Privacy Policy

Your privacy is important to Tinubu Square SA (“Tinubu”), so we’ve developed a privacy policy that covers how we collect, use, disclose, transfer, and store your personal information.

Please do not hesitate to contact us if you have any questions on this matter. Note that you are accepting the practices described in this privacy policy by visiting this website, including its subdomains and any content, functionality, and services offered on or through them (collectively, the "Website"). Please note that this privacy policy does not cover the processing of any personal information collected in connection with any surety services offered by Tinubu Square B&A, LLC (“TSBA”) to registered brokers and agents through the domain name spd.suretywave.com, for which any processing of personal information is governed by the TSBA privacy policy available at https://spd.suretywave.com/login.

Introduction

Welcome to the Tinubu privacy policy.

The website www.tinubu.com (the “Website”) is operated by Tinubu Square SA (“Tinubu”).

In order to enhance your experience and the performance of the Website, and to allow you to contact us and follow our activity, Tinubu requires the collection of some of your personal data. Tinubu Square SA, as the data controller, attaches great importance to the protection and respect of your privacy, so we’ve developed a privacy policy that covers how we collect, use, disclose, transfer, and store your personal information.

This privacy policy gives you details about the manner and purposes for which we collect and use the information that we gather and that you provide us through the Website, regardless of where you access or visit it from.

We invite you to read this privacy policy carefully and please do not hesitate to contact us if you have any questions on this matter by sending an email to: legal@tinubu.com.

Privacy Policy Changes

Tinubu undertakes to process personal data in compliance with applicable laws and regulations, this privacy policy and, where applicable, user’s consent. This privacy policy explains to users how their personal data is used and protected by Tinubu.

Tinubu reserves the right to modify the privacy policy. In case of substantial modification of the privacy policy, Tinubu will post a notice on the homepage of the Website at least thirty (30) days prior to the implementation of these modifications, announcing that the privacy policy has changed, and pointing the changes to your attention.

Tinubu encourages users to regularly read this privacy policy, together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal information about you so that you have a complete understanding of Tinubu’s practices concerning the processing of your personal data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

User Consent

By accessing and using our Website, you agree that you have read and understood this privacy policy and consent to the privacy practices (and any uses and disclosures of information about you) described in it.

This privacy policy is in a layered format, so you can click through to the specific areas below.

Because we offer our services globally, we have chosen to format this privacy policy using the European Union (GDPR) model, often considered the strictest model for user transparency.

Privacy Policy Content

1. Important information and who we are
2. The data we collect about you
3. How is your personal data collected
4. How we use your personal information
5. Disclosures of your personal data
6. International transfers
7. How long will you use my personal data for
8. Security
9. Your rights in relation to your personal data
10. Contact Tinubu Square SA

1. Important Information and Who We Are

This privacy policy aims to give you information on how Tinubu collects and processes your personal information through your use of the Website, including any information you may provide through the Website when you fill out a form to download specific content from the site, when you register to receive our news; or when you request information using our contact form.

This privacy policy however does not apply to any personal information processed in connection with any credit insurance surety, or associated consulting services (our “Services”) that we provide to our clients (our “Customers”).

In our processing of personal information in connection with Services we provide to our Customers, we act as a processor under applicable data privacy laws, and in that context, our Customers act as controllers on behalf of whom we process data for purposes of the Services.

Our Website is not intended for users under 18 years of age. If you are under 18, do not use or provide any information on the Website. If we learn we have collected or received personal information from a user under 18, we will delete that information. If you believe we might have any information from or about a user under 18, please contact us by email at legal@tinubu.com.

1.1 Controller

The controller and responsible entity for your personal information is:

• Tinubu Square SA
• Immeuble Eqwater, 86 rue Henry Farman, 92 130 Issy-les-Moulineaux
• SIREN number: 432 915 460
• SIRET number: 432 915 460 00054
• VAT number: FR 06 432 915 460

1.2 Third-party Links

Our Website may include links to third-party websites, plug-ins, and applications. Clicking or enabling those links may allow third parties to collect or share information about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Website, we encourage you to read the privacy policy of every website you visit.

