Privacy Policy

Trikle (“Trikle,” “we,” “us,” or “our”) provides an AI-powered personal finance companion with tools designed to help users manage aspects of their personal finances, including savings, budgeting, and investment tracking.

This Privacy Policy explains how we collect, use, disclose, store, and otherwise process your personal information when you access or use Trikle and the choices and rights available to you.

By creating or using a Trikle account, you acknowledge the practices described in this Privacy Policy. If you do not agree with this Policy, please do not use Trikle.

1. Who We Are

Trikle is operated by:

Trikle Technology Ltd

For purposes of applicable data protection law, Trikle Technology Ltd is responsible for the personal information it processes through the Trikle platform, except where another organization independently determines how and why particular information is processed.

2. Information We Collect

The personal information we collect depends on the features and services you choose to use.

2.1 Account and Profile Information

When you create an account, we may collect information such as your:

• first and last name;
• email address;
• country or location; and
• account authentication information.

You may also choose to provide additional information such as your:

• middle name;
• telephone number;
• date of birth; and
• profile photograph.

We also process information necessary to authenticate your account and help protect it against unauthorized access.

You must be at least 18 years old to create a Trikle account.

2.2 Financial and Transaction Information

Depending on the Trikle features you use, we may process financial information such as:

• transaction history;
• information from financial accounts you choose to connect;
• income and expense information;
• savings goals;
• budgets; and
• investment information you choose to record.

Where you choose to connect an external financial account, we may use an authorized financial technology or open-banking service provider to facilitate the connection and retrieve information you have authorized us to access.

Access to connected accounts for budgeting and financial-management functionality is intended to be limited to the information and permissions necessary to provide the relevant feature.

We do not use your connected-account credentials to independently initiate unauthorized transactions.

2.3 Communications with Your AI Companion

When you interact with Trikle's AI Companion through text, voice, or other supported features, we may process the information you provide, including messages, financial information, preferences, goals, and other content you choose to share, to provide and personalize your experience.

Where voice functionality is used, we may process audio and related data as necessary to enable voice-based interactions.

We may use artificial intelligence technologies and trusted service providers to process these interactions and provide relevant responses and functionality.

We may retain conversation history to provide continuity, maintain appropriate context, improve your experience, and support operation of the AI Companion.

Conversation information associated with your account is retained and deleted in accordance with our data-retention practices and applicable law. See our AI Disclaimer for more on how the AI Companion's responses should be used.

2.4 Payment Information

If you purchase paid Trikle features or services, payments may be processed by third-party payment service providers.

Depending on your location and selected payment method, those providers may collect payment-card, bank-account, billing, or other payment information directly from you.

Trikle generally receives transaction-related information necessary to confirm and administer your purchase, such as:

• payment amount;
• currency;
• payment status; and
• transaction or reference information.

We do not directly store complete payment-card details where those details are processed by our payment service providers.

2.5 Device and Notification Information

When you access Trikle, we may collect certain device and technical information necessary to operate, secure, and improve the Service.

If you enable notifications, we may process device or notification identifiers necessary to deliver alerts, reminders, security messages, and other communications you have requested or enabled.

You can manage notification permissions through your device or application settings where available.

2.6 Cookies and Similar Technologies

We may use cookies and similar technologies that are necessary to operate the Trikle website or platform, maintain user sessions, remember relevant preferences, protect account security, and provide requested functionality.

Where we introduce additional analytics, advertising, or similar technologies, we will provide any notices, choices, or consent mechanisms required by applicable law. See our Cookie Policy for full detail on how we currently use cookies.

3. How We Use Your Information

We may use personal information to:

• create, administer, and secure your account;
• authenticate users;
• provide Trikle's AI Companion and personal finance features;
• provide savings, budgeting, and investment-tracking functionality;
• provide connected-account functionality where requested;
• process purchases;
• personalize your experience;
• maintain appropriate context within AI Companion interactions;
• provide customer support;
• communicate with you about your account, transactions, security, or use of Trikle;
• send notifications you have enabled;
• detect, investigate, and prevent fraud, abuse, unauthorized activity, and security incidents;
• enforce our Terms of Use;
• maintain and improve the reliability and functionality of our Services;
• comply with applicable legal, regulatory, tax, accounting, and recordkeeping requirements; and
• establish, exercise, or defend legal rights and claims.

We do not sell your personal information, and we do not use your financial information to serve third-party advertising.

4. How We Disclose Your Information

We do not disclose personal information except where reasonably necessary to provide our Services, operate our business, protect our users, or comply with applicable law. Depending on the features you use, we may disclose relevant personal information to:

Financial Connectivity Providers. Where you voluntarily connect an external financial account, relevant information may be processed by authorized financial connectivity or open-banking providers to establish and maintain the connection and provide requested account information to Trikle.

