Privacy Notice

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.

Personal Information We Collect

Personal Information You Provide to Us

Registration and Profile Information. When you open an account with us through the Services (“Account”), we may ask you to provide us with identifiers and contact information such as your name, email address, and any other information you may provide.

Communications. We may also collect identifiers, such as your name, email address, and other information you choose to provide, when you participate in any interactive features of the Services (like send us a message through the Services), fill out a form, publish statements on our platform, participate in a contest or promotion, communicate with us via third-party social media sites, request customer support, or otherwise communicate with us. If you subscribe to our newsletter, then we will collect certain information from you, such as your email address. When we send you emails, we may track whether you open them to learn how to deliver a better customer experience and improve the Services.

Service Content. When you interact with other Members, Creators, and any online communities on the Services, they may collect any content or information you disclose to them. Circle may also collect any content or information you disclose with others through the Services.

Messages Between Creators and Members. When you communicate with Creators and Members through the Services, we and our third-party partners receive the content of the messages you send and receive and information about those messages, such as when it was sent or received.

Careers. If you decide that you wish to apply for a job with us, you may submit your contact information and your resume online. We will collect the information you choose to provide on your resume, such as your education and employment experience. You may also apply through LinkedIn. If you do so, we will collect the information you make available to us on LinkedIn.

Payment Information. If you make a payment through the Services, we ask for your credit card information. Your credit card is passed directly to our payment processor. We do not store this information on our servers. We do store a record of the payment transaction, including the last 4 digits of the credit card number, for account history, invoicing, and billing support. We also store your billing address to calculate any sales tax due in the United States, to maintain records that may be used for investigations of potentially fraudulent credit card transactions, and to print on your invoices. We may collect commercial information such as your purchase history, including records of products or services you have purchased, provided, returned, or are considering purchasing from us.

Personal Information Creators Provide to Us

Creator Content. We may collect content and information Creators disclose through the Services when Creators submit information or content, such as text, messages, audio content, video, images, etc., or when Creators otherwise interact with the Services.

Personal Information Members Provide to Us

Member Content. We may collect content and information Members disclose through the Services when Members submit information or content, such as by commenting on a blog or participating in online communities, or when Members otherwise interact with the Services.

Personal Information That May Be Collected Automatically Through The Services

When you access or use the Services or transact business with us, we and our third-party partners may automatically collect information you provide to us, information about how you access and use the Services and information about the device you use to access the Services, including:

Device Identifiers. Identifiers, such as your IP address, internet service provider, the type of mobile device you use, the temporary or persistent unique device identifiers (sometimes called UDID), and identifiers associated with browser cookies, web beacons and similar technologies we deploy on the Services.

Internet or Other Electronic Network Activity Information. We and our third-party partners may collect information about the devices and computers you use to access the Services, such as browser type, language, operating system, the referring web page, pages visited, and hyperlinks clicked. When you use the Services, we may collect usage information sent to us by your computer, mobile, or other access device that tells us how you are using the Services and other information about your internet activity (“Usage Information”), including the pages you visit, the links you click, the ads you view and click on, videos you watch, purchase information and your checkout process, your location when you access or interact with the Services, and other similar actions. We may also use third-party tools to collect Usage Information you provide to us or information about how you use the Services and may record your mouse movements, scrolling, clicks and keystroke activity on the Services and other browsing, search or purchasing behavior. These tools may also record Usage Information you enter when you interact with the Services or engage in chat features through the Services.

Commercial Information. Commercial information, such as your purchase history, including records of products you have purchased or are considering purchasing from us, services you have provided or have had provided to you, transactional information when you make a purchase (i.e., services provided, product details, purchase price, and date and location of the transaction).

Geolocation Information. We may derive the approximate location of your device from your IP address. We may combine this information with other location-based information, such as your billing or postal code. You have the ability to stop the collection of precise location information at any time (see “Your Choices” below for details).