For opt-out resources, refer to the following links:

• United States: Network Advertising Initiative
• Canada: Digital Advertising Alliance of Canada
• European Union: EIDAA
• UK: Advertising Standards Authority

1.3 Social Media Features

Our Website includes Social Media Features, such as links to our company pages on LinkedIn, X (formerly Twitter), Vimeo, and YouTube. As a result of you following our company pages on social media, these features may collect your IP address and information on which page you are visiting on our Website. Social Media Features are either hosted by a third party or hosted directly on our Website. Your interactions with these Features are governed by the privacy policies of the companies providing them.

2. The Data We Collect About You

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store, and transfer different kinds of personal data about you grouped together as follows:

• Identity Data includes first, maiden, last, and company names.
• Contact Data includes email addresses and telephone numbers.
• Technical Data includes your equipment’s internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this Website.
• Usage Data includes information about how you use our Website.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use, and share Aggregated Data, such as statistical or demographic data, for any purpose. Aggregated Data could be derived from your personal information but is not considered personal information by law as this information will not directly or indirectly reveal your identity. For example, we may aggregate Usage Data to calculate the percentage of users accessing a Website feature. However, if we combine or connect Aggregated Data with your personal information so that it directly or indirectly identifies you, we treat the combined data as personal information in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data).

We do not collect any information about criminal convictions and offenses.

2.1 If You Fail to Provide Personal Information

Where we need to collect personal information by law or under the terms of a contract we have with you, and you fail to provide that information when requested, we may not be able to perform the contract we have or are trying to enter with you (for example, to provide you with our Services). In this case, we may have to cancel a Service you have with us, but we will notify you if this is the case at the time.

2.2 Changes to the Privacy Policy and Your Duty to Inform Us of Changes

It is important that the personal information we hold about you is accurate, complete, and up to date. Please keep us informed if your personal information changes during your relationship with us.

3. How is your personal data collected

We use different methods to collect data from and about you, including through:

4. How we use your personal information

We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation.
• Where we have obtained your active agreement to use your personal data for a specified purpose, for example, if you subscribe to an email newsletter.

We will only send you direct marketing communications by email or text if we have your consent. You have the right to withdraw that consent at any time by contacting us.

4.6 U.S. Residents: Your State Privacy Rights

California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Montana, Oregon, Tennessee, Texas, Utah, and Virginia provide (now or in the future) their state residents with rights to:

• Confirm whether we process their personal information.
• Access and delete certain personal information.
• Correct inaccuracies in their personal information, taking into account the information's nature processing purpose (excluding Iowa and Utah).
• Data portability.
• Opt-out of personal data processing for:
  • Targeted advertising (excluding Iowa).
  • Sales.
  • Profiling in furtherance of decisions that produce legal or similarly significant effects (excluding Iowa and Utah).
• Either limit (opt-out of) or require consent to process sensitive personal information.

The exact scope of these rights may vary by state. To exercise any of these rights, please send an email to legal@tinubu.com.

Canadian Residents: Your Federal and Provincial Privacy Rights

Rights of users located in Canada are governed by the Personal Information Protection and Electronic Documents Act, S.C. 2000, c. 5, the Personal Information Protection Act, R.S.A. 2003, c. P-6.5, the Personal Information Protection Act, R.S.B.C. 2003, c. 63 and an Act respecting the protection of personal information in the private sector, CQLR, c. P-39.1, as amended by Law 25, An Act to modernize legislative provisions as regards the protection of personal information (as applicable based on the location of the user in Canada).

Since the adoption of Law 25, Quebec residents have enhanced rights:

• Access Rights: The right to receive confirmation of the processing of their personal information and receive a copy of it.
• Data Portability Right: The right to ask for computerized personal information in a structured, commonly used, technological format.
• Rectification Right: The right to request correction of inaccurate, incomplete, or ambiguous information, or if its collection or use is not authorized by law.
• De-indexation Right: The right to ask organizations to stop disseminating their personal information or to de-index any hyperlink attached to their name.
• Automated Decision Making: The right to be informed about automated decisions based on their personal information and to request human review of such decisions.

Canadian residents who wish to exercise these rights may submit a request to this designated address: legal@tinubu.com.

