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 sending an email to: legal@tinubu.com.

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.

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.

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.

When we act as processors, our processing of personal information isn’t governed by this privacy policy but by our Data Processing Addendum or other data processing terms in place between Tinubu and each customer. For more information on our processing of your personal information as a processor, please contact the Customer that collected your personal information in connection with the Services. 

Our Website is not intended for users under 18 years of age. No one under age 18 may provide any information to or on the Website. We do not knowingly collect personal information from users under 18. If you are under 18, do not use or provide any information on the Website, or on or through any of their respective features, or provide any information about yourself to us, including your name, address, telephone number, or email address. 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, a duly incorporated French company (SA) with a capital of 3 900 290 euros whose head office is located at Immeuble Eqwater, 86 rue Henry Farman, 92 130 Issy-les-Moulineaux. Registered at the R.C.S. NANTERRE

SIREN number: 432 915 460

SIRET number: 432 915 460 00054

Code APE: 6201Z

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.

Please note that we also do not control third parties' collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way.

If you are based in the United States, you can opt out of receiving targeted ads from members of the Network Advertising Initiative ("NAI") on the NAI's website at http://optout.networkadvertising.org.

If you are based in Canada, you can opt out of receiving targeted ads from members of the Digital Advertising Alliance of Canada using their Opt-Out Tool.

If you are based in the European Union, you may visit the websites of the European Interactive Digital Advertising Alliance (“EIDAA”) at https://www.edaa.eu and the European Advertising Standards Alliance (“EASA”) at  http://www.easa-alliance.org.

If you are based in the UK, you can contact the Advertising Standards Authority at https://www.asa.org.uk/.

Residents of certain states in the United States may have additional personal information rights and choices. Please see Your State Privacy Rights in section 4.6 for more information.

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 and may set a cookie to enable the feature to function properly. 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 & 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:

3.1 Direct interactions

You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal information you provide when you:

• download specific content, such as customer success stories, from our Website;
• subscribe to our newsletter;
• request marketing to be sent to you; or
• contact us through our contact form.

3.2 Automated technologies or interactions

As you interact with our Website, we will automatically collect Technical and Usage Data about your equipment, browsing actions and patterns. We collect this personal information using cookies, server logs and similar technologies. We may also receive Technical and Usage Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.

Third parties sources

Your Technical Data is processed by Analytics and IT Security providers such as Google Analytics and SEMRush.

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.

4.1 Purposes for which we will use your personal information

We have set out below, in a table format, a description of all the ways we plan to use your personal information, and, if you are based in the European Union or the UK, which of the legal bases we rely on to do so. Where we rely on legitimate interests as the legal basis for processing your personal data if you are based in the EU ore the UK, we have also identified what our legitimate interests in processing your data are.

4.2 Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing.

4.3 Promotional offers from us

We may use your Identity, Contact, Technical, and Usage Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.

You will receive marketing communications from us if you have requested information from us or purchased products and/or services from us and you have not opted out of receiving that marketing.

4.4 Third-party marketing

We will get your express opt-in consent before we share your personal information with any third party for marketing purposes, including service providers who perform marketing services on our behalf, such as sending communications to you on our behalf, or serving advertisements to you.

4.5 Opting out

You can ask us or third parties to stop sending you marketing messages at any time by contacting us by email at legal@tinubu.com.

If you opt out of receiving marketing messages, you will still receive service-related communications that are essential for administrative or customer service purposes, for example relating to order confirmations, updates to our Website Terms of Use, checking that your contact details are correct.

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; or
• 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 with respect to their personal information, including:  

• Access Rights: the right to receive confirmation of the processing of their personal information, of the nature of the information being processed, and to receive a copy of it.
• Data Portability Right: the right, subject to certain exceptions, to ask that the processing organization communicate to them computerized personal information in a written, intelligible transcript, and any collected personal information in a structured, commonly used, technological format.
• Rectification Right: subject to certain requirements and exceptions, the right to ask to correct the information in the processing organization’s possession t is inaccurate, incomplete, or ambiguous, or if collecting, communicating, or keeping it is not authorized by law.
• De-indexation Right or "Right to be Forgotten": the right to ask organizations to stop disseminating their personal information or to de-index any hyperlink attached to their name giving access to information if this dissemination causes them harm or contravenes the law or a court order.
• Automated Decision Making: the right to be informed when they are the subject of a decision based exclusively on automated processing of their personal information. Organizations must also, on request, inform them about the personal information used to make the decision, the reasons and main factors leading to the decision, and the right to request correction of the personal information used to make the decision. They must also be given the opportunity to present their observations to a member of their staff for review of this decision.

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

4.7 Do Not Track “DNT” Signals

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

4.8 Cookies

You can set your browser to refuse all or some browser cookies or to alert you when websites set or access cookies. If you disable or refuse cookies (or mobile cookies), please note that some parts of this Website may become inaccessible or not function properly. For more information about the cookies we use, 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 get an explanation as to 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 we will explain the legal basis which allows us to do so.

Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, 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, namely, 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) (as applicable);
• 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 UK, namely, as applicable, 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. To obtain a copy of these contractual safeguards, please contact us at [insert contact email address or link to Contact details (Paragraph 10).

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] below for further information.

In some circumstances we will anonymize your personal data (so that it can no longer be associated with you) 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.

You have the right to:

• request access to your personal data (commonly known as “subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• request that we correct your personal data where it is inaccurate or outdated.
• under certain circumstances, have your personal data erased. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons, which will be notified to you, if applicable, at the time of your request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
• If you want us to establish the data's accuracy;
• Where our use of the data is unlawful but you do not want us to erase it;
• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise, or defend legal claims or
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• object to the processing of your personal data at any time, on legitimate grounds, except if otherwise permitted by applicable law, or to lodge a complaint with a supervisory authority, unless we are able to demonstrate that we have compelling legitimate interests that override your rights and freedoms.
• oppose the processing of your personal data for marketing purposes.
• In certain circumstances, you may request the transfer of your personal data to you or a third party. Tinubu Square SA will provide your personal data to you or a third party you have chosen in a commonly used, machine-readable format, but only where the processing of that information is based on (i) your consent; or (ii) the performance of a contract to which you are a party.
• Withdraw consent at any time where we are relying on consent to process your personal data (see the table in section 4 for details of when we rely on your consent as the legal basis for using your data). However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may be unable to provide you certain products or services. We will advise you if this is the case at the time you withdraw your consent.

All the above rights may be exercised by contacting Tinubu Square SA by email at legal@tinubu.com. To protect your privacy, Tinubu Square SA  will take appropriate measures to verify your identity. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

Tinubu Square SA undertakes to provide a response within one month of your request, although that delay may be extended by two further months where necessary, taking into account the complexity and number of the requests.

In general, any person whose personal data is collected may define general or specific guidelines for the storage, erasing, and communication of his or her personal data after his or her death.

Finally, if you are based in the European Union you have the right to file a complaint concerning the processing of your personal data by Tinubu Square SA, with the CNIL (Commission Nationale Informatique et Libertés), the French regulator for data protection issues.

We would, however, appreciate the chance to deal with your concerns before you approach the CNIL so please contact us in the first instance.

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.