Privacy Policy

Welcome to the Circle Privacy Policy

When you use Circle services, you trust us with your information. This Privacy Policy is meant to help you understand what data we collect, why we collect it, and what we do with it. This is important; we hope you will take time to read it carefully.

Privacy Policy

Last modified: July 1, 2017

There are many different ways you can use our services – to search for and share information, to communicate with other people. When you share information with us, we can make those services even better – to help you connect with people or to make sharing with others quicker and easier. As you use our services, we want you to be clear how we’re using information and the ways in which you can protect your privacy.

Our Privacy Policy explains:
• What information we collect and why we collect it.
• How we use that information.
• The choices we offer, including how to access and update information.

We’ve tried to keep it as simple as possible. Your privacy matters to Circle so whether you are new to Circle or a long-time user, please do take the time to get to know our practices – and if you have any questions contact us.

Information we collect

We collect information to provide better services to all of our users.
We collect information in the following ways:

• Information you give us. For example, many of our services require you to sign up for a Circle Account or sign in from social network media accounts. When you sign up a Circle Account we’ll ask for personal information, like your email address and password with your account.
• Information we get from your use of our services. We collect information about the services that you use and how you use them. This information includes:
◦ Device information
We collect device-specific information (such as your hardware model, operating system version, unique device identifiers, Circle MAC identifiers). Circle may associate your device identifiers with your Circle Account.
◦ Log information
When you use our services by Circle, we automatically collect and store certain information in server logs. This includes:
▪ details of how you used our service.
▪ device event information such as hardware settings, browser language and mobile phone model number.
◦ Location information
When you use Circle services, we may collect and process information about your actual location. We use various technologies to determine location, including GPS, and other sensors that may, for example, provide Circle with information on nearby devices, Wi-Fi access points and cell towers.
◦ Unique application numbers
Certain services include a unique application number. This number and information about your installation (for example, the operating system type and application version number) may be sent to Circle when you install or uninstall that service or when that service periodically contacts our servers, such as for automatic updates.
◦ Local storage
We may collect and store information (including personal information) locally on your device.

Information we collect when you are signed in to Circle, in addition to information we obtain about you from partners, may be associated with your Circle Account. When information is associated with your Circle Account and social network media accounts, we treat it as personal information.

How we use information we collect

We use the information we collect from all of our services to provide, maintain, protect and improve them, to develop new ones. We will ask for your consent before using information for a purpose other than those that are set out in this Privacy Policy.

Circle processes personal information on our servers in many countries around the world. We may process your personal information on a server located outside the country where you live.

Information you share

Many of our services let you share information with others.

Information we share

We do not share personal information with companies, organizations and individuals outside of Circle unless one of the following circumstances applies:

• With your consent
We will share personal information with companies, organizations or individuals outside of Circle when we have your consent to do so. We require opt-in consent for the sharing of any sensitive personal information.
• For external processing
We provide personal information to other trusted cooperate 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
• For legal reasons
We will share personal information with companies, organizations or individuals outside of Circle if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:
◦ meet any applicable law, regulation, legal process or enforceable governmental request.
◦ enforce applicable Terms of Service, including investigation of potential violations.
◦ detect, prevent, or otherwise address fraud, security or technical issues.
◦ protect against harm to the rights, property or safety of Circle, our users or the public as required or permitted by law.

We may share 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.
If Circle is involved in a merger, acquisition or asset sale, we will continue to ensure the confidentiality of any personal information and give affected users notice before personal information is transferred or becomes subject to a different privacy policy.

Information security

We work hard to protect Circle and our users from unauthorized access to or unauthorized alteration, disclosure or destruction of information we hold. In particular:
• We encrypt many of our services using SSL.
• We review our information collection, storage and processing practices, including physical security measures, to guard against unauthorized access to systems.
• We restrict access to personal information to Circle employees, contractors and agents who need to know that information in order 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.

When this Privacy Policy applies

Our Privacy Policy applies to all of the services offered by Circle Inc. on Android devices, and services offered on other sites, but excludes services that have separate privacy policies that do not incorporate this Privacy Policy.
Our Privacy Policy does not apply to services offered by other companies or individuals, including products or sites that may be displayed to you in Circle 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.

Compliance and cooperation with regulatory authorities

We regularly review our compliance with our Privacy Policy. When we receive formal written complaints, we will contact the person who made the complaint to follow up. We work with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of personal data that we cannot resolve with our users directly.

Changes

Our Privacy Policy may change from time to time. We will not reduce your rights under this Privacy Policy without your explicit consent. We will post any privacy policy changes on this page and, if the changes are significant, we will provide a more prominent notice (including, for certain services, email notification of privacy policy changes). We will also keep prior versions of this Privacy Policy in an archive for your review.