Payment Processors. We use third-party payment processors to facilitate purchases and other applicable payments. Payment providers may process your payment information directly and provide us with information necessary to confirm and administer transactions.

AI and Technology Service Providers. We may use trusted technology, infrastructure, communications, artificial intelligence, cloud, security, and related service providers to help operate and deliver Trikle. These providers may process personal information only as necessary to provide services to us and subject to applicable contractual and legal requirements.

Professional Advisers. We may disclose information to lawyers, auditors, accountants, consultants, insurers, and other professional advisers where reasonably necessary for legal, regulatory, accounting, risk-management, or compliance purposes.

Government Authorities and Regulators. We may disclose personal information to courts, regulators, law-enforcement agencies, government authorities, or other authorized bodies where required or permitted by applicable law or valid legal process.

Corporate Transactions. If Trikle or Trikle Technology Ltd undergoes or considers a merger, acquisition, financing, restructuring, sale of assets, investment transaction, or similar corporate transaction, personal information may be disclosed to relevant parties subject to appropriate safeguards and applicable law.

We may also disclose information where reasonably necessary to protect the rights, property, security, or safety of Trikle, our users, or others, subject to applicable law.

5. International Data Transfers

Trikle is operated from Nigeria, but some of our technology and service providers may process or store personal information in other countries.

As a result, information may be transferred to or processed in jurisdictions outside Nigeria.

Where personal information is transferred internationally, we take appropriate steps designed to ensure that such transfers are made in accordance with the Nigeria Data Protection Act 2023 and other applicable data protection requirements.

Where required, we use appropriate contractual, organizational, technical, or other safeguards for international transfers.

6. Data Security

We take the security of personal and financial information seriously.

We maintain reasonable and appropriate technical, administrative, and organizational safeguards designed to protect personal information against unauthorized access, disclosure, alteration, misuse, loss, or destruction. Our safeguards may include measures relating to:

• encryption and secure transmission;
• account authentication;
• access controls;
• monitoring and security procedures;
• personnel access restrictions; and
• other measures appropriate to the nature and sensitivity of the information involved.

However, no electronic system, storage method, or transmission method can guarantee absolute security.

If we become aware of a personal-data breach, we will take appropriate action and provide notifications to affected individuals and relevant authorities where required by applicable law.

7. Data Retention

We retain personal information only for as long as reasonably necessary to provide the Services, fulfill the purposes described in this Policy, maintain appropriate business records, resolve disputes, prevent fraud, enforce our agreements, and comply with applicable legal and regulatory obligations.

Different categories of information may therefore be retained for different periods.

Certain financial, transaction, accounting, tax, or regulatory records may need to be retained after an account has been closed or deleted where required or permitted by applicable law.

When personal information is no longer reasonably required, we will delete, anonymize, or otherwise securely dispose of it in accordance with applicable requirements.

8. Your Privacy Rights

Subject to applicable law, you may have the right to:

• access personal information we hold about you;
• correct inaccurate or incomplete information;
• request deletion of personal information;
• object to or request restriction of certain processing;
• withdraw consent where processing is based on your consent;
• request information concerning how your personal information is processed;
• request data portability where applicable; and
• lodge a complaint with the appropriate data protection authority.

Certain information may be updated through your Trikle account or profile settings.

You may also request deletion of your Trikle account through available account-management functionality.

Account deletion may be subject to reasonable restrictions where an account contains an outstanding balance, pending transaction, unresolved financial obligation, security investigation, or other matter that must be resolved before closure.

Deleting an account does not necessarily result in the immediate deletion of every record. We may retain certain information where required or permitted by law, including financial transaction, fraud-prevention, regulatory, tax, accounting, or legal records.

To exercise a privacy right or request assistance, contact us at compliance@mytrikle.com.

We may need to verify your identity before completing certain requests and will respond within the timeframe required by applicable law.

9. Children's Privacy

Trikle is intended only for individuals who are 18 years of age or older.

We do not knowingly permit individuals under 18 to create or maintain a Trikle account.

If we become aware that personal information has been collected from an individual who is not eligible to use Trikle, we will take appropriate steps to address the account and information in accordance with applicable law.

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our Services, business practices, technology, legal requirements, or regulatory obligations.

When we update the Policy, we will revise the “Last Updated” date.

Where a change materially affects how we process personal information, we will provide additional notice or obtain consent where required by applicable law.

11. Contact Us

If you have questions, concerns, complaints, or requests relating to this Privacy Policy or the way Trikle processes your personal information, contact us at:

• General Support: support@mytrikle.com
• Privacy & Compliance: compliance@mytrikle.com

Trikle Technology Ltd