Last updated on: 21st February, 2018
At Circles we want you to feel safe and confident sharing information. That is why:
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 "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.
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.
We may use your Personal Data for the following purposes:
Providing our App. We may use your Personal Data to offer you all services available through 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 via email or SMS (e.g to verify your account upon registration and to inform you when the Circle you chose is available, and when it starts and ends) 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 “user feedback” surveys designed to help us improve the overall app experience.
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.
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.
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.
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.
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.
Our App may provide links to other websites for your convenience and information and some of these links can be opened in our App. 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.
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 firstname.lastname@example.org. 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.
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.