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Privacy Policy

Nigima Circles and NigimaHand

Prepared 1 October 2026 | Effective date 7 October 2026

1 Who we are and what this policy covers

WIZER GENERAL INC, incorporated in CANADA and located at 300-181 UNIVERSITY AVENUE, TORONTO ON. M5H 3M7, operates Nigima Circles and NigimaHand. We are accountable for personal information under our control. Our privacy officer can be contacted at PRIVACY@NIGIMA.APP or the address above.

This policy covers visitors, account holders, circle members, organizers, donors including guests, beneficiaries, representatives and people who contact support. It covers our website, progressive web application, any official mobile applications, payment-related records and administrative support. Separate providers may have their own legal responsibilities and privacy notices.

Circles share selected member and contribution information within a group. NigimaHand campaigns can publish stories to anyone on the internet. Financial and identity checks may link activity across both services. These consequences are explained below and through notices at the relevant step. Accepting Terms does not constitute blanket consent to every optional use of personal information.

2 Information we collect

Account and contact information includes your name, email, phone number, country, address where needed, age or date of birth, chosen language, login identifiers and account settings.

Verification information may include identity document details or images, address evidence, verification results, authorized representative details, organization registration, owners or controllers, source-of-funds evidence and screening results. We collect only what the applicable check reasonably requires. A selfie or biometric verification, if introduced, requires a specific notice identifying the provider, processing, retention and available rights before collection; this policy does not authorize an undisclosed biometric feature.

Circles information includes circle membership, agreements, contribution schedules, recipient order, payout details, settled and missed contributions, change requests, approvals, disputes and restriction or clearance records.

NigimaHand information includes organizer and beneficiary details, their relationship and authority, campaign narrative, images, target, donor choices, donation references, payout records and supporting evidence. Medical or hardship evidence may be sensitive. We seek limited evidence of the cause rather than complete medical histories.

Payment records include amount, currency, status, payment route, provider reference, masked account or card identifiers, payment tokens, fees, exchange details, refunds and disputes. Payment providers may receive full payment credentials directly. Card security codes must not be retained by Nigima; full card details must not be placed in chats or proof uploads.

Support and security records include messages sent to support, submitted attachments, complaints, audit logs, consent history and investigation outcomes. Technical information may include IP address, browser and device attributes, timestamps, session identifiers, errors and relevant account or payment security signals. We do not require access to your entire contact list or precise location for ordinary use.

3 Where information comes from

We receive information from you when you register, join a circle, create a campaign, donate, upload proof or contact us. We may also receive it from other members or organizers, payment and identity providers, fraud and sanctions services, and lawful public or official sources used to validate identity or a cause.

An organizer or member providing someone else’s information must have appropriate authority and inform them about its intended use. We do not assume that an organizer’s statement alone provides valid consent to publish sensitive beneficiary information. Where appropriate, we seek confirmation from the person or their authorized representative.

4 Why we use information

We use necessary account information to authenticate users, administer eligibility and preferences, and provide support. We use circle records to administer agreements, reconcile contributions, schedule payouts, communicate material events and resolve disputes. We use campaign and donation records to publish authorized causes, process payments, issue acknowledgments, verify recipients and administer refunds.

Identity, ownership and relevant financial information supports required verification, anti-money-laundering and sanctions obligations where applicable, prevention of impersonation and payment misuse, and lawful responses to authorities. Security logs help investigate account takeover, duplicate payments, unauthorized changes and attempts to bypass restrictions.

We use contact details for essential service notices, and for marketing only with the permission required by applicable law. We may use aggregated or appropriately de-identified statistics to understand payment completion, service errors and use of features. Information that can reasonably be linked back to you remains subject to this policy.

We do not use confidential medical evidence or circle-default notices for unrelated advertising. We do not sell personal information. Any future materially different purpose will be explained before it begins, with consent or another lawful basis where required.

5 Consent choices and legal grounds

We identify the purpose of collecting information before or at collection and obtain meaningful consent where required. We distinguish information essential to a requested service from optional publication, marketing and other optional uses. Express permission is sought for sensitive disclosures where required.

You may refuse optional information, choose not to make a public donor attribution, stop marketing and withdraw consent by contacting the privacy officer. Some withdrawals prevent us from continuing a requested feature, such as verifying a payout. We will explain the effect. Withdrawal does not erase records that we must lawfully retain or stop processing allowed without consent by applicable law.

Consent is not the only possible ground for processing. We may handle information without consent where law permits or requires it, including specified investigations, legal reporting or responses to valid authority requests. We will not rely on a general reference to compliance to justify unnecessary collection.

Where an additional jurisdiction’s law applies, we will identify the relevant legal basis, such as contractual necessity, legal obligation, consent or a permitted legitimate interest, in the applicable notice. A legitimate-interest claim does not override a local requirement for consent.

