Privacy Policy


Who are we for the purpose of Data Processing.

  • DevClub360 is a product of Mortgogenie Property Company Ltd., a private limited company incorporated under the laws of the Federal Republic of Nigeria, with registered office address at 87, Allen Avenue, Ikeja, Lagos.

Why do we collect information?

We collect information to provide, maintain, protect, and improve the Service we offer to our Members of the DevClub360 and to develop new services. We also use the information to protect DevClub360 and the information of the Members and related Users. Unless expressly stated otherwise at the time of collection, all Personal Data collected are mandatory for the purposes described in this policy. Thus, failure to provide them may prevent Us from processing the User’s request or otherwise fulfill the purposes described below. By providing DevClub360 with Your data, You warrant that the data provided is accurate, true, and up to date in all respects.

We also process Personal Information for certain legitimate business purposes, which may include some or all of the following:

  • To enhance, modify, personalize our Services/communications to provide a user-friendly service to all Members of the Platform; 
  • To enhance the security of our app and information systems;
  • To better understand how Members interact with our website;
  • To provide commercial communications that we think will be of interest to You and similar to those contracted by You by DevClub360. This processing activity may involve attaching the information we collect about the User representative of the Member of DevClub360 through this website, information that the Users provide or have provided through other means;
  • To monitor, evaluate and analyze our market, Users, and Services (even ask Your opinion about our Services and conduct User’s surveys) to improve the commercial offer and experience with our Users;
  • To determine the effectiveness of promotional campaigns and advertising, and for periodic review by electronic means (email, phone calls or messages, postal service, etc.) of the usability of the Platform as well as sending information on our Services. At the time of information collection, it will be given the chance to state Your intention not to receive commercial communications by electronic means. In any case, Users would have the option of modifying their preferences for sending commercial communications. Note that even if the User decides not to subscribe or disembroiled from promotional emails or newsletters DevClub360 will need to contact the User to provide relevant information referring to non-commercial communications. In this sense DevClub360 may contact the User to send him/her messages about faults and Service issues. Furthermore, we reserve the right to use e-mail to notify the Users and the Members of the DevClub360 with any eventual claims related to the use of our Services, including without limitation, claims of violation of third-party rights; and/or
  • To identify and prevent fraud.
How do we collect information?

We collect information in three ways: 

Information You give to us. For example, when the User in name and on behalf of the represented Member may choose to sign up for an DevClub360 membership, we will ask for information, like User’s name and email, Member’s geographical and industrial focus.

Information we get from the use of our Services. We may collect information about the User, the Member and the Service that the User in name and on behalf of a Member of the DevClub360 uses and how he/she uses them, like when he/she visits different areas of our website or he/she views and interacts with our ads and content. We use various technologies to collect and store information when the User visits and uses DevClub360, and this may include sending one or more cookies or anonymous identifiers to User’s device. Such Personal Information is collected on the website and generated by the Services usage, it will be subject to all provisions regarding its filings, records, processing, keeping and transferring under Nigeria law and the law of DevClub360’s affiliates’ countries where such data could be collected, processed or accessed.
Information You share through the Service. Many of our Services let the Member of the DevClub360 share information with others. Remember that when the Member shares information publicly, it may be indexable by search engines. Our Services provide the Member with different options on sharing and removing content. Moreover, when an DevClub360 membership has been created via invitation received from a Trusted Partner, the Member also shares some information with the Trusted Partner, such as when the Member joins DevClub360, shares opportunities and creates connections.

What information do we collect?

The information we collect from the Users and/or the Members of the DevClub360 includes: 

  • Contact Information of the Users that allows Us to communicate with them, such as name, professional phone number, and professional email addresses. We may collect additional information in the future with Users’ consent. 
  • Administrative Information of the Members and Potential Members like, for instance, billing information.
  • Relationship Information that helps Us to understand who the Potential Members, the Members, and Users are and what types of Services the Members might like. This includes geographical and industrial focus information. Also, we will collect feedback Users and Members voluntarily share with Us.
  • Transaction Information about how Users and Members interact with DevClub360, such as connections requested, Opportunities shared, and whether Users and Members open an email we send them.
  • Cookies may be used to analyze the Services usage, improve the content, customize our website content and layout, and for other customer service purposes. Cookies are text files that are stored in a computer system via an Internet browser. Through the use of cookies, DevClub360 can provide the users of this website with more user-friendly services that would not be possible without the cookie setting.
  • User’s IP Addresses are automatically logged when a User visits the DevClub360 webpage. The IP Address is used to help identify the User and to gather demographic information about our Users in the website. Our servers may also record: the pages the User visits on our website; the advertising the User sees and/or clicks on; computer, platform, related software, and settings the User is using when accessing the platform; any search terms the User has entered on our website or a referral site; any other web usage activity and data logged by DevClub360’s servers. We use this information for internal system administration, as well as to help diagnose problems with the servers and to administer our website. Such information may also be used to gather demographic information, such as country of origin and Internet Service Provider.
  • Log information we automatically collect and store in server logs when the User in name and on behalf of the related Member uses our Services or views content provided by DevClub360. This may include information and details related to Users and Members, such as: 

