Circles - Privacy Policy

Last updated on: 1st November, 2017

At Circles we want you to feel safe and confident sharing information. That is why:

  • You have no public profile with Circles and we do not post anything online linking you or your username to the App.
  • Your Circle Members can only see the profile you create on joining a Circle and the information you choose to share within your Circle.
  • The only people who can contact you through the App are your Circle Members and the Circles team. Your Circle Members will never be given your phone number or email address. The Circles system only uses your phone number to identify your account and to let you know when the programme you signed up to begins and ends.
  • We employ login control and encryption methods designed to ensure that only your Circle Members can see anything in your Circle.

Please read our full privacy policy below for more information about how we process your personal data. If you have any questions, please get in touch with us at support@findcircles.io

Welcome to Find Circles Ltd ("Circles") Privacy Policy. Circles is a mobile app designed to help users improve their mental health by subscribing to group based, digital self-development programmes.

We take appropriate security measures, including reasonable physical, organizational, and technical safeguards, to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data. Please be aware that no security measures are perfect or impenetrable, and therefore we cannot guarantee the security of your data.

The Privacy Policy explains how Circles may collect, use, disclose, and secure Personal Data we obtain through the "App" or directly from you (e.g., during physical meet ups). The terms "Circles," "we," and "us" include Circles and our affiliates and subsidiaries. This Privacy Policy is incorporated by reference into the Circles Terms of Use.Any capitalized terms used and not defined in this Privacy Policy shall have the meaning given to them in the Terms of Use.

The "App" means Circles mobile App, our website located at www.findcircles.io, and any other website, mobile application, or Internet service under the control of Circles, whether partial or otherwise, and other software and services provided by us. "Personal Data" means information relating to an identified or identifiable natural individual, such as name, address, email address, or phone number.

PERSONAL DATA WE MAY COLLECT

We may obtain your Personal Data from various sources.

Registration and Account Information. You must create an account to use our App. This includes entering Personal Data such as your username, mobile number, e-mail address and other information you may provide, including which area of your life you are looking to improve, which programme you would like to join, and what your goals are to get there. The Personal Data requested on the registration page is necessary for activating your account registration and for completing your profile information on the App.

Using the App. We collect Personal Data you provide through the App, for example, when you interact with other users in your Circles (e.g., through posts & comments).

Communicate with Us. We may collect Personal Data through your communications with our support team or other communications with us, including Personal Data provided on social media pages relating to our App or during physical meet ups.

Information and Content from Your Device. The App automatically collects information about your device, such as a device unique ID, so that we can provide and customize functionality, such as push notifications. With your permission, the App may access and collect information from your device’s contact list and photo storage.

Automatic Data Collection: Cookies and Related Technologies. When you visit our App or open our emails, we and our third-party partners, such as advertising networks, social media widgets, and analytics providers, may collect certain information by automated means, such as cookies, web beacons and web server logs. By using the App, you consent to the placement of cookies, beacons, and other similar technology in your browser and on emails in accordance with this Privacy Policy. The information collected in this manner includes IP address, browser characteristics, device IDs and characteristics, operating system version, language preferences, referring URLs, and information about the usage of our App. We may use this information, for example, to determine how many users have visited certain pages or opened messages or newsletters, or to prevent fraud. We may link this data to your profile. Our partners also may collect information about your online activities over time, on other devices, and on other websites or apps, if those websites and apps also use the same partners. When they provide such services, they are governed by their own privacy policies.

HOW WE USE YOUR PERSONAL DATA

We may use your Personal Data for the following purposes:

Providing our App. We may use your Personal Data to offer you the App available on our App. This includes for example the access to and use of the Circles to which you have subscribed. We may use sensitive data, such as information about your current health challenges to help find the most relevant Circle for you.

Communicating with you and answering your queries. We may use your Personal Data when we communicate with you (e.g., to verify your account upon registration) and to process and answer your queries relating to our App.

Marketing. We may use your Personal Data, including your email address, for marketing purposes, including to send you marketing communications we think may be useful or relevant to you. We will only send you marketing communications with your prior consent where required under applicable law.

Surveys. With your consent, we may use your Personal Data you provide when completing our voluntary surveys for user feedback.

Improving and maintaining our App. As necessary for the legitimate interests pursued by Circles, we may use your Personal Data to maintain the functionalities and security of the App and improve the services available on the App. In particular, the Personal Data (such as age, gender and area of interest) gathered during sign up allows us to filter and sort the most relevant Circles for you to choose from. We will also build a profile for you, based on the data we collect during signup, but you will have control as to what is shown here and only the members within your Circle can ever see your profile.

Aggregated Data. Aggregated Personal Data does not personally identify you or any other user. We may use and disclose Aggregated Data for any purpose, except where we are required to do otherwise under applicable law. For example, as necessary for the legitimate interests pursued by Circles, we may use it for analytics, statistical purposes, and research to help improve the App or share with individuals or entities who could benefit from the App.

