PRIVACY POLICY – CERKLES

Last Updated: 25/09/2026

Welcome to Cerkles.

Cerkles is a music and creator social platform that enables fans to discover, stream, share, engage with, and support music and other content created by artists and creators. This Privacy Policy explains how Cerkles (“Cerkles,” “we,” “us,” or “our”) collects, uses, stores, shares, and protects information when you use our website, mobile applications, and related services (collectively, the “Services”).

By using Cerkles, you acknowledge that you have read and understood this Privacy Policy.

GHANA DATA PROTECTION LAW      
Cerkles is committed to protecting personal data in accordance with the Data Protection Act, 2012 (Act 843) of Ghana and other applicable data protection and privacy laws. Where Cerkles processes personal data in Ghana, it will process that data in accordance with the requirements applicable to it under Act 843.

1.0 PURPOSE AND BASIS OF COLLECTION
Cerkles collects personal information only where it is necessary, relevant, and reasonably required for the operation, security, improvement, and provision of the Services, or where otherwise permitted by applicable law.

Depending on the circumstances, Cerkles may process personal information where necessary to provide the Services or perform a contract with you, where you have provided consent, where processing is necessary for legitimate interests that do not override your rights, or where processing is required by law.

Where the provision of particular personal information is optional or mandatory, Cerkles will indicate this where appropriate. If you choose not to provide information that is necessary for a particular feature or service, we may be unable to provide that feature or service.

1.1 ACCOUNT INFORMATION

When you create an account, we may collect the following information enlisted below including but not limited to:

• Name or display name
• Username
• Email address
• Phone number
• Password or authentication credentials
• Profile photograph
• Date of birth or age information where required
• Country or region
• Artist or creator information, where applicable

1.2 CONTENT YOU PROVIDE

 When you use Cerkles, you may provide or upload:

• Music and audio recordings
• Album artwork
• Photos and videos
• Posts
• Comments
• Playlists
• Artist biographies
• Lyrics or other information associated with content
• Messages or other content you choose to submit

You are responsible for ensuring that you have the necessary rights and permissions to upload content to Cerkles. Cerkles may process personal information contained within content you upload or publish, including information about you or other individuals appearing in that content. You should not upload another person's personal information unless you have the appropriate rights or authorisation to do so.

1.3 USAGE AND ACTIVITY INFORMATION

We may collect information about how you interact with Cerkles, including:

• Songs you play
• Listening duration
• Songs you skip
• Likes and dislikes
• Favourites
• Artists you follow
• Playlists you create
• Searches
• Content you view
• Posts you interact with
• Features you use
• Referral information
• Session information

This information may be used to operate and improve Cerkles and to personalize recommendations and content discovery. It further helps the algorithms pick relevant and user-interest worthy content. Cerkles may analyze your activity and interactions to understand your interests and personalize recommendations, including recommending music, artists, creators, playlists, posts, and other content. Where applicable, Cerkles will provide information about the nature and purpose of such profiling and any choices or rights available to you under applicable law.

1.4 DEVICE AND TECHNICAL INFORMATION

 When you access Cerkles, we may automatically collect certain technical information, including:

• IP address
• Device type
• Operating system
• Browser type
• Application version
• Device identifiers
• Network information
• Language and regional settings
• Crash and diagnostic information
• Date and time of activity

1.5 LOCATION INFORMATION

Cerkles may collect approximate location information where reasonably necessary for the operation, security, personalization, or improvement of the Services. In the case of an introduction of a new feature that requires precise location information, we will request the appropriate permission before collecting it. You can control certain location permissions through your device settings.

1.6 PAYMENT INFORMATION

If you purchase products, services, subscriptions, tickets, creator support, or other paid features through Cerkles, payment information may be processed by third-party payment providers. Where appropriate, Cerkles may receive information such as transaction status, transaction amount, payment method type, and transaction identifiers. Cerkles does not necessarily store complete payment card information.

2. HOW WE USE INFORMATION 

We may use collected information to:

• Create and manage user accounts
• Provide and operate Cerkles
• Stream and deliver content
• Personalize music and content recommendations
• Enable users to follow and interact with creators
• Process transactions and payments
• Provide customer support
• Send service-related notifications
• Communicate important updates
• Detect and prevent fraud, abuse, and unauthorized activity
• Protect the security of Cerkles
• Analyse platform performance
• Improve our products and services
• Develop new features
• Understand how users interact with Cerkles
• Enforce our Terms of Service and other policies
• Comply with applicable laws and legal obligations including applicable data protection requirements

We will not use personal information for purposes that are incompatible with the purposes described in this Privacy Policy unless permitted or required by applicable law or, where required, after obtaining appropriate consent.

4. PERSONALIZED RECOMMENDATIONS

Cerkles may use information about your activity on the platform to personalize your experience. For example, we may consider information such as:

• Songs you listen to
• Artists you follow
• Songs you like or save
• Searches
• Listening patterns
• Content you interact with
• Your general region
• Your interaction with recommendations

This information may help us recommend music, artists, playlists, posts, and other content that may be relevant to you. Cerkles may use automated systems to analyze activity and content interactions for recommendation and personalization purposes. These systems are designed to improve content discovery and do not necessarily make decisions that produce legal or similarly significant effects on users.

