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Privacy Policy

Welcome to Workincircles' Limited Privacy Policy.  Circles is an app that helps people with mental health challenges by proactively keeping them in touch with a small number of committed supporters

The Privacy Policy explains how Circles may collect, use, disclose, and secure information we obtain through the 'App.'  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 any website, mobile application, or Internet service under the control of Circles, whether partial or otherwise, in connection with providing an online platform for Circles' services.


'Personal Information' can be used to readily identify, contact, or locate you.

'Personal Information' means information that alone or when in combination with other information may be used to readily identify, contact, or locate you, such as: name, address, email address, or phone number.  Except where required by law, we do not consider Personal Information to include information an individual makes public through the Service or information about a device.

Personal information we may collect


We collect information when you:

  • register to use the App;
  • use the App; and
  • communicate with us. 

We also collect information, such as anonymous usage statistics, by using cookies, server logs, and other similar technology as you use the App.

Registration and Account Information.
  You must register to use the App. This includes entering your username, mobile number, password, e-mail address and other information you provide. Note that while numerous fields are provided at the time of registering, not all are required to activate your Circles account. It also includes Profile Information that you provide for your user profile. This information allows us to help 'match' users who ask for that service and may include your name, address, health conditions, e-mail address, or any other information you may voluntarily choose to place into your profile or share with other Users.

Using the App.  We collect information you provide through the App.  For example, when you interact with other users through their posts & comments, the App will collect the information you provide in such submissions, including any Personal Information.

Invitations.  We allow users to invite other members to join the app, more specifically to join their Circle, by entering their invitees' mobile phone number. Once the phone number has been entered, we would then send that person an SMS with a link to a page where they can then download our app from the app store?

The phone numbers are only used for inviting people into the Circles' application

Communicate with Us.  We may collect Personal Information through your communications with our support team or through other communications with us, including through social media. 

Location Information from Your Mobile Device.  We may collect and store your location information if your device settings are enabled to send it to us.  We may also infer your location from your IP address and other data.  Collection of this information may improve the provision of the App.

Passive Data Collection. With your permission, we may collect passive data (such as your location and movement) if your device settings are enabled to send it to us. You will have the ability to change these settings at anytime.

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. [If applicable]   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 Service, 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.  We currently use Google Analytics to collect and process certain website usage data.  To learn more about Google Analytics and how to opt out, please visit www.google.com/policies/privacy/partners/.  You may be able to change browser settings to block and delete cookies when you access the App through a web browser.  However, if you do that, the App may not work properly.

How We Use Your Information


We use information to:

  • facilitate and improve our services;
  • communicate with you; and
  • send you marketing communications.
  • Share this info or info derived from user interactions, if permitted by you, with your Circle members to help to help proactively keep you connected to your circle so you can support each other better'

Internal and Service-Related Usage.  We use information, including Personal Information, for internal and service-related purposes.  We may use and retain any data we collect to provide and improve any of our services.

Communications.  We may send email to the email address you provide to us, push notifications to your mobile device if they are enabled, or text messages with your consent, to verify your account and for informational and operational purposes, such as account management, customer service, system maintenance, and other App-related purposes.

Marketing.  We may use information, including Personal Information, to send you information we think may be useful or relevant to you.  You may opt out of email marketing by using the unsubscribe link in a marketing email.

Aggregate Data.  We may anonymize data collected through the App and use and disclose it for any purpose.

How we May Disclose Your Information


We may share information:

  • with our third-party vendors and service providers;
  • with other users;
  • to comply with legal obligations;
  • to protect and defend our rights and property; and
  • with your permission.


We do not rent, sell, or share Personal Information about you with other people or nonaffiliated companies for their direct marketing purposes, unless we have your permission.

We Use Vendors and Service Providers.  We may share any information we receive with vendors and service providers we use to help us provide and improve the App.  For example, we will provide Personal Information to payment processors as part of financial transactions.

Displaying to Other Users.  The information and content you provide to the App may be displayed on the App.  Other users of the App can only see information about you if they are part of your Circle. You can create your own Circle and invite members in or you can be invited into another members' Circle. Any Circle member can share content to the wider network which can then be viewed by the whole Circles' Community.

Marketing.  We do not rent, sell, or share personal information about you that we collect on the App with other people or unaffiliated companies for their direct marketing purposes, unless we have your permission.  We may allow access to data collected by the App to send you information we think may be useful or relevant to you.

Legal and Similar Disclosures.  We may access, preserve, and disclose collected information, if we believe doing so is required or appropriate to: comply with law enforcement requests and legal process, such as a court order or subpoena; respond to your requests; comply with the law; or protect your, our, or others' rights, property, or safety.

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 information 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.  We cannot control how such entities may use or disclose such information.

With Your Permission.  We may also disclose your Personal Information with your permission.


How We Protect Personal Information


We maintain administrative, technical and physical safeguards designed to protect the Personal Information you provide or we collect against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.

We take steps in an effort to treat your information securely and in accordance with this Privacy Policy.  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 Information only for as long as it is necessary for the fulfillment of the purpose for which the Personal Information was collected, unless otherwise required or authorized by applicable law.

By using the App or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the 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 personal information from children under 13.  We will take steps to delete it if we learn we have collected it.

We do not knowingly collect, maintain, or use personal information from children under 13 years of age, and no part of the App is directed to children under the age of 13.  If you learn that your child has provided us with personal information without your consent, you may alert us at datacontroller@circles.care].  If we learn that we have collected any personal information from children under 13, we will promptly take steps to delete such information and terminate the child's account.

Your rights and choices

You have certain rights regarding the Personal Information we maintain about you. We also offer you certain choices about what Personal Information we collect from you, how we use that information, and how we communicate with you.

To the extent provided by applicable law, you may withdraw any consent you previously provided to us, or object at any time on legitimate grounds, to the processing of your Personal Information. To withdraw your consent to or object to the processing of your Personal Information, please contact us as set forth below. We will apply your preferences going forward. In some circumstances, withdrawing your consent will mean that you cannot take advantage of the App.

Subject to applicable law, you may have the right to: obtain confirmation that we hold Personal Information about you, request access to and receive information about the Personal Information we maintain about you, receive copies of the Personal Information we maintain about you, update and correct inaccuracies in your Personal Information, object to the processing of your Personal Information, and have the information blocked, anonymized or deleted, as appropriate. The right to access Personal Information may be limited in some circumstances by local law requirements. To exercise these rights, please contact us as set forth below.

You can opt-out from receiving our marketing communications at any time by e-mail by clicking on the unsubscribe link within the marketing e-mails you receive from us or by contacting us as indicated below.

international users

[If applicable] We may transfer your Personal Information 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 Information to other countries, we will protect that information as described in this Privacy Policy.



We may revise this Privacy Policy, so review it periodically.

Posting of Revised Privacy Policy.  We will post any adjustments to the Privacy Policy on this web page, and the revised version will be effective when it is posted.

New Uses of Personal Information.  From time to time, we may desire to use Personal Information for uses not previously disclosed in our Privacy Policy.  If our practices change regarding previously collected Personal Information in a way that would be materially less restrictive than stated in the version of this Privacy Policy in effect at the time we collected the information, we will make reasonable efforts to provide notice and obtain consent to any such uses as may be required by law.


Effective Date: Jan 17th 2017