Information From Cookies and Similar Technologies. We (and our third-party partners and service providers) use different technologies to collect information, including cookies, embedded scripts, mobile SDKs, location-identifying technologies and web beacons. For reference, cookies are small data files stored on your hard drive or in device memory that help us improve the Services and your experience, see which areas and features of the Services are popular, and count visits and web beacons (also known as “pixel tags” or “clear GIFs”) are electronic images that may be used in the Services or emails and help deliver cookies, count visits, and understand usage and campaign effectiveness. For more information about cookies and how to disable them, see our Cookie Policy.

Personal Information Collected from Third Parties.

Information from Third-Party Sources. We may also obtain information about you from other sources. For example, we may collect information about you from third parties, including but not limited to mailing list providers and publicly available sources. When you interact with our Creators, Members, and online communities on the Services, we may collect from them any content or information you choose to disclose or provide. We may also obtain information about you from other sources, including but not limited to social media platforms, marketing partners, and other third parties. For example, if you connect your social media account to your Account or create or log into your Account through a social media site, certain information from your social media account will be disclosed to us, which may include information that is part of your profile or your friends’ profiles. In addition, we may supplement the information that you provide us and/or the information we collect from you with demographic, social, and other information about you that we receive from other sources. Once we combine information from other sources with your information collected pursuant to this policy, we apply this policy to the combined information as long as it is combined.

Personal Information Usage
We use the information, including personal information, we collect about you to:

• provide, maintain, and improve the Services and to enhance and personalize your experience;
• process, complete, and maintain records on transactions;
• provide our Members, Creators, and online communities with the Services. Other Creators may use your personal information for their own purposes, such as to provide you with content, discussions, events, and memberships;
• send you technical notices, updates, security alerts, and support and administrative messages;
• respond to your comments, questions, and requests, and to provide customer service;
• communicate with you about products, services, offers, promotions, rewards, and events offered by Circle and others, and provide news and information we think will be of interest to you;
• monitor and analyze trends, usage, effectiveness and activities in connection with the Services, including our offers, advertising, communications features, and customer service;
• generate deidentified or aggregated data for any lawful purpose;
• detect, investigate and prevent fraudulent transactions and other illegal activities and protect the rights and property of Circle;
• facilitate contests, sweepstakes and promotions and process and deliver entries and rewards;
• link or combine with information we get from the Services and from others to help understand your needs and provide you with better service;
• maintain appropriate records for internal administrative purposes; and
• carry out any other purpose described to you at the time the information was collected or permitted by law.

Personal Information Disclosure

We do not disclose information we collect from or about you, including personal information, except as follows, as otherwise described in this Privacy Policy, or at the time of collection.

With Partners and Affiliates. We may disclose any information we receive to our partners, corporate affiliates, parents, or subsidiaries for any purpose described in this Privacy Policy.

With Service Providers. We may disclose your information to vendors, consultants and other service providers under contract who help with our business operations or who we provide services to (such as web hosting and operations of the app, IT, to process opt-out requests, to assist us in responding to consumer requests for access, deletion, or correction of information, direct mail and email distribution, site analytics, operations or legal and compliance services, and customers purchasing services from Circle).

With Data Analytics and Aggregation Vendors. We may disclose aggregated information that does not include your personal information, and we may otherwise disclose non-identifying information such as general (non-specific) geographic location, device/browser technology, onsite behavior, population data, user segmentation, survey results, and log data, with third parties for data analysis, demographic profiling, and other purposes. Any aggregated information disclosed in this manner will not contain your personal information.

With Other Creators and Members of the Services. If you provide or disclose information with other Creators and Members on the Services, they may use it for their own purposes. If you post information or content, such as by posting photos, commenting on a blog, or participating in online communities, or when you interact with the Services through social media sites, plug-ins or other applications, depending upon your privacy settings, this information may become public on the internet. We cannot prevent further use of this information. You can control what data you disclose through privacy settings available on some social media sites. Please refer to those third-party sites’ privacy policies and terms of use to learn more about their privacy practices, which we do not control.

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 Emergency Response Services. In rare circumstances, if we believe that another Creator or Member on the Services may be at imminent risk of serious physical harm or self-harm, we may access or disclose limited personal information to (a) the Creator responsible for administering the relevant community (the data controller or business) or (b) appropriate emergency response services. We will do so only in accordance with the Creator’s documented permission, limit such disclosures to the minimum amount of personal information necessary, and use this information solely to protect life or physical safety.