4. INFORMATION THAT IS PUBLIC

 Some information you provide may be visible to other Cerkles users or the public. Depending on the features you use, this may include:

• Username
• Display name
• Profile photograph
• Artist profile
• Music and other content you publish
• Public playlists
• Followers and following information
• Public posts
• Comments and other public interactions

Do not publish information that you do not want other people to see.

5. HOW WE SHARE INFORMATION

We do not sell your personal information as a standalone product. We may disclose or make personal information available to third parties where necessary to provide the Services, operate our business, protect users and Cerkles, process transactions, comply with legal obligations, or otherwise as permitted by applicable law.

CATEGORIES OF SERVICE PROVIDERS

We may use third-party companies to provide services such as:

• Cloud hosting and infrastructure providers;
• Content delivery providers;
• Storage providers;
• Analytics and measurement providers;
• Authentication and identity providers;
• Communications and messaging providers;
• Payment processors;
• Email or messaging
• Security
• Customer-support providers;
• Error monitoring
• Security and fraud-prevention providers;
• Professional advisers;
• Regulators, courts, law-enforcement authorities or other government bodies where legally required or permitted; and
• Other parties where you have provided appropriate consent.

These providers may process information on our behalf to provide their services.

LEGAL REQUIREMENTS

We may disclose information where reasonably necessary to:

• Comply with applicable law
• Respond to lawful requests
• Protect the rights and safety of Cerkles, users, creators, or others
• Investigate fraud or abuse
• Enforce our agreements and policies

Business Transfers

If Cerkles is involved in a merger, acquisition, financing, restructuring, sale of assets, or similar transaction, information may be transferred as part of that transaction, subject to applicable law.

6. CREATOR CONTENT AND RIGHTS

Creators retain ownership of their content to the extent provided by applicable law and their agreements with Cerkles. When you upload content to Cerkles, you grant Cerkles the permissions necessary to host, store, reproduce, process, distribute, display, communicate, and make that content available through the Services. The specific rights granted may also be governed by Cerkles’ Terms of Service and any separate creator agreements. Uploading content to Cerkles does not by itself transfer ownership of your copyright to Cerkles.

7. DATA SECURITY

We use reasonable technical and organizational measures designed to protect information against unauthorized access, loss, misuse, alteration, or disclosure. These measures may include access controls, authentication controls, encryption where appropriate, monitoring, backups, security testing, staff confidentiality obligations, incident response procedures, and measures designed to prevent unauthorized access, alteration, disclosure, loss, or destruction of personal information. However, no internet service can guarantee absolute security. You are responsible for keeping your account credentials confidential and should notify us if you believe your account has been compromised.

8. DATA RETENTION

Cerkles retains personal information only for as long as reasonably necessary to fulfil the purposes for which it was collected, provide and secure the Services, comply with legal and regulatory obligations, resolve disputes, enforce agreements, prevent fraud and abuse, and protect the rights and safety of Cerkles and its users.

Retention periods may vary depending on the type of information and the purpose for which it is processed. When personal information is no longer required, Cerkles will delete, anonymize, or securely dispose of it in accordance with applicable law and its internal retention procedures. We retain information for as long as reasonably necessary to:

• Provide our Services
• Maintain user accounts
• Meet legitimate business and operational needs
• Resolve disputes
• Prevent fraud and abuse
• Comply with legal obligations
• Enforce our agreements

When information is no longer required, we may delete, anonymize, or otherwise securely dispose of it, subject to applicable legal requirements.

 9. ACCOUNT DELETION AND CONTENT RETENTION

You may request deletion of your Cerkles account by contacting us at privacy@cerkles.com. Cerkles does not currently provide an in-app account deletion function. Once we receive and verify your request, we will take reasonable steps to process the deletion of your account and associated personal information in accordance with applicable law and this Privacy Policy.

9.1 MUSIC AND OTHER UPLOADED CONTENT

When you request deletion of your account, your music, audio recordings, photos, videos, posts, playlists, and other content associated with your account may be removed from public access and from the active Cerkles platform.

Unless a longer retention period is required or permitted by applicable law, Cerkles will retain certain uploaded content for up to sixty (60 days) following a verified account-deletion request. This period allows us to complete deletion processes, address technical issues, prevent abuse, investigate disputes, and maintain the security and integrity of the Services.

After the applicable retention period, Cerkles will delete the content or anonymize it where appropriate.

9.2 AI, MACHINE LEARNING AND PRODUCT IMPROVEMENT

Cerkles may use information and content submitted to the Services to improve, develop, test, evaluate, and maintain Cerkles' technology, including recommendation systems, artificial intelligence and machine-learning models, automated systems, moderation systems, and other features.

Where Cerkles uses uploaded content or associated information for model training, evaluation, corrective feedback, quality improvement, or similar purposes, such use will be subject to the purposes, legal bases, and rights described in this Privacy Policy and applicable law.

