Effective March 5, 2026 · Last updated March 5, 2026
This summary is here to be helpful, but it's not legally binding. Check the For lawyers section at the top for the full policy.
| Category | Examples |
|---|---|
| Account information | Name, email address, phone number, date of birth, profile photo, username |
| User content | Messages, photos, videos, posts, and other content you share with your contacts through the Service |
| Contact information | Contacts you add or invite within the app (with your permission) |
| Communications with us | Support requests, feedback, and correspondence you send to us |
| Category | Examples |
|---|---|
| Device information | Device type, operating system, unique device identifiers, browser type, language settings |
| Usage data | Features used, actions taken, timestamps, frequency of use, interaction patterns |
| Log data | IP address, access times, pages viewed, app crashes, and diagnostic data |
| Location data | Approximate location derived from IP address (we do not collect precise GPS location unless you explicitly enable a location-sharing feature) |
We may receive information about you from third-party services if you choose to link them to your Circles account (for example, signing in via a social login provider). We only receive the information you authorize the third party to share.
We use the information we collect for the following purposes:
We do not sell your personal information. We do not use your private messages or posts for advertising purposes.
We share your information only in the following circumstances:
We retain your personal information for as long as your account is active or as needed to provide the Service. Specific retention periods include:
We implement technical and organizational measures designed to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include encryption of data in transit (TLS 1.2 or higher) and at rest, access controls, regular security assessments, and incident response procedures.
However, no method of transmission over the internet or electronic storage is completely secure. While we strive to protect your information, we cannot guarantee its absolute security. You are responsible for maintaining the confidentiality of your account credentials.
In the event of a data breach that affects your personal information and poses a risk to your rights and freedoms, we will notify you and the relevant supervisory authorities as required by applicable law. For users in the EEA/UK, we will notify the appropriate data protection authority within 72 hours of becoming aware of a qualifying breach, in accordance with GDPR Article 33. For users in the United States, we will comply with applicable state breach notification laws. Notifications will include the nature of the breach, the categories of data affected, the likely consequences, and the measures we are taking to address it.
Depending on your location, you may have the following rights regarding your personal information:
To exercise any of these rights, contact us at contact@use-circles.com. We will respond within the time frame required by applicable law (typically 30 days). We may ask you to verify your identity before processing your request.
In compliance with the Children's Online Privacy Protection Act (COPPA), we require verifiable parental consent before collecting personal information from children under 13 in the United States. Parents or guardians must create and manage accounts for children under 13.
For users in the European Economic Area and the United Kingdom, we comply with age-appropriate design requirements. We process children's data based on parental consent where required, apply enhanced privacy settings by default for younger users, and conduct data protection impact assessments for features used by minors.
Circles operates globally, and your information may be transferred to and processed in countries other than your country of residence, including the United States and other countries where our servers, service providers, or affiliates are located.
When we transfer personal information across borders, we implement appropriate safeguards to ensure your data receives an adequate level of protection, including:
By using the Service, you acknowledge that your information may be transferred to countries that may have different data protection laws than your country of residence.
Our website and Service may use the following technologies:
We do not use advertising or third-party tracking cookies. You can manage cookie preferences through your browser settings. Disabling certain cookies may affect the functionality of the Service.
The Service may contain links to third-party websites or services. We are not responsible for the privacy practices of those third parties. We encourage you to review the privacy policies of any third-party services you access through the Service.
If you are in the European Economic Area or the United Kingdom, we process your personal information on the following legal bases:
| Legal Basis | Applies To |
|---|---|
| Contract performance | Processing necessary to provide the Service you requested (account creation, messaging, content delivery) |
| Consent | Processing based on your opt-in consent (e.g., optional analytics, contact list access, children's accounts) |
| Legitimate interests | Processing necessary for our legitimate interests, such as improving the Service, preventing fraud, and ensuring security, where those interests are not overridden by your rights |
| Legal obligation | Processing necessary to comply with a legal obligation to which we are subject |
| Vital interests | Processing necessary to protect the vital interests of you or another person (e.g., child safety) |
Residents of certain U.S. states (including California, Virginia, Colorado, Connecticut, and others with comprehensive privacy laws) have additional rights, which may include:
In the preceding 12 months, we have collected the categories of personal information described in Section 1. We do not sell personal information or share it for cross-context behavioral advertising as defined by the CCPA/CPRA. We do not use or disclose sensitive personal information for purposes other than those permitted by the CCPA/CPRA.
To exercise your rights, contact us at contact@use-circles.com. You may also designate an authorized agent to make a request on your behalf.
We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or the Service. When we make material changes, we will notify you by posting the revised policy within the app, sending you an email or push notification, or by other reasonable means at least thirty (30) days before the changes take effect.
The "Last Updated" date at the top of this page will be revised accordingly. Your continued use of the Service after the effective date constitutes acceptance of the updated policy.
If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:
If you are in the EEA or UK and wish to contact our Data Protection Officer, please email [DPO email].
If you are not satisfied with our response, you have the right to lodge a complaint with your local data protection authority.