists and will apply safeguards appropriate to the nature of that information.

We may collect personal data from the following sources:

• Directly from you: when you register, join a waitlist, create or edit a profile, complete a form, upload information or documents, make a payment, submit a request, communicate with us or use another Platform feature.
• Automatically when you use Seed: certain technical, device, cookie and usage information may be collected automatically as you interact with the Platform.
• From other users or authorised representatives: a co-founder, team member, employer, investment organisation, accelerator, partner or other authorised person may provide information about you where they have lawful authority to do so.
• From connected or third-party services: where you choose to connect Seed with an external service, we may receive information that you authorise that service to provide.
• From publicly available sources: we may review company websites, professional profiles, corporate records, startup directories and other lawfully available sources where reasonably necessary for verification, research, moderation or profile accuracy.
• From service and business partners: we may receive information from payment providers, authentication providers, event or programme partners and other service providers where necessary to provide a feature you use or where otherwise permitted by law.

If you provide personal data relating to another person, you are responsible for ensuring that you have a lawful basis and authority to provide that information and that any required privacy information has been given to that person.

We process personal data only where an appropriate lawful basis applies and only for purposes connected with providing, administering, protecting and improving Seed.

We may use personal data to:

• Create, administer, authenticate and secure accounts.
• Receive, review, verify, publish and manage founder, startup, investor and ecosystem profiles.
• Display information according to the relevant profile, document-access and visibility settings.
• Enable startup discovery, search, ranking, filtering, bookmarking, recommendations and other discovery functions.
• Facilitate authorised introductions, expressions of interest, document requests and communications between ecosystem participants.
• Administer subscriptions, billing, payments, renewals, cancellations and related customer support.
• Respond to enquiries, complaints, support requests and feedback.
• Send account, security, verification, policy, transaction and other important service communications.
• Send newsletters, opportunities, events and promotional communications where you have consented or another lawful basis permits us to do so.
• Analyse Platform usage, measure performance, troubleshoot problems, conduct research and improve our products and user experience.
• Detect, investigate and prevent fraud, impersonation, unauthorised access, abuse, security incidents and violations of our Terms of Use.
• Moderate content, enforce agreements, resolve disputes and protect the rights, property and safety of Seed, our users and third parties.
• Comply with applicable laws, regulatory requirements, court orders and lawful requests from competent authorities.
• Establish, exercise or defend legal claims and maintain appropriate business, tax, accounting, security and compliance records.
• Create aggregated or anonymised statistics and insights that do not reasonably identify an individual.

Other lawful bases recognised by applicable law, including protection of vital interests or processing in the public interest, may apply in limited circumstances where appropriate.

Where we rely on consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out before consent was withdrawn.

Where we rely on legitimate interests, we consider the relevant business purpose, whether the processing is necessary for that purpose and the potential effect on your privacy rights.

Seed is designed to increase startup visibility and facilitate legitimate connections between founders, investors, strategic partners, mentors and other ecosystem participants. The extent to which information is visible depends on the type of information, the relevant Platform feature and any visibility or access settings available to the user.

Information submitted to a public founder or startup profile may be accessible to visitors and other Platform users. Public information may also be indexed by search engines or shared outside Seed by people who view it.

Seed may distinguish between public profile information and non-public or restricted Founder Information. Restricted information may be made available only through features intended for authorised users or where the founder has selected or approved the relevant form of access.

Founder Information may include personal data, business information, startup details, funding history, pitch materials, financial information, contact information and other information voluntarily submitted or made available by a founder.

Where non-public Founder Information is made available to an authorised investor or other ecosystem participant, the recipient is expected to use that information only for the legitimate purpose for which it was made available and subject to the confidentiality obligations in our Terms of Use.

We may disclose personal data to the following categories of recipients where reasonably necessary and lawful:

• Other Platform users: including founders, investors and ecosystem participants, according to the relevant feature and access or visibility settings.
• Service providers: including providers that support hosting, cloud infrastructure, databases, authentication, file storage, communications, email delivery, analytics, security, customer support and payment processing.
• Professional advisers: including lawyers, accountants, auditors, insurers and data protection advisers where reasonably necessary.
• Ecosystem and programme partners: where you request or authorise an introduction, apply for an opportunity, participate in a programme or use a jointly delivered service.
• Competent authorities: where disclosure is required or permitted by applicable law, court order, regulatory requirement or other lawful process.
• Corporate transaction participants: where information is reasonably necessary in connection with a proposed financing, restructuring, merger, acquisition, sale of assets or similar transaction, subject to appropriate confidentiality and legal safeguards.

We do not sell or rent personal data to third parties for monetary consideration. We may disclose aggregated or properly anonymised information that does not reasonably identify an individual.

Seed may use cookies, local storage, pixels and similar technologies to operate the Platform, authenticate users, remember preferences, maintain security, understand usage, diagnose problems and improve performance.

• Strictly necessary technologies: used for authentication, fraud prevention, security, session management and other essential Platform functions.
• Preference technologies: used to remember settings and improve your experience.
• Analytics technologies: used to understand Platform usage, identify errors, measure engagement and improve our services.
• Marketing technologies: where used, these may help us understand campaign performance or provide more relevant communications and will be subject to applicable consent requirements.

Where applicable law requires consent for non-essential technologies, we will provide an appropriate mechanism through which you can make or change your choices.

You may also control cookies through your browser or device settings. Disabling certain technologies may affect the availability or performance of some Platform features.

We may send service-related communications concerning your account, security, transactions, verification, subscriptions, policy updates or other important Platform matters where reasonably necessary.

