ValueCycleNetwork (VCN) Privacy Policy

Welcome to ValueCycleNetwork (“VCN”).

VCN is operated by Value Cycle Network LTD, a company registered in the Federal Republic of Nigeria.

We operate a digital knowledge marketplace that provides access to digital products, educational resources, marketplace participation, utility services, AI-powered tools and other digital services.

We respect your privacy and are committed to protecting personal information entrusted to us.

This Privacy Policy explains how Value Cycle Network LTD (“VCN”, “we”, “us” or “our”) collects, uses, stores, shares and otherwise processes personal information when you use our website, applications, marketplace, member back office, Sales Pages, AI tools and other VCN services.

Our processing of personal data is intended to comply with the Nigeria Data Protection Act 2023 and other applicable Nigerian data-protection requirements.

The Nigeria Data Protection Commission identifies important data-subject rights including rights to information, access, rectification, objection, restriction, portability, erasure in appropriate circumstances, complaint to the supervisory authority and protections relating to automated decision-making.

By using VCN, you acknowledge this Privacy Policy.

Where consent is legally required for a particular processing activity, we will seek that consent separately where appropriate.

Depending on how you use VCN, we may collect information including:

A. Account and Identity Information

• first and last name
• username
• email address
• telephone number
• WhatsApp number
• date or confirmation of age eligibility
• profile information
• account status
• verification information

B. Banking and Transaction Information

Where necessary for marketplace transactions or other services, we may process information such as:

• bank name
• account number
• verified account name
• transaction references
• payment status
• payment amounts
• payment confirmations
• payment receipts
• marketplace transaction history

VCN may use third-party payment or banking service providers to verify or process certain transactions.

VCN does not necessarily receive or store all information supplied directly to a third-party payment provider.

C. Marketplace Information

We may process information relating to your participation in VCN, including:

• products purchased
• marketplace selected
• Activation Fee records
• Selling License status
• Sellers Queue information
• buyer/seller assignments
• cycle information
• payment confirmations
• marketplace eligibility
• marketplace progression
• pauses and resumptions
• appeals and disputes
• Referral Bonus records
• applicable rewards and credits

D. Utility Credit Information

We may maintain records relating to:

• Utility Credits earned
• Utility Credits funded
• Utility Credits transferred
• Utility Credits spent
• utility purchases
• Creator Studio usage
• transaction history

E. AI Creator and AI Music Information

When you use VCN's AI-powered services, we may process:

• prompts
• lyrics
• descriptions
• themes
• creative instructions
• generated-content requests
• generation status
• generated-content metadata
• transaction information
• API task identifiers
• usage history

Information submitted to an AI service may need to be transmitted to third-party AI providers to generate the requested output.

You should therefore avoid entering unnecessary confidential, sensitive or third-party personal information into AI prompts.

F. Technical Information

We may automatically receive information such as:

• IP address
• browser type
• device information
• operating system
• session information
• login activity
• approximate location derived from technical information
• referring pages
• pages visited
• error and security logs
• cookie identifiers
• interaction information

We may collect information:

• directly from you
• during registration
• when you verify your email or WhatsApp number
• when you update your profile
• when you purchase products
• when you participate in a marketplace
• when you make or receive marketplace payments
• when you fund or use Utility Credits
• when you use VCN Creator Studio or AI Music Studio
• when you contact Support
• when you submit an appeal
• through cookies and similar technologies
• from payment processors and service providers
• from other VCN users where required for legitimate marketplace transactions

VCN may process personal information to:

• create and maintain accounts
• authenticate users
• verify contact information
• verify banking information
• provide digital products
• operate VCN marketplaces
• administer Sellers Queues
• make buyer/seller assignments
• facilitate marketplace transactions
• issue Selling Licenses
• administer Referral Bonuses and other applicable rewards
• administer Utility Credits
• provide utility services
• provide AI services
• process payments
• detect duplicate accounts
• prevent fraud and abuse
• enforce marketplace rules
• investigate appeals
• provide customer support
• send service notifications
• maintain security
• comply with legal obligations
• maintain financial and audit records
• improve VCN products and services
• perform analytics
• communicate important changes

Depending on the circumstances, VCN may process information because:

• processing is necessary to perform a contract with you or take steps at your request
• you have given valid consent
• processing is necessary to comply with legal obligations
• processing is necessary for legitimate interests pursued by VCN or another party, where those interests are not overridden by applicable rights
• another lawful basis recognised under applicable law applies

VCN will not rely on consent where another lawful basis is more appropriate merely to make consent appear mandatory.

NDPC's own published privacy framework similarly recognises lawful, fair and transparent processing, purpose limitation, data minimisation, storage limitation, accuracy and appropriate security as core principles.

VCN may require users to verify their:

• WhatsApp number and/or email address

Verification may involve sending a one-time verification code.

WhatsApp communications may be delivered through an authorised messaging service provider.

Email communications may be delivered through VCN's email infrastructure or authorised service providers.

Verification requirements may be changed where necessary for security or operational reasons.

VCN marketplace transactions may require certain information to be shared between an assigned Buyer and Seller.