6 What circle members can see

Members of a circle may see the member identity or display name needed to administer their agreement, accepted schedule and recipient order, contribution and payout status, and material approved changes. Contact details are shared only to the extent explained and necessary for the selected circle communication feature. Full bank details and verification documents are not ordinary group-visible information.

If you are under a circle probe or in default, all circles in which you are involved receive a limited notice of the participation restriction. A pending review must be distinguished from a confirmed default. Once cleared, those circles receive a correction or resolution notice. The purpose is to administer existing shared obligations, not to create a public blacklist.

Notices must be accurate, proportionate and confined to affected circles. They must not disclose medical evidence, source-of-funds documents, confidential compliance alerts or regulatory reports. You may challenge inaccurate status through support or the privacy officer. Recipients must not republish the information for harassment or unrelated screening. Sharing within a circle creates a risk that another member may copy it despite these rules.

7 Public campaigns beneficiaries and donor privacy

A public NigimaHand campaign may display its title, organizer name, authorized beneficiary identity, story, images, target, fundraising total and updates. Public pages may be copied, indexed by search engines and shared outside Nigima. Remove unnecessary identifiers and carefully consider publication of medical, hardship or child-related details.

Sensitive beneficiary content is published only with appropriate informed authorization or another lawful basis. Supporting identity and medical evidence should be supplied privately. An authorized adult must manage a campaign benefiting a child and minimize public information about that child.

Donors may choose whether their name appears publicly where donor attribution is offered. “Anonymous” means hidden from public attribution; it does not mean anonymous to Nigima, a payment provider or an authority acting lawfully. Public display of a name, message or donation amount must match the choices explained at checkout.

Organizers receive the donation and reconciliation information necessary to administer the campaign. Donor contact details are not automatically provided as a marketing list. Any donor-identifying detail shared with the organizer must be disclosed at checkout and have an appropriate legal basis. Beneficiary stories and donor details must not be reused for unrelated promotion without required permission.

You may request removal or correction of public content. We can act on content we control, but cannot guarantee deletion of copies held by search engines or other people. Necessary private transaction and legal records may remain.

8 Guest donation records

You can donate without creating an account. Checkout still collects the donor contact and transaction information needed for processing, acknowledgments, support and checks. Additional identity information may be needed under law, provider requirements or a proportionate risk review. Choosing guest checkout does not waive these requirements.

We can associate a guest payment with a campaign, provider reference and relevant identity or security signals to investigate duplicate payments or misuse. A receipt or support reference allows us to locate the donation without requiring registration. We do not enroll guests in marketing merely because they donate.

9 Providers other recipients and disclosures

We may share necessary information with contracted payment processors, banks and mobile money operators to execute, reconcile, refund and dispute payments; identity and screening providers to perform checks; and hosting, storage, security, notification and customer-support providers to operate the service. Providers acting for us are subject to appropriate confidentiality, security, use and deletion requirements.

Payment institutions and some verification providers may also act under their own legal duties. Their identity and applicable notices will be supplied in the relevant payment or verification flow. A provider discussed during product planning is not necessarily contracted or active.

Authorized staff and professional advisers may access information needed for their role, audit, legal advice or dispute management. We may disclose necessary information to verified regulators, law enforcement, courts or other authorities where legally required or permitted. We evaluate the request and restrict disclosure to its lawful scope.

If our business is reorganized or transferred, personal information may be shared for a lawful transaction subject to appropriate safeguards and use restrictions. We will provide notice and additional choices where required. We do not disclose sensitive information merely because a potential purchaser requests it.

10 Cross service checks and review of decisions

Activity in Circles and NigimaHand may be linked using identity, provider references and lawful security signals to detect account duplication, connected misuse, unusual payments or evasion of legal restrictions. Access must be limited to the relevant purpose.

A circle probe or default alone does not prohibit NigimaHand participation. Its restriction must not be treated as proof of financial crime. Separate legal or security concerns may affect both services and are reviewed independently.

Automated rules may flag activity or apply temporary checks. A flag is not conclusive evidence of wrongdoing. You may request correction of information and review by an authorized person through support, subject to legal confidentiality. Before introducing a solely automated decision with significant effects, we will provide any notices, explanations, contest rights and safeguards required by applicable law. This draft does not authorize an undisclosed credit-scoring service.

11 Cookies device permissions and communications

Essential cookies or similar storage may maintain sessions, authentication, security and checkout continuity. Blocking them can prevent those features from working. Optional analytics or advertising tools, if used, must be identified in a current cookie notice and enabled only under the choices required by applicable law. Rejecting optional tracking must not prevent ordinary use.

Camera or file access is requested when you choose to upload a document or image; push notification permission is requested separately. We do not access your microphone, camera or location in the background for undisclosed monitoring. Any new communication feature requiring these permissions needs a specific notice.