Where information can reasonably be associated with an identifiable user, Cerkles will take appropriate measures to limit the use of such information and, where appropriate and technically feasible, will use de-identified or anonymized information for model development, testing, research, analytics, and product improvement.

Deletion of your Cerkles account or removal of content from the Services may not automatically result in the immediate removal of information that has already been incorporated into an aggregated, anonymized, or de-identified dataset, model evaluation dataset, or other technical artifact where the information can no longer reasonably be associated with you.

Cerkles will not represent that deletion of an account necessarily causes previously generated model outputs, aggregated statistics, anonymized datasets, or other non-identifiable technical artifacts to be deleted where such deletion is not technically feasible or is not required by applicable law.

9.3 PUBLIC POSTS AND COMMENTS

If you request account deletion, public posts, comments, and other public interactions associated with your account may be removed from public display. Where necessary for legal, security, fraud-prevention, dispute-resolution, or other permitted purposes, certain records may be retained for the applicable retention period.

9.4 MESSAGES

Private messages associated with your account may be deleted or deactivated as part of the account-deletion process, subject to technical limitations and any information that must be retained for legal, security, fraud-prevention, or dispute-resolution purposes.

Messages sent to other users may remain visible to those recipients where necessary for the operation of the messaging service or where technically necessary to preserve the integrity of conversations. Where appropriate, the sender's identifying information may be removed or replaced with a generic indication that the account has been deleted.

9.5 CREATOR PROFILES

Creator profiles and associated public information may be removed or deactivated following a verified account-deletion request. Content that has been legitimately distributed, licensed, shared, or otherwise made available through the Services may be subject to applicable agreements and may require additional processing to remove.

9.6 FINANCIAL AND TRANSACTION RECORDS

Financial and transaction information may be retained for as long as reasonably necessary to complete transactions, provide refunds, resolve disputes, prevent fraud, maintain accounting records, comply with tax and financial obligations, and satisfy other legal or regulatory requirements.

Cerkles will not retain complete payment-card information where that information is processed and stored by third-party payment providers.

9.7 FRAUD, SECURITY AND LEGAL RECORDS

Cerkles may retain limited information after account deletion where reasonably necessary to detect, investigate, prevent, or respond to fraud, abuse, security incidents, unauthorized activity, legal claims, disputes, or violations of our Terms of Service.

Such information will be retained only for as long as reasonably necessary for the applicable purpose or as required or permitted by applicable law.

9.8 BACKUPS

Deleted information may remain temporarily in encrypted backups or disaster-recovery systems until those backups are overwritten or securely deleted in accordance with Cerkles' backup-retention procedures. Information retained in backups will not be used for ordinary platform purposes except where necessary for security, disaster recovery, legal compliance, or other permitted purposes.

10. YOUR PRIVACY RIGHTS

Depending on where you live and applicable law, you may have rights relating to your personal information, including the right to:

• Request access to information we hold about you
• Request correction of inaccurate information
• Request deletion of certain information
• Request restriction of certain processing
• Object to certain processing
• Request portability of certain information
• Withdraw consent where processing is based on consent

To exercise applicable rights, contact us using the information provided below. We may need to verify your identity before processing certain requests.

11. COOKIES AND SIMILAR TECHNOLOGIES

Our website may use cookies and similar technologies to:

• Keep users signed in
• Remember preferences
• Understand website usage
• Improve performance
• Maintain security
• Measure the effectiveness of our services

You may be able to control cookies through your browser settings. Some functionality may not work properly if certain cookies are disabled.

 12. CHILDREN’S PRIVACY 

Cerkles is intended for users aged 13 and older. We do not knowingly permit individuals under 13 to create accounts or use the Services. If we become aware that an individual under 13 has provided personal information to us, we will take reasonable steps to investigate and delete the information where appropriate. If you believe that a child has provided personal information to Cerkles in circumstances where it should not have been collected, please contact us so that we can investigate and take appropriate action.

 13. INTERNATIONAL DATA TRANSFERS

 Cerkles may use service providers, cloud infrastructure, payment providers, analytics providers, and other technology providers located outside Ghana. Where personal information is transferred outside Ghana, Cerkles will take the measures required by applicable law to protect the information and maintain appropriate safeguards.

14. THIRD-PARTY SERVICES AND LINKS

Cerkles may contain links to websites, applications, payment services, or other third-party services. We are not responsible for the privacy practices of third parties that we do not control. We encourage you to review the privacy policies of third-party services before providing them with personal information.

15. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time. When we make material changes, we may provide notice through Cerkles, our website, email, or other appropriate means. The “Last Updated” date at the top of this Privacy Policy indicates when it was most recently updated.

16. CONTACT US

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

Cerkles

Data Controller: Limitless Technologies Limited
Registered Address: NA/TT 0989 Amanfro-Kasoa

Privacy Email: privacy@cerkles.com

17. GOVERNING LAW

This Privacy Policy is governed by the applicable laws of the Republic of Ghana, including the Data Protection Act, 2012 (Act 843), without limiting any mandatory privacy or data-protection rights that may apply to users under the laws of another jurisdiction.