This may include information reasonably necessary to:

• identify the assigned party
• make payment
• confirm payment
• communicate about the transaction
• deliver the applicable product
• resolve disputes

Users must use such information only for the relevant VCN transaction.

You must not harvest, sell, publish, misuse, spam or use another member's information for unrelated purposes.

VCN may use third parties that provide:

• payment processing
• banking verification
• communications
• WhatsApp messaging
• email delivery
• utility fulfilment
• hosting
• cloud infrastructure
• cybersecurity
• analytics
• artificial intelligence
• music generation
• database services
• customer support
• fraud prevention
• software infrastructure

Only information reasonably necessary for the relevant service should be shared.

Some providers may operate outside Nigeria. Where personal data is transferred internationally, VCN will seek to use appropriate mechanisms and safeguards required by applicable data-protection law.

NDPC guidance expressly contemplates third-party and international processing subject to the Nigeria Data Protection Act.

Utility Credits are non-cash platform credits.

They are not a bank deposit, savings product, investment account or ordinary cash balance.

Utility Credits cannot ordinarily be withdrawn as cash.

They may be used for eligible VCN-supported services, which may include:

• airtime
• mobile data
• electricity
• television subscriptions
• VCN Creator Studio
• AI Music Studio
• other supported services

VCN maintains transaction records relating to Utility Credits for operational, security, accounting and compliance purposes.

VCN may use cookies and similar technologies for:

• authentication
• security
• maintaining sessions
• remembering preferences
• analytics
• performance monitoring
• fraud prevention
• measuring website usage
• advertising and marketing where permitted

Where legally required, non-essential cookies will be subject to appropriate consent choices.

Users should be able to manage applicable cookie preferences.

NDPC itself describes cookies as technologies capable of processing website-engagement information and provides cookie-management controls on its website.

A separate VCN Cookie Policy provides further information.

Eligible VCN members may receive a personal VCN Sales Page.

VCN may permit members to configure third-party advertising or analytics technologies on their Sales Pages, including supported advertising pixels or identifiers.

Where an independent member chooses and controls such third-party technology, additional processing may occur through the relevant third-party platform.

Members must use such features lawfully and comply with applicable privacy, advertising and platform requirements.

VCN may restrict or disable configurations that threaten security, privacy or platform integrity.

Where permitted, VCN may communicate information about:

• products
• marketplace developments
• new features
• educational resources
• community activities
• promotions
• services

Where consent is required for direct marketing, VCN will seek appropriate consent.

Users should be provided with an appropriate means to opt out of non-essential marketing communications.

Transactional, security and legally required messages may still be sent where necessary.

VCN uses reasonable administrative, technical and organisational safeguards designed to protect information against:

• unauthorised access
• unlawful processing
• loss
• misuse
• alteration
• disclosure
• destruction

However, no internet-based system can guarantee absolute security.

Users are responsible for protecting their passwords, verification codes and devices.

Never disclose your VCN password or OTP to another person.

VCN retains personal information only for as long as reasonably necessary for:

• providing services
• maintaining accounts
• transaction records
• fraud prevention
• dispute resolution
• accounting
• security
• regulatory compliance
• legal obligations
• enforcing agreements

Some transaction and audit information may need to be retained after an account is closed where legally or operationally necessary.

Subject to applicable law and relevant exemptions, you may have rights concerning your personal information, including rights to:

• be informed about processing
• request access
• request correction
• request deletion where applicable
• object to certain processing
• request restriction
• withdraw consent where processing depends on consent
• request portability where applicable
• raise concerns about certain automated decisions
• lodge a complaint with the relevant supervisory authority

These categories correspond broadly with the data-subject rights identified by the Nigeria Data Protection Commission.

To submit a privacy request, contact: support@valuecyclenetwork.com. We may need to verify your identity before acting on a request.

VCN is intended only for persons 18 years of age or older. Persons under 18 must not create an account or participate in VCN marketplaces.

If we reasonably determine that an account belongs to an ineligible minor, we may restrict or terminate it and handle associated information in accordance with applicable law.

Where a personal-data breach occurs, VCN will assess the incident and take appropriate steps in accordance with applicable law, which may include containment, investigation, remediation and legally required notifications.

VCN may contain links to third-party websites or services. VCN's Privacy Policy does not automatically govern independent third-party websites.

Users should review the privacy policies of those services.

Privacy concerns should first be sent to:

Email: support@valuecyclenetwork.com

VCN will investigate legitimate privacy complaints and seek to resolve them appropriately.

Nothing in this Policy prevents a data subject from exercising rights available under applicable law, including the right to complain to the Nigeria Data Protection Commission where applicable.

We may update this Privacy Policy to reflect:

• changes in law
• regulatory requirements
• new VCN features
• changes in technology
• changes in our processing practices

Material changes may be communicated through the website, member account, email, WhatsApp or another appropriate channel.

The current version and effective date will be displayed on this page.

For privacy questions, requests or complaints:

Value Cycle Network LTD

Email: support@valuecyclenetwork.com