Privacy
policy

HOC Capital Club (“HOC”, “we”, “us”) operates the members-only HOC Capital Club mobile app for iOS and Android, and this download site. HOC Capital Club is a Cersei Partners company and acts as the data controller for member personal data processed through the app.

This policy is maintained by HOC Capital Club and describes our own practices. It is not an independent certification or audit.

• •Account and identity data. Name, email address, password (stored only as a salted hash), profile details and profile-completion status.
• •Membership application data. Personal details, passport image and the KYC information required to assess a membership request.
• •Financial and transactional data. Payout bank accounts you add (per category and currency), payment receipts you upload, subscription and membership fee records, investments, purchases, RSVPs and bookings.
• •Submissions. Deals, marketplace listings, events and travel packages you submit for approval, including their documents, images, pricing and supporting files.
• •Device and technical data. Device model and operating system, app version, push notification token, session and refresh tokens, and security events such as idle-timeout locks.
• •Location data (optional). If you enable location check-in, we collect your device's precise (fine) location, including in the background while the app is closed, so you're checked in automatically the moment you arrive at the club address — without needing to open the app. We also record any manual country, state or city check-ins you make yourself. Background location is used solely to detect arrival at the club; it is not tracked continuously or used to build a location history.
• •Communications. Messages you send through the concierge, support and account-deletion forms.

Your biometrics never reach us. Face ID, Touch ID and Android fingerprint or face unlock are handled entirely by your device’s secure hardware. The app only receives a yes-or-no result.

Usage Insights stay on your phone. The private tally of how you use the app is stored on the device and is not transmitted to us.

We do not sell member data, and we do not share it for third-party advertising.

• •To provide the club. Authenticating you, showing deals, events, travel, marketplace and concierge, and processing investments, purchases, RSVPs and bookings.
• •To verify members. Assessing membership applications, KYC and identity checks, and managing subscription status.
• •To handle money. Recording payments and receipts and paying out to the bank accounts you nominate.
• •To keep you informed. Status changes on your submissions, club announcements, event reminders and subscription renewal prompts.
• •To keep the club secure. Session management, token revocation on logout, idle-timeout locks and fraud prevention.
• •To provide location check-in. Precise and background location is used only to detect arrival at the club address and record your check-in — a feature you turn on yourself and can turn off at any time.
• •To meet legal obligations. Nigerian financial, tax, anti-money-laundering and audit requirements.

Access inside HOC is limited to the club staff who need it to review submissions, process payments and answer your requests. Outside HOC, data is shared only with service providers acting on our instructions:

• •Push notification providers. Apple Push Notification service (iOS) and Firebase Cloud Messaging (Android) receive a device token so notifications can be delivered.
• •Payment and banking partners. To process membership, subscription and transaction payments and to make payouts.
• •Infrastructure providers. Hosting, storage and email delivery for the club's backend.
• •Regulators and authorities. Where Nigerian law, a court order or a lawful request requires it.

We do not share location data with any third party for advertising or analytics purposes.

Traffic between the app and the club’s backend is encrypted in transit. Passwords are stored hashed, never in plain text, and password creation runs a strength meter and reuse detection. Sessions expire, idle timeouts lock the app, and logging out revokes your refresh token on the server rather than only clearing the device.

The iOS app is distributed through Apple's App Store and the Android app is distributed through Google Play. Only install the apps from links the club publishes.

We keep your personal data for as long as your membership is active. When you ask us to delete your account, we retain your personal data for six to nine months to satisfy Nigerian financial, tax and audit obligations, then delete it permanently.

Records of executed investments, transfers, purchases and bookings may be retained longer where Nigerian financial and tax law specifically requires it, even after your account is deleted.

Location data collected for check-in is retained only as part of your check-in history under the same schedule above, and is deleted with the rest of your account.

Under the Nigeria Data Protection Regulation (NDPR) and, where applicable, the GDPR, you can request access to your data, correction of inaccurate data, deletion of your account and data, restriction of or objection to certain processing, a portable copy of your data, and withdrawal of consent for optional features such as location check-in and push notifications.

Many of these are self-service: edit your profile in the app, tune push notifications per category in Notification settings, turn location check-in on or off at any time in the side drawer, and start a deletion request from Profile → Data & Privacy. Everything else can be raised through the form at the bottom of this page.

The club and its app are intended for adults. We do not knowingly collect data from anyone under 18. If you believe a minor has an account, contact us through the form below and we will remove it.

We may update this policy as the app evolves. Material changes are announced in the app and the revision date at the top of this page is updated. The current version is also cached in the app under Saved for Offline so you can read it without a connection.