HOW WE MAY DISCLOSE YOUR PERSONAL DATA

We do not rent, sell, or share your Personal Data, unless as described below or with your permission. We will share your Personal Data with third parties in the following circumstances:

We Use Service Providers. We may share your Personal Data with vendors and service providers we use to help us provide and improve the App on our behalf. We do not authorize these service providers to use or disclose such data except as necessary to perform certain services on our behalf. We require these service providers by contract to appropriately safeguard the privacy and security of Personal Data they process on our behalf.

Displaying to Other Users. We may disclose Personal Data, (i) if we are required to do so by law or legal process, (ii) to respond to requests from law enforcement authorities or other government officials, (iii) when we believe disclosure is necessary or appropriate to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others, (iv) in connection with an investigation of suspected or actual fraudulent or illegal activity, or (v) to enforce our terms and conditions.

Legal and Similar Disclosures. We may disclose Personal Data, (i) if we are required to do so by law or legal process, (ii) to respond to requests from law enforcement authorities or other government officials, (iii) when we believe disclosure is necessary or appropriate to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others, (iv) in connection with an investigation of suspected or actual fraudulent or illegal activity, or (v) to enforce our terms and conditions.

Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of Circles assets, or transition of service to another provider, your Personal Data may be disclosed in connection with the negotiation of such transaction, and/or sold or transferred as part of such a transaction as permitted by law and/or contract. If this happens, we will request the buying company to use your Personal Data in a manner that is consistent with this Policy. Following such sale or transfer, the buying company will be the entity responsible for processing your Personal Data and you may contact it directly about any inquiries relating to the processing of your Personal Data.

YOUR RIGHTS AND CHOICES

Subject to applicable law, you may have different rights regarding our use of your Personal Data. You may have the right to request access to and receive information about the Personal Data we maintain about you, update and correct inaccuracies in your Personal Data, and have such information deleted. You also may have the right to restrict or to object to our processing of your Personal Data, or to exercise your right to data portability, as appropriate. You can also withdraw your consent to our processing of Personal Data at any time. When you request the deletion of your Personal Data, object or withdraw your consent to the processing of your Personal Data by Circles, we may not be able to provide all the features of our App to you. Similarly, you can choose not to provide all or parts of your Personal Data to us (e.g., by not completing all data fields in our registration forms). However, in such case, you may not be able to benefit from all the features of our App (e.g., to create an account to use our App). In addition to the above-mentioned rights, you also always have the right to lodge a complaint with a competent supervisory authority subject to applicable law.

If you would like to exercise any of your rights, you can contact us as described in the section "How to Contact Us" below.

You can choose to opt out of the collection and use of certain information through cookies. You can do so via your browser that allows such opt out from certain types of cookies. However, without some of these cookies, we may not be able to provide all the features of our App.

You can at any time tell us not to send you marketing communications by email by clicking on the unsubscribe link within the marketing emails you receive from us, or by contacting us as indicated in the section "How to Contact Us" below.

HOW WE HOLD AND PROTECT PERSONAL DATA

We care about the security of your Personal Data. Therefore, we maintain appropriate administrative, technical and physical safeguards to protect the Personal Data we have about you, in accordance with applicable law. Unfortunately, the Internet cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you provide to us.

We store Personal Data only for as long as it is necessary for the fulfillment of the purpose for which the Personal Data was collected, unless otherwise required or authorized by applicable law.

We may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our App. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the App or sending an email to you.

LINKS TO OTHER WEBSITES

Our App may provide links to other websites for your convenience and information. These websites may operate independently from us. Linked websites may have their own privacy notices or policies, which we strongly suggest you review if you visit any linked websites. To the extent any linked websites you visit are not owned or controlled by us, we are not responsible for the websites' content, any use of the websites, or the privacy practices of the websites.

CHILDREN'S PRIVACY

We do not knowingly collect, maintain, or use Personal Data from children under 18 years of age, and no part of the App is directed to children under the age of 18. If you learn that your child has provided us with Personal Data without your consent, you may alert us at support@findcircles.io. If we learn that we have collected any Personal Data from children under 18, we will promptly take steps to delete such information and terminate the child’s account.

DATA TRANSFERS

We may transfer your Personal Data to countries other than the country in which the information was originally collected. Those countries may not have the same data protection laws as the country in which you initially provided the information. When we transfer your Personal Data to other countries, we will protect that information as described in this Privacy Policy.

If you are located in the European Economic Area (EEA) or Switzerland, we comply with applicable legal requirements providing adequate protection for the transfer of your Personal Data to countries outside of the EEA or Switzerland.

CHANGES TO OUR PRIVACY POLICY

We may update this Policy from time to time to reflect changes in the way we process Personal Data. When we do, we will post the revised policy for material changes, we may also post a prominent notice on the App or send you an email or other notification to notify you of such changes and when they will become effective. We will consider that you have read and accepted these changes if you continue to use the App after we post this notice. Please review our Privacy Policy periodically to ensure that you are aware of any updates.

Contact Information

Circles is the entity responsible for the processing of your Personal Data as described in this Privacy Policy. If you have any questions or comments about this Privacy Policy or if you would like to exercise your rights regarding your Personal Data, please contact us by email at support@findcircles.io or write to us at:

  • Find Circles LTD
  • Attn: Customer Service
  • Flat F
  • 53 Lancaster Gate
  • London
  • W2 3NA