You may control optional push notifications and marketing through available settings or unsubscribe links. Essential receipts, security notices and material circle or campaign communications may still be sent where needed. Avoid including sensitive details in notification previews. We do not promise end-to-end encryption for messaging unless the implemented feature actually provides it.

12 International processing

Nigima may serve people and use providers in more than one country. Personal information may be processed outside your province or country, where legal protections and lawful government access can differ. We remain accountable for information transferred to providers acting on our behalf and use appropriate contractual and other safeguards.

Before publication, the operating notice must identify the actual hosting and processing locations and provide accessible information about relevant providers. The current deployment details are [HOSTING AND PROCESSING COUNTRIES] and [PROVIDER DIRECTORY OR CONTACT ROUTE]. These fields must be completed rather than interpreted as confirmation that data stays in Canada.

Where local law requires a transfer assessment, consent, contractual mechanism or other safeguard, we apply it before the transfer. Service availability in a country does not itself establish that every international transfer is lawful. You may ask the privacy officer about the locations and safeguards relevant to your information.

13 How long we retain information

We retain information only as long as needed for the disclosed purpose, a legal obligation or a documented dispute or preservation requirement. Account closure and consent withdrawal do not automatically erase completed transaction records.

Circle and campaign records are retained for administration, reconciliation and necessary dispute handling. Verification and financial records follow the applicable record category and statutory starting event. Where Canadian money-services-business record obligations apply, many records have minimum five-year requirements; this is not a blanket requirement to keep every image or all data for five years after account closure.

Sensitive identity images and medical evidence should be deleted earlier when a verification result or limited evidence suffices and no legal duty requires the underlying file. Security and support data must have proportionate, documented periods. Records under a legal hold are restricted and retained until the hold ends.

Our approved category-specific schedule is available through [RETENTION SCHEDULE URL OR PRIVACY EMAIL]. Before adopting this policy, Nigima must set actual periods and starting events for accounts, transactions, verification evidence, campaigns, support, logs, consent and backups. At expiry we securely delete or anonymize information; backup copies expire through the documented backup cycle and are not restored for routine use after deletion.

14 Security and privacy incidents

We use safeguards appropriate to sensitivity, including access controls, restricted administrative roles, secure transmission, protection of stored sensitive data, audit records and vendor controls. Before publication, Nigima must verify that the controls described here are implemented. No certification, regulatory endorsement or absolute security guarantee is claimed.

We restrict staff access to the information needed for their work. Confidential investigations and beneficiary evidence require additional access limits. Sensitive documents must be submitted through the designated secure channel, not ordinary group chats. You can help by protecting credentials, checking payment destinations and reporting suspected compromise promptly.

If a privacy incident occurs, we investigate, contain it and assess risk. We notify affected people and authorities, and maintain breach records, where applicable law requires. Where PIPEDA applies, notification and reporting are required as soon as feasible for breaches creating a real risk of significant harm; applicable local duties may differ.

15 Access correction deletion and complaints

You may ask whether we hold information about you, request access and information about its use and disclosures, and challenge its accuracy. We may request proportionate identity confirmation so we do not disclose your information to the wrong person. We will respond within the applicable legal period; under PIPEDA, access requests normally require a response within 30 days, subject to permitted extensions.

You may request account closure, deletion, consent withdrawal or removal of public content. We will explain any lawful retention or refusal and the complaint route. Correction of a default record includes appropriate correction notices to affected circles where required. We do not promise deletion of records that must remain for legal compliance, another person’s rights or a valid legal hold.

Additional rights, including portability, restriction, objection and protections around automated decisions, may apply depending on your location and the processing involved. We assess requests under the law that applies; this policy does not claim that every jurisdiction grants identical rights.

Send requests or complaints to PRIVACY@NIGIMA.APP or SUPPORT@NIGIMA.APP. Explain the issue and include a safe contact method. You may complain to the Office of the Privacy Commissioner of Canada at https://www.priv.gc.ca or another competent privacy authority, whether or not you first contact Nigima. We will not penalize you for exercising lawful privacy rights.

16 Children changes and contact

Our accounts and donation checkout are intended for adults meeting the applicable age requirement. We do not knowingly permit children to operate accounts. Campaigns may benefit children only through an authorized adult, with appropriate permission and limited disclosure. Contact the privacy officer if a child’s information has been submitted without appropriate authority.

We may update this policy to reflect changes in services, providers or law. We display the effective date and provide notice of material changes. If a change introduces a new purpose or disclosure requiring consent, we request that consent before proceeding rather than relying solely on continued use.

Email: PRIVACY@NIGIMA.APP

Operator and postal address: 300-181 UNIVERSITY AVENUE, TORONTO ON. M5H 3M7

Website: https://nigima.app