With AI providers or Large Language Models (LLMs). We may offer Creators certain AI-powered features to help them operate their community. These features are provided through Circle and operate on models built by trusted third‑party providers such as OpenAI or AWS. These providers have been chosen by Circle for product fit and strong security and privacy oversight. Your personal data may be used to generate responses and enhance your experience. However, we will never use your personal data to train, fine-tune, or improve any external AI models. All data processed by AI models is handled securely and no information is stored, retained, or logged by the AI model provider.

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.

We participate in interest-based advertising and use third-party advertising partners to serve you targeted advertisements based on your browsing history. Typically, though not always, the information used for interest-based advertising is collected through cookies or similar technologies. We may disclose a common account identifier (such as an email address or user ID) with our third-party advertising partners to help identify you across devices. We and our third-party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics and market research.

To learn about interest-based advertising and how you may be able to opt-out of some of this advertising, you may wish to visit the Network Advertising Initiative’s online resources, at http://www.networkadvertising.org/choices, and/or the DAA’s resources at http://www.aboutads.info/choices.

Transfer of Information to the U.S. from Other Countries

The Services are hosted in the United States (“U.S.”) and intended for visitors located within the U.S. If you choose to use the Services from the European Economic Area (“EEA”), United Kingdom (“UK”), Switzerland or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your personal information outside of those regions to the U.S. for storage and processing. We may transfer personal information from the EEA, the UK or Switzerland to the U.S. and other third countries based on approved Standard Contractual Clauses, or otherwise in accordance with applicable data protection laws. We may also transfer your personal information from the U.S. to other countries or regions in connection with storage and processing of personal information, fulfilling your requests, and operating the Services. By providing any information, including personal information, on or to the Services, you consent to such transfer, storage, and processing. For more information about the tools that we use to transfer personal information, you can contact us as described below.

Your Choices

Account Information. You may update and correct certain Account information you provide to us at any time by logging into your Account. If you wish to exercise any privacy-related requests, including deleting or deactivating your Account, you may email us at legal@circle.so or write to us at 228 Park Ave S, PMB 52933, New York, NY 10003, but note that we may retain certain information as required by law or for legitimate business purposes. We may also retain cached or archived copies of information about you for a certain period of time.

Location Information. If you initially consent to our collection of this location information through the Services, you can subsequently stop the collection of this information at any time by changing the preferences on your computer or device. If you do so, certain features may no longer function properly.

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.

Communications with Circle. We want to communicate with you in ways you want to hear from us. Examples include email, which may contain special offers and new product announcements. To the extent that you are receiving marketing communications from the Services, you may unsubscribe or opt-out of future communications as follows: If you no longer wish to receive emails you may click on the hyperlink titled “Unsubscribe” at the bottom of any marketing related email Circle sends to you, and then follow the directions to unsubscribe from email, or you can modify your preferences in your Account settings. Please note that if you opt out of receiving promotional communications from us, we may still send you transactional communications, including emails about your account or purchases.

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.

Do Not Track. There is no accepted standard on how to respond to Do Not Track signals, and we do not respond to such signals.

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.

Additional Notice to Nevada Residents

If you are a resident of the state of Nevada in the United States, you have the right to opt out of the sale of your personal data. Although we do not currently sell personal data of Nevada residents (as defined under Nevada law), you may submit a request to opt-out of the sale of your personal data by legal@circle.so.

Additional Notice to California Residents

If you are a California resident, please also review our California Resident Privacy Notice for more information about the types of personal information we collect and disclose, as well as how to exercise your rights under California law.

Contact Us

Circle is responsible for processing your information. If you have any questions, comments or concerns about our Privacy Policy, you may email us at legal@circle.so. Additionally, if you have any questions, comments or concerns about our Privacy Policy, feel free to send correspondence to the following address:

CircleCo, Inc.
228 Park Ave S
PMB 52933
New York, NY 10003