– details of how our Service is used, such as search queries and information and accessed pages;

– device-specific information (such as hardware model, operating system version, unique device identifiers);

– Internet protocol address; and/or

– cookies that may uniquely identify used browser or DevClub360 account.

How do we share and protect Your information?

For Legal Reasons. We will share information with companies, organizations, or individuals outside of DevClub360 if we have a good-faith belief that access, use, preservation or disclosure of them is reasonably necessary to: 

  • meet any applicable law, regulation, legal process or enforceable governmental request;
  • enforce applicable Terms and Conditions, including investigation of potential violations;
  • detect, prevent, or otherwise address fraud, security or technical issues; and/or
  • protect against harm to the rights, property, or safety of DevClub360, our Users and Members, or the public as required or permitted by law.

With Trusted Partners. When the Member’s memberships have been created via invitation received from a Trusted Partner, the Trusted Partner receives information concerning its Members, such as when Members join DevClub360, share opportunities, and create connections. The Trusted Partner may process the information of its invited Members of the DevClub360 to single out and report opportunities such Members may be interested in or offer services that may help such Members achieve an Opportunity.

For external processing. We do not share information with companies, organizations, and individuals outside of DevClub360 without the consent of the Users and the related Members. Nonetheless, please note that information regarding the User and the represented Member may be communicated to our affiliates or other trusted businesses or persons to process it for Us, based on our instructions and in compliance with our Privacy Policy and any other appropriate confidentiality and security measures. Before transferring any information considered personal to EEA members/same level of protection states, DevClub360 will obtain the express consent of the User representing a Potential Member or a Member of the DevClub360 and will take steps to ensure that such Personal Information will be afforded the same level of protection as under applicable data protection laws within the DevClub360.

Anonymized Data. We may also share aggregated, non-personally identifiable information publicly, and with our partners. For example, we may share information publicly to show trends about the general use of our Services. 

How can You exercise Your rights of access, rectification, erasure, restriction on processing, objection and portability?

Your Rights. 

The User may exercise at any time its rights of access, rectification, erasure, restriction on processing, and objection to the processing of data, as well as to withdraw at any time any consents that the User has previously given to DevClub360. The Member of DevClub360 has also the right of portability which means the right to receive the personal data which was provided and transmit those data to another controller, as long as the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

Contact Us. To that effect the User may send an email to, enclosing a copy of its ID or equivalent official document certifying its identity. We may reject unreasonably repetitive requests, require disproportionate technical effort (for example, developing a new system or fundamentally changing an existing practice), or risk the privacy of others. 

Data Protection Authorities. Furthermore, if appropriate, the User also has the right to make a complaint to the relevant data protection supervisory authority, e.g. the Spanish Data Protection Authority (“AEPD”) or the UK Data Protection Authority (“ICO”), especially if he/she considers that DevClub360 has not adequately addressed its rights.

Retention of Your Personal Data

We will retain Your personal information for as long as it is necessary for the purposes listed in this Privacy Policy and in no case longer than legally permitted. We maintain a data retention policy that we apply to all data in our care. As long as the personal data is no longer necessary for the fulfillment of the contract or its initiation or if the law does not require us to keep it, it will be securely deleted from our servers.

Children’s Privacy

The Services are not intended for or designed to attract any person under the age of 18 or of the different legal age provided by each country in which the User has access to our Services. DevClub360 does not intentionally or knowingly collect or maintain Personal Information or non-personally identifiable information from any person under the age of 18 or of the different legal age provided by each country in which the User has access to the Services. If DevClub360 learns that Personal Information of persons under the age of 18 or of the different legal age provided by each country in which the User has access to the Services has been collected on the Service’s platform, then DevClub360 may deactivate the User’s account.


Storage. DevClub360 is committed to ensuring that the User’s information is kept and stored securely, and we maintain reasonable physical, technical and organizational measures, and procedures to safeguard and secure the information we collect through our Services and our website. This has been done to prevent unauthorized or unlawful processing of the User’s Personal Information and accidental, unauthorized or unlawful access, use, processing, copying, alteration, transfer, loss or destruction of, or damage to Personal Information. We review our information collection, storage, and processing practices, including physical security measures, to guard against unauthorized access to systems. 

Access by Employees. We restrict access to Personal Information to DevClub360 employees, contractors, and agents who need to know that information to process it for Us, and who are subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations.

Our Privacy Policy does not apply to services offered by other companies or individuals, including products or sites that may include DevClub360 Services or other sites linked from our Services. Our Privacy Policy does not cover the information practices of other companies and organizations who advertise our Services, and who may use cookies, pixel tags, and other technologies to serve and offer relevant ads.

Potential Security Breaches. Whilst DevClub360 has done all of this to comply with the standards required by applicable laws, DevClub360 cannot guarantee that such information will not be subject to unauthorized access, disclosure, alteration or destruction, DevClub360 has physical, electronic, and procedural safeguards in place to protect information. Information is stored on DevClub360 servers and protected by secured networks to which access is limited to a few DevClub360’s authorized employees and personnel. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. If DevClub360 learns of a security systems breach, then we may attempt to notify the User electronically so that he/she will be able to take appropriate protective steps. We may also have the obligation to contact the relevant Data Protection Authority according to the current legislation in force. Furthermore, DevClub360 may also post a notice on the Service platform whether a security breach occurs.

Business Transitions

If DevClub360 is involved in a business transition, such as Joint venture, partnership, a merger, acquisition by another company, or sale of all or a portion of its assets, DevClub360 reserves the right to transfer or assign Users’ and Members’ information to the new entity. As part of such a transaction, the new entity shall be required to commit to the same level of protection of the User’s and Members’ information as described in this Privacy Policy. If DevClub360 will not be able to obtain such a commitment, we will not perform the business transition. DevClub360 shall post a notice on the Service of every change in ownership or control of the Users’ and Members’ information that may occur. The User acknowledges and accepts that in the event of DevClub360’s bankruptcy, insolvency, reorganization, receivership, and/or assignment for the benefit of creditors, and/or the application of laws or equitable principles affecting creditors’ rights generally, DevClub360 may not be able to control how the User’s and Members’ information will be treated, transferred, or used.

International Users

The DevClub360 website and Service are hosted in the United Kingdom. If You are a User accessing the DevClub360 website and Service from the United States, the European Union, Asia, or any other region with laws or regulations governing Personal Information collection, use, and disclosure, that differ from the United Kingdom and/or European Union laws, please be advised that through Your continued use of the DevClub360 website and Service, which are governed by United Kingdom law, and the Agreement, including this Privacy Policy, You are transferring Your Information to the United Kingdom and You expressly consent to that transfer and consent to be governed by United Kingdom law for these purposes.


Our Privacy Policy may change from time to time, and if we make material changes to it, we will provide notice through our Services, or by other means, to provide You the opportunity to review the changes before they become effective. If You object to any changes, You may contact to opt-out of specific new features or to close Your Membership. You acknowledge that Your continued use of our Service after we publish or send a notice about our changes to this Privacy Policy means that the collection, use, and sharing of Your personal data is subject to the updated Privacy Policy.

Cookie management

We inform You that You can revoke at any time the consent given for the use of Cookies, by configuring Your browser in the terms provided in this section. However, You must bear in mind that preventing the use or installation of any specific type of Cookies may affect or hinder the access to and/or provision of certain Services offered on the Website.

Depending on the browser used, the installation options can be found in different sections. Please, consult the instructions of Your browser if You want to know how to block or allow the installation of Cookies.

For the following browsers, You can find more information in the following links:


What Cookies do we use on our Website?

At the DevClub360 Website, we use the following Cookies corresponding to the following purposes:

  1. Technical cookies(i.e. own csfr token session Cookies). These Cookies enable the User to browse through the Website using the different features and services, for example, session cookies which allow to identify the User session or to carry out the authentication for access to restricted areas.
  2. Statistical Cookies(i.e. third-party Google Analytics and Mouseflow Cookies). These Cookies enable DevClub360 to quantify the number of Users and to implement the measurement and statistical analysis of the Services usage. Therefore, DevClub360 analyzes the User’s browsing on the Website in order to improve the offered Services.

Additional information about Mouseflow and Google Analytics is available here: