Privacy Policy

Last updated 28 July 2026

Draft — not yet legally reviewed. This document describes how the platform actually behaves, but has not been approved by counsel against the Nigeria Data Protection Act. It must not be relied on, and must be signed off before launch.

This policy explains what Elite Circle collects, why we collect it, who sees it, and what you can ask us to do with it. It is written to be read, not to be survived.

Who we are

Elite Circle is operated by Cemmey Enterprises. For the purposes of the Nigeria Data Protection Act 2023, we are the data controller for the information described here.

What we collect

What you give us

Account details — your name, date of birth, and either a phone number or an email address. Date of birth is required and cannot be changed later: it is how we enforce that every member is 18 or over.
Profile content — photos, your bio, prompt answers, interests, and the attributes you choose to show, such as occupation, education, religion or relationship goal. Any of these can be hidden or removed by you at any time.
Messages — the content of conversations with your matches.
Verification media — a selfie, and where you choose to complete ID verification, an identity document.
Trusted contacts — the name and number of anyone you add to the Safety Centre.

What we collect automatically

Approximate location, to show you people nearby. We store your coordinates so distances can be calculated, but we never show another member your exact position — distances shown to others are deliberately fuzzed.
Device and usage information — device model, operating system, app version, IP address, and a device identifier. This is used for fraud prevention, crash diagnosis and support.
Activity — when you were last active, who you liked or passed on, and which profiles you viewed. This is what makes the deck work.

Why we use it

To run the service — building your deck, forming matches, delivering messages.
To keep members safe — reviewing photos and reports, detecting fraudulent accounts, and escalating safety alerts to your trusted contacts when you ask us to.
To meet legal obligations — including age verification and responding to lawful requests.
To improve matching — measuring which matches lead to conversations, in aggregate.

Sensitive information

Some of what a dating profile contains is sensitive by nature. We treat it accordingly:

Religion is available as a matching preference, because it matters to many members in our launch market. You choose whether to state it, and you can hide it from your profile while still using it as a filter.
Ethnicity is display-only. It is never used as a matching weight and cannot be used to filter other members.
Sexual orientation is inferred only from the preferences you set, and is never shared with other members or third parties.
Identity documents are used solely to verify you are who you say you are. They are not shown to other members, and are deleted once verification completes.

Who sees your information

Other members see your profile as you have configured it — nothing more. They never see your email address, your phone number, your exact location, your date of birth, or your account history.

We share data with a small number of processors, each under contract:

Cloud hosting and object storage, to run the service.
Payment providers, to take payment. We never see or store your card number.
SMS and push delivery providers, to send verification codes and notifications.
Content moderation services, to review photos before they appear.
Error monitoring, configured not to receive message or profile content.

We do not sell your personal data, and we do not share it with advertisers.

Where your data is held

Data is processed on servers that may be outside Nigeria. Where it is transferred internationally, we rely on the safeguards permitted under the NDPA and contractual protections with each processor.

How long we keep it

While your account is active — for as long as you use the service.
After deletion — your profile and photos are removed from the app immediately and purged within 30 days.
Safety and fraud records — reports, sanctions and fraud signals are kept longer, because deleting them would let a banned member return by making a new account. We keep the minimum needed for that purpose.
Transaction records — kept as long as tax and accounting law requires.

Your rights

Under the NDPA you may:

Ask for a copy of the data we hold about you.
Correct anything inaccurate.
Delete your account and your data, subject to the retention above.
Object to or restrict certain processing.
Withdraw consent where we relied on it.
Complain to the Nigeria Data Protection Commission.

Account deletion and data export are both available in the app, under Settings. You do not need to email us to exercise either. If you would rather write, use privacy@elitecircle.site; we respond within 30 days.

Children

Elite Circle is strictly for adults. We do not knowingly allow anyone under 18 to register, and we remove any account we find to belong to a minor. If you believe a minor is using the service, report the profile in the app or write to safety@elitecircle.site.

Changes

If we change this policy in a way that materially affects you, we will tell you in the app before the change takes effect.

Questions about this document? Write to privacy@elitecircle.site.