4.7 Do Not Track “DNT” Signals

While we take reasonable steps to protect the privacy of our Website visitors, we cannot promise that the current limitations of our programming will address every browser setting or honor every browser preference. In particular, we have not implemented program changes to honor “Do Not Track” browser signals. As we refine our programming, we will take steps to honor such requests in the future. Please return to this privacy policy for updates.

4.8 Cookies

You can set your browser to refuse all or some cookies or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this Website may become inaccessible or not function properly. For more information, please see our Cookie Policy.

4.9 Change of Purpose

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to understand how the processing for the new purpose is compatible with the original purpose, please contact us at legal@tinubu.com.

If we need to use your personal information for an unrelated purpose, we will notify you and explain the legal basis for doing so. Note that we may process your personal information without your knowledge or consent, where this is required or permitted by law.

5. Disclosures of Your Personal Data

We may share your personal data with third-party providers in certain circumstances and for the following purposes:

• We will transmit your personal data to its technical service providers, acting in its name and on its behalf.
• We require that these processors undertake to keep your personal data confidential and not use it for any purposes other than providing services to us.
• When it is required to do so under applicable law or to comply with legal proceedings, a court decision, or any other administrative or judicial proceedings.

In the event Tinubu Square SA should change its corporate structure, whether by merging or acquiring another company or following a sale of part or all of its share capital or assets, we reserve the right to transfer your personal data to the entity resulting from such a change.

6. International Transfers

We may transfer your personal data to service providers that carry out certain functions on our behalf. If you are based in the EU or the UK, this may involve transferring personal data outside the UK and European Economic Area (EEA) to countries with laws that do not provide the same level of data protection as EU or UK law (as applicable).

Whenever we transfer your personal data out of the UK or EEA to service providers, we ensure a similar degree of protection is afforded to it by ensuring that the following safeguards are in place:

• We will only transfer your personal data to countries that the EU and the UK have deemed to provide an adequate level of protection for personal data, such as the United States, when the service providers are self-certified under the EU-U.S. and Swiss-U.S. Data Privacy Frameworks and their UK Addition (UK Data Bridge).
• We may use specific standard contractual terms approved for use in the UK and the EU that give the transferred personal data the same protection as it has in the UK and the EU, namely the European Commission’s standard contractual clauses for international data transfers (EU SCCs), the UK International Data Transfer Agreement, or Addendum to the EU SCCs.

Your personal data are hosted on HubSpot servers in the US based on the EU SCCs.

7. How Long Will You Use My Personal Data For

Tinubu Square SA retains your personal data only for the duration necessary to process it, to protect its rights in case of legal disputes, and according to its legal obligations and contractual undertakings.

In particular:

• Your personal data will be retained for 3 years after your last contact with Tinubu Square SA.
• Data collected through cookies are only kept for a thirteen-month period.

In some circumstances, you can ask us to delete your data: see Paragraph 9 for further information.

In some circumstances, we will anonymize your personal data for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

8. Security

This website is protected by physical, administrative, and technical measures implemented to maintain the security, confidentiality, and integrity of personal data collected by Tinubu Square SA and to protect them from loss, abusive use, or alteration.

In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data according to our instructions, and they are subject to confidentiality duties.

We have implemented procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

If you have any questions relating to the security of the website, you can contact Tinubu Square SA by email at legal@tinubu.com.

9. Your Rights in Relation to Your Personal Data

You have a number of rights under data protection laws in relation to your personal data:

• Request access to your personal data (“subject access request”).
• Request that we correct your personal data where it is inaccurate or outdated.
• Under certain circumstances, have your personal data erased.
• Restrict processing of your personal data in certain situations.
• Object to the processing of your personal data for marketing purposes.
• Request the transfer of your personal data to you or a third party in a commonly used, machine-readable format.
• Withdraw consent at any time where we rely on consent for processing.

To exercise these rights, please contact us at legal@tinubu.com.

10. Contact Tinubu Square SA

If you have any questions or suggestions about this Privacy Policy, you can email our legal team at legal@tinubu.com.

If you are based in the European Union or the United Kingdom, you also have the right to complain to your national supervisory authority at any time about data protection issues. We would, however, appreciate the chance to address your concerns before you approach the regulator, so please contact us in the first instance.