Promotional emails and similar direct marketing communications may be sent where permitted by law. You may unsubscribe using the link provided in the communication or another available preference mechanism. Opting out of marketing does not prevent us from sending necessary service communications.

Seed is operated from Nigeria but may use service providers, infrastructure, contractors or business partners located in other countries. Personal data may therefore be stored, accessed, transferred or otherwise processed outside Nigeria.

Where we transfer personal data internationally, we will take reasonable steps to ensure that the transfer is permitted under applicable data protection law and that appropriate safeguards are used.

Depending on the circumstances, this may involve transferring information to a jurisdiction recognised as providing adequate protection, using approved contractual or other transfer safeguards, relying on an applicable statutory exception, obtaining consent where appropriate, or using another legally recognised transfer mechanism.

Service providers processing personal data on our behalf are expected to process it only for authorised purposes and to apply appropriate confidentiality, security and data protection measures.

We use reasonable and proportionate technical and organisational measures designed to protect personal data against accidental or unlawful destruction, loss, alteration, disclosure, misuse or unauthorised access.

These measures may include:

• Role-based access controls and restricted permissions.
• Protected transmission and encryption where appropriate.
• Secure authentication and password protection.
• Administrative and infrastructure access restrictions.
• Logging, monitoring and security review processes.
• Data minimisation and appropriate deletion or anonymisation procedures.
• Confidentiality and data protection obligations for personnel, contractors and service providers.
• Incident-response and personal-data-breach management processes.

No internet transmission, software platform, database or electronic storage system can be guaranteed to be completely secure. You are responsible for protecting your login credentials and should notify us promptly if you suspect unauthorised access to your account.

Where a personal data breach triggers a notification obligation under applicable law, we will notify the Nigeria Data Protection Commission and/or affected data subjects as required.

We retain personal data only for as long as reasonably necessary for the purposes for which it was collected and for legitimate related purposes such as providing services, maintaining security, preserving business records, resolving disputes, enforcing agreements and complying with legal, tax, accounting and regulatory obligations.

Retention periods may vary according to the nature of the information, the purpose of processing, your relationship with Seed, legal requirements, the sensitivity of the information and the risks associated with continued retention.

When personal data is no longer required, we will take reasonable steps to delete, anonymise or securely isolate it, subject to lawful backup, archival and record-keeping requirements.

Subject to applicable law and any lawful limitations or exceptions, you may have the following rights regarding your personal data:

• The right to be informed about how your personal data is processed.
• The right to request confirmation of whether we process your personal data and to request access to that data.
• The right to request correction of inaccurate or incomplete personal data.
• The right to request deletion of personal data in circumstances where there is no lawful basis for its continued processing.
• The right to withdraw consent where processing is based on consent.
• The right to object to certain processing, including direct marketing and processing based on legitimate interests where the law gives you that right.
• The right to request restriction of processing in applicable circumstances.
• The right to data portability where the statutory requirements for portability are satisfied.
• Rights relating to decisions based solely on automated processing that produce legal or similarly significant effects concerning you.
• The right to lodge a complaint with the Nigeria Data Protection Commission.

Certain profile and account information may be updated directly through available Platform settings.

Seed may use automated systems to organise search results, support ranking, recommend profiles, identify relevant content or personalise discovery using information such as profile details, preferences and Platform activity.

We do not ordinarily use solely automated processing to make decisions about individuals that produce legal or similarly significant effects. If this changes, we will apply the safeguards required by applicable law.

To exercise a privacy right, contact us using the details below. We may request information reasonably necessary to verify your identity and protect personal data from unauthorised disclosure.

A request may be restricted or refused where permitted by law, including where necessary to protect another person's rights, comply with a legal obligation, prevent fraud or establish, exercise or defend legal claims. Where appropriate, we will explain the reason for our decision.

Seed is intended primarily for founders, investors, professionals, organisations and other adult participants in the entrepreneurial ecosystem.

Users must ordinarily be at least eighteen (18) years old or the age of majority applicable in their jurisdiction to create an account, consistent with our Terms of Use.

We do not knowingly invite children to create ordinary Seed accounts or independently submit personal data through the Platform. If we become aware that personal data relating to a child has been collected without an appropriate lawful basis or necessary authorisation, we will take reasonable steps to restrict, delete or otherwise address the information as required by applicable law.

A parent or legal guardian who believes that a child's personal data has been provided to Seed inappropriately may contact us using the details below.

Where you submit information about a co-founder, employee, adviser, team member, investor, customer, representative or another person, you are responsible for ensuring that you are authorised to provide the information and that its submission complies with applicable law.

We may update this Privacy Policy from time to time to reflect changes to Seed, our processing activities, Platform features, service providers, legal obligations or regulatory requirements.

The date displayed at the top of this page indicates when this version of the Policy was last updated.

Where a change materially affects the way we process personal data or materially affects your privacy rights, we will provide reasonable notice through the Platform, by email or through another appropriate communication channel where required.

Where applicable law requires consent or another affirmative action before a new processing activity begins, we will obtain that consent or take the required action.

We encourage you to review this Privacy Policy periodically to remain informed about how personal data is processed and protected.

Africa Geek Circle Network is responsible for personal data processed for the purposes of operating Seed.

For privacy questions, complaints or requests relating to your personal data, contact us at support@seed54.com or legal@africageekcirclenetwork.com.

Please provide enough information to help us identify the relevant account or processing activity and understand your request. Do not send passwords, complete payment credentials or unnecessary sensitive personal data by email.

We encourage you to contact us first so that we can investigate and address your concern. This does not restrict your right to lodge a complaint with the Nigeria Data Protection Commission or exercise any other right or remedy available under applicable law.