Last Updated: August 12, 2024

Circle is an all-in-one community platform for creators and brands. This privacy policy (“Privacy Policy”) explains how CircleCo, Inc. (“Circle” “we,” “us,” and/or “our”) collects, uses, and discloses information from individuals (“you” and/or “your”), including community owners (“Creators”) and community members (“Members”), who use our website (including https://circle.so), app, and other online products or services that link to this Privacy Policy (collectively, the “Services”). Beyond the Privacy Policy, your use of the Services is also subject to our Terms of Service.

Part of the Services include enabling certain Creators to form communities (each, a “Community”) and to make these Communities available to others on the Services. This Privacy Policy does not apply to your activity or data processed within a Community or any information you disclose to a Community. We encourage you to read each Community’s privacy policies before providing any information to them.

We reserve the right, at our discretion, to change, modify, add, or remove portions of this Privacy Policy at any time. If we make changes, we will notify you by revising the date at the top of the policy and, in some cases (for example if we plan to use your information in a way that materially differs from this Privacy Policy), we will provide you with additional notice (such as adding a statement to our website homepage or sending you a notification).

We encourage you to review the Privacy Policy whenever you access the Services or otherwise interact with Circle to stay informed about our information practices and the choices available to you.

When our Creators use the Services to set up accounts for their Members, or submit, manage, or otherwise use content relating to our Creators’ data, we have contractually committed ourselves to only process such information on behalf of and under the instruction of the respective Creator. Where applicable, this means that the Creator is the “data controller” or “business," and we use such information as a "processor" or "service provider." This Privacy Policy does not apply to such processing, and we recommend you read the privacy policy of the respective Creator if their processing concerns your personal information.

When you use the Services, we may collect the following types of information from and about you. Some of this information may be considered “personally identifiable information,” “personal data,” or “personal information,” meaning it reasonably identifies you or your device or could reasonably be linked or associated with you.

With Legal and Law Enforcement. We may disclose information collected about you with law enforcement, governmental agencies, or authorized third parties, in response to a verified request relating to a criminal investigation or alleged illegal activity or any other activity that may expose us, you, or any other Creator or Member to legal liability or if we believe disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements.

In Connection with a Change of Control. We may transfer or disclose your information in connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company.

With your Consent. Where applicable, we may disclose your information with your consent or at your specific direction.

Children’s Privacy

The Services are not intended for individuals under the age of 16. No one under the age of 16 is authorized to provide any personal information through the Services. We do not knowingly collect personal information from the Services from anyone in this age group. If we learn that we have collected or received personal information from a child under the age of 16, we will take reasonable steps to delete that information. If you believe we might have any information from or about a child under 16, please contact us at the email address below.

Social Sharing Features

The Services may offer social sharing features and other integrated tools, which let you share actions you take on the Services with other media, and vice versa. Your use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the entity that provides the social sharing feature. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of the entities that provide these features.

Third-Parties

The Services may contain links to other websites, including our affiliated or co-branded web sites. Other websites may also reference or link to the Services. These other websites may not be controlled by us. We encourage you to read the privacy policies of every website or mobile application that collects personal information. We do not endorse, screen or approve, and are not responsible for the privacy practices or content of other websites or mobile applications. Visiting these other websites is at your own risk.

Security

We make reasonable efforts to protect your information by using security measures designed to safeguard the information we maintain. However, because no electronic transmission or storage of information can be entirely secure, we can make no guarantees as to the security or privacy of your information.

Advertising and Analytics Services Provided by Others

We may allow third-party partners and tools to provide analytics services and serve advertisements on our behalf across the internet and in the Services, including Google Analytics. These partners may automatically collect device identifiers and Usage Information through technologies such as cookies and web beacons, including mouse clicks and movements, page scrolling and any text keyed into website forms and other browsing, search or purchasing behavior. These tools may also record information you enter when you interact with the Services and other websites and applications. This information may be used by Circle and our third-party partners to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on the Services, and better understand your online activity. Please see our Cookie Policy for more information about these practices and any choices you may have regarding cookies. You may learn more about Google’s practices with Google Analytics by visiting Google’s privacy policy at http://www.google.com/policies/privacy/partners.

Cookies. For more information about our and our third-party partners’ use of cookies and related technologies to collect information automatically, and any choices you may have in relation to cookies, please see our Cookie Policy.

Mobile Push Notifications/Alerts. With your consent, we may send promotional and non-promotional push notifications or alerts to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device. By downloading and using our app, you may also receive promotional messages, offers, news and information about Circle. If you do not want to receive “in app” messages, offers, news and information, do not download or use our app.

Additional Notice to European Residents

If you are located in the EEA,EU, UK, or Switzerland, or otherwise engage with our European operations, please see the European Privacy Policy for additional European-specific privacy information, including what constitutes your personal data, the lawful bases we rely on to process your personal data, how we use cookies when you access the Services from the EEA, UK or Switzerland, our data retention practices, and your rights in respect of your personal data.

To see full Circle privacy notice visit: