Toogeda.com (“we”, “us”, or “our”) is committed to protecting your privacy. This Privacy Policy explains how we collect, use, store, share, and protect your personal information when you access or use our platform (“Platform”), which connects investors with investment opportunities.

1. Who We Are
   Toogeda.com is being operated by Firstverse Networks Limited, a limited liability company duely incorporated with Corporate Affairs Commission (CAC) under the laws of Nigeria. We operate a digital investment platform that facilitates access to investment opportunities. For the purposes of applicable data protection laws, we are the “data controller” of your personal data.
2. Information We Collect
   We collect personal information to deliver our services, comply with legal obligations, and improve user experience. The types of information we collect include:

a) Information You Provide
Full name, date of birth, nationality

Email address, phone number

Residential or business address

Government-issued ID (passport, national ID, driver’s license)

Financial details (bank account, investment history)

Source of funds and wealth (for KYC/AML compliance)

Employment and income information

Investment preferences and risk appetite

b) Automatically Collected Information
IP address

Browser type and version

Device identifiers

Geolocation data

Pages viewed, session duration

Cookies and similar tracking technologies

c) Third-Party Data
We may receive information from:

Identity verification services

Credit bureaus

Public databases

Partner financial institutions

3. How We Use Your Information
   We use your information for the following purposes:

To create and manage your account

To verify your identity and perform KYC/AML checks

To provide access to investment opportunities

To process your investments and transactions

To comply with legal, regulatory, and tax obligations

To detect and prevent fraud or financial crime

To send service notifications and platform updates

To provide customer support

To personalise your experience

To improve our products and services

4. Legal Basis for Processing (for GDPR Users)
   We process personal data based on one or more of the following legal grounds:

Your consent

Performance of a contract with you

Compliance with legal obligations

Our legitimate interests (e.g., fraud prevention, service improvement)

5. How We Share Your Information
   We do not sell your personal data. We may share your information with:

Regulatory bodies and law enforcement, as required by law

Identity verification and AML service providers

Partner financial institutions, investment issuers, or payment providers

Cloud hosting and IT infrastructure providers

Auditors, legal and tax advisors

Analytics and marketing service providers (only with consent)

All third parties are subject to confidentiality obligations and must comply with applicable data protection laws.

6. Cross-Border Transfers
   Your information may be transferred to and stored in countries outside your country of residence, including countries that may not provide the same level of data protection. When we do so, we ensure appropriate safeguards are in place (such as Standard Contractual Clauses).
7. Data Retention
   We retain personal information only as long as necessary to:

Fulfill the purposes outlined in this policy

Comply with legal, regulatory, tax, or accounting obligations

Resolve disputes and enforce agreements

Retention periods may vary depending on jurisdiction and regulatory requirements (e.g., 5–10 years after account closure for financial recordkeeping).

8. Cookies and Tracking Technologies
   We use cookies and similar technologies to:

Authenticate users

Remember preferences

Analyse Platform usage

Provide targeted content or ads (only with consent)

You can control cookies via your browser settings. For more information, please review our Cookie Policy.

9. Your Rights
   Depending on your jurisdiction, you may have the following rights:

Access: Request a copy of the data we hold about you.

Correction: Request corrections to inaccurate or incomplete data.

Deletion: Request erasure of your data (subject to legal obligations).

Objection: Object to processing based on legitimate interests.

Restriction: Request limitations on data processing.

Portability: Request your data in a portable format.

Withdraw Consent: Withdraw consent at any time (where applicable).

Lodge a Complaint: Contact a data protection authority.

To exercise your rights, contact us at: privacy@toogeda.com

10. Security Measures
    We implement appropriate technical and organisational measures to protect your data,

Encryption of data in transit and at rest

Secure access controls and authentication

Regular vulnerability scanning and audits

Role-based access restrictions

However, no system is completely secure. You are responsible for safeguarding your login credentials.

11. Children’s Privacy
    Our Platform is not intended for individuals under 18 years of age. We do not knowingly collect personal data from minors. If we discover such data, it will be promptly deleted.
12. Third-Party Links
    The Platform may contain links to third-party websites. We are not responsible for their privacy practices. Please review their privacy policies before providing any personal data.
13. Changes to This Policy
    We may update this Privacy Policy periodically. When we do, we will revise the “Effective Date” and notify you via email or the Platform where required. Your continued use of the Platform after such updates constitutes your acceptance.

14. Contact Us
    If you have any questions about this Privacy Policy or our data handling practices, please contact:

Data Protection Officer
📧 Email: privacy@toogeda.com
📍 Address: