Privacy Policy

Version 0.2: Effective as of September 1st, 2019.

                                                                                                                                                    

This Privacy Policy describes how Circles Dot World, Inc. (collectively, “ Circles ”, “ we ”, “ us ”, or “ our ”) collects, uses and shares your personal information if you visit the Circles platform, including iOS & Android apps, the website   https://circles.world/  (and subdomains), email distribution lists using the domain @circles.world, or our other websites or services that link to this Privacy Policy (collectively, the “Services”), contact us, receive our communications, or attend our events.

This Privacy Policy does not address content in customer websites.  Content from the Circles platform may be embedded in customer websites with their own URLs (which is covered by this policy) but other content in customer websites is not covered.

Personal Information We Collect

Information you provide to us.   Personal information you provide to us through the Services may include:

End Users

Group (or “circle”) Administrators (“Admins”)

Other information  that we may collect which is not specifically listed here, but which we will use in accordance with this Privacy Policy or as otherwise disclosed at the time of collection.

Cookies  and Other Information Collected by Automated Means

We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and activity occurring on or through the Services. The information that may be collected automatically includes your computer or mobile device operating system type and version number, manufacturer and model; device identifier; browser type; screen resolution; IP address; and information about your use of and actions on the Services, such as pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and length of access.  

This information is used only to operate and improve the service. We do not use third party tracking or analytics, or collect data for the purposes of user tracking or advertising. See our Cookie Policy for more information.

How We Use Your Personal Information

We use your personal information for the following purposes and as otherwise described in this Privacy Policy or at the time of collection:

To operate the Services.   We use your personal information to:

For research and development.   We analyze use of the Services to improve the Services and to develop new products and services.

For compliance, fraud prevention, and safety.   We may use your personal information and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to: (a) protect our, your, or others’ rights, privacy, safety, or property (including by making and defending legal claims); (b) enforce the terms and conditions that govern the Services; and (c) protect, investigate, and deter against fraudulent, harmful, unauthorized, unethical, or illegal activity.

With your consent.   In some cases we may specifically ask for your consent to collect, use, or share your personal information, such as when required by law.

To create anonymous data.   We may create aggregated and other anonymous data from your personal information and other individuals whose personal information we collect.  We make personal information into anonymous data by removing information that makes the data personally identifiable to you.  We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve the Services and promote our business.

Sensitive personal information.   We ask that you not provide us with any sensitive personal information (e.g., social security number, government-issued identification, payment card information , health, biometrics or genetic characteristics, or criminal background) on or through the Services, or otherwise to us.  It is not the purpose of the platform to provide a place for political opinions, but you may do so.

How We Share Your Personal Information

We do not share your personal information with third parties without your consent, except in the following circumstances or as otherwise described in this Privacy Policy:

Other Users of the Services . Other users and admins in your circles will see the content you submit, such as posts, comments and photos. We will display some information, such as your name and a link to your user profile along with the content you submit. We do not control how users or admins use any personal information that you post to the Services.

Circle Admins . Admins in some circles can export a list of user emails or other information for their own organizational and communications purposes. Users joining any circles where this is the case will be clearly warned, with details of what information is being exported and for what purpose. These details provided by the admins constitute a legally binding statement. If you do not wish to make this information available to these admins, do not join these circles.

Service providers .  We may share your personal information with third-party companies and individuals that provide services on our behalf or help us operate the Services (such as customer support, hosting, analytics, email delivery, marketing, and database management services). These third parties may use your personal information only as authorized by their contracts with us.  For example, our hosting company is currently AWS and our payment processor is currently Stripe.  Their privacy policies are  here  and  here .

Third-party platforms and social media networks .  If you have enabled features or functionality that connect the Services to a third-party platform or social media network (such as by connecting your account with a third party to the Services or sharing content via a third-party platform), we may disclose the personal information that you authorized us to share. We do not control the third party’s use of your personal information.

Professional advisors . We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors, and insurers, where necessary in the course of the professional services that they render to us.

For compliance, fraud prevention and safety . We may share your personal information for the compliance, fraud prevention and safety purposes described above.  

Government Requests .  Law enforcement will have access to data only as ordered by a duly-authorized warrant.  Nothing in this policy is intended to limit any legal defenses or objecti ons that you may have to a third party or government request to disclose your information.

Business transfers .   We will not sell, transfer, or otherwise share your personal information in connection with a (potential) business transaction such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets or in the event of bankruptcy or dissolution.

For example, in the event that Circles Dot World, Inc. is acquired by another company, the acquiring company will not gain access to your personal information unless you specifically opt-in to such access.

Your Choices

In this section, we describe the rights and choices available to all users.

Access, update, or delete your information.  We will create a User Data Portal that will provide full access for users to manage their data by logging in, including deletion.

Cookies & browser web storage.   For information on how to disable cookies and similar technologies used in the Services, see our Cookie Policy.

Do Not Track.   Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit.  We do not track users between sites for any users regardless of your DNT setting.

Choosing not to share your personal information. Where we are required by law to collect your personal information, or where we need your personal information to provide the Services to you, if you do not provide this information when requested (or you later ask to delete it), we may not be able to provide you with the Services.  We will tell you what information you must provide to receive the Services by designating it as required at the time of collection or through other appropriate means.

Third-party platforms. If you choose to connect to the Services via a third-party platform, you may have the ability to limit the information that we may obtain from the third party at the time you connect your third-party account to the Services. Subsequently, you may be able to control your settings through the third-party platform. If you withdraw our ability to access certain information from a third-party platform, that choice will not apply to information that we have already received fr om that third party.

Other Sites, Mobile Applications, and Services

The Services may contain links to, or content or features from   other websites and online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or in mobile applications or online services that are not associated with us. We do not control third-party websites, mobile applications, or online services, and we are not responsible for their actions.  

Other websites and services follow different rules regarding the collection, use, and sharing of your personal information.  We encourage you to read the privacy policies of the other websites and mobile applications and online services you use.

Security Practices

The security of your personal information is important to us.  We employ a number of organizational, technical and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.

Examples:

 

 

Retention

We retain personal information where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested; to comply with applicable legal, tax or accounting requirements; to establish or defend legal claims; for fraud prevention; or to identify and report security incidents).  When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

Examples of Specific Practices:

Platform Content : Until the content is deleted in the Services

User Details : As long as that user account exists

Device Information : As long as that device remains logged into the Circles platform

Usage Information : 90 days in complete form; 12 months in aggregated statistics

International Data Transfers

We are headquartered in the United States and store data and have service providers all  in the United States as of the date of this policy, and your personal information may be transferred to the United States from your province or country where privacy laws may not be as protective as those in your province or country.

Children  

The Services are not directed to, and we do not knowingly collect personal information from anyone under the age of 16.  If we learn that we have collected personal information of a child without the consent of the child’s parent or guardian, we will delete it.  We encourage parents with concerns to contact us.

Changes to this Privacy Policy

We may amend this Privacy Policy at any time by posting the amended version on the Services and indicating the effective date of the amended version. We may announce any material changes to this Privacy Policy within the client for all iOS and Android client users.  Email users will be sent policy updates by email.  In all cases, your continued use of the Services after the posting of any modified Privacy Policy indicates your assent to the amended Privacy Policy.

How to Contact Us

If you have any questions or comments about this Policy or Circles’s privacy practices or to exercise your rights under applicable law, email us at privacy-requests@circles.world .

Your California Privacy Rights

Under California law, California residents are entitled to ask us for a notice identifying the categories of personal customer information that we share with certain third parties for their direct marketing purposes, and providing contact information for such third parties. If you are a California resident and would like a copy of this notice, please submit a written request to us via email at privacy-requests@circles.world . You must put the statement "Your California Privacy Rights" in your request and include your name, street address, city, state, and ZIP code. We are not responsible for notices that are not labeled or sent properly, or do not have complete information.

 

California has recently passed legislation known as the California Consumer Privacy Act regarding privacy rights.  That law is still evolving and the terms of this section will be updated to reflect changes in the law.

We are making our best attempt at interpreting it as of the date of this policy.  If the CCPA is applicable to you in its current form, you have the right to:

  1. know the categories of personal information collected about you and its sources and business purpose;
  2. know whether your personal information is sold or disclosed, and to whom;
  3. opt out of the sale of your personal information;
  4. access and then delete your personal information; and
  5. equal service and price (non-discrimination) if you exercise your privacy rights.

“Personal Information” is defined to include information that identifies, relates to, describes, or is capable of being associated with a particular consumer or household. This includes (among other types of personal information) IP addresses, geolocation data, biometric information, and “unique identifiers” such as device and cookie IDs, Internet activity information like browsing history, commercial information such as products or services purchased or consuming histories or tendencies, and characteristics concerning an individual’s race, color, sex (including pregnancy, childbirth, and related medical conditions), age (40 or older), religion, genetic information, sexual orientation, political affiliation, national origin, disability or citizenship status. Inferences drawn from personal information “to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, preferences, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes” are also considered “personal information.”

Contact us at privacy-requests@circles.world  or via the link on our website at https://circles.world  to exercise your CCPA rights.

Thank you for reading this privacy policy. Please send any questions or comments to privacy-feedback@circles.world .

Cookie & Browser Web Storage Policy  

This Cookie Policy explains how Circles Software, Inc. and our corporate subsidiaries and affiliates (collectively, “ Circles ”, “ we ”, “ us ” or “ our ”) uses cookies, browser web storage and similar technologies in connection with the Circles platform and any other service or website that we own or control and which posts or links to this Cookie Policy (collectively, the “ Services ”).

What are cookies and browser web storage?

Cookies are small data files that are placed on your computer or mobile device when you visit a website.  Cookies serve different purposes, like helping us understand how a site is being used, letting you navigate between pages efficiently, remembering your preferences and generally improving your browsing experience.  

Browser web storage, also known as locally stored objects (“LSOs”), is used for similar purposes as cookies. Browser web storage enables the storage of a larger amount of data than cookies.

Your web browser will provide functionality to clear your cookies and web storage.  

What types of cookies and similar technologies does Circles use on the Services?

The core Circles platform does not use cookies of any kind. It uses browser web storage to cache Platform Content to improve your browsing experience. This cached content is not shared with or available to third parties.

Other parts of the Services may use essential session cookies, which expire once you close your web browser.

Parts of the Services that integrate with third-party online services and are clearly offered to users as such, including Single Sign-On using a user identity from another service, may require cookies from that third-party service. We encourage you to read the privacy policies of such online services.

We do not use third-party tracking or analytics cookies, or engage in data collection for the purposes of advertising or user commodification.

Your choices

Most browsers let you remove or reject cookies and browser web storage.  To do this, follow the instructions in your browser settings.  Many browsers accept cookies by default until you change your settings.  Please note that if you set your browser to disable cookies, the Services may not work properly.

For more information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit   www.allaboutcookies.org .  If you do not accept our cookies, you may experience some inconvenience in your use of our Services.

For more information about how we collect, use, and share your information, see our Privacy Policy.

Changes

Information about the cookies we use may be updated from time to time, so please check back on a regular basis for any changes.

Questions

If you have any questions about this Cookie Policy, please contact us at privacy-requests@circles.world .