Privacy Policy

We believe you should always know what data we collect from you and how we use it. We want to empower you to make the best decisions about what you share with us. This policy describes the data we process to support Circles and other services and products offered by Circles (services). If you have questions about this policy, how we collect or process your personal data, or anything else related to our privacy practices, we want to hear from you. You can contact us at any time.

1. What information do we collect?

Information we collect from you

We collect information from you as you use our services. We use this information to operate our services and to personalize your experience.

Account information: To create an account, you must provide us with some personal data so that we can provide our services. This includes your name, a password or other form of authentication, and an email address or phone number. We use this information to authenticate your account and keep it secure, and to help prevent spam, fraud, and abuse. We also use your account information to send you information about our services, recommend relevant content and accounts to you, help you connect with people you know and help others connect with you, and market to you as your country’s laws allow. If you provide us with your phone number, you agree to receive text messages from Circles to that number as your country’s laws allow.

Public content and activity: Most content and activity on Circles is public, including your profile, followed circles and users, tags, likes, posts, replies, and public playlists. We use this information to recommend relevant content and accounts to you and to recommend your content or account to others, to personalize your experience, and to market to you as your country’s laws allow. You are responsible for information you provide through our services, and you should carefully consider what you make public, especially if it is sensitive information. If you update your public content on Circles, such as by deleting a post, we will reflect your updated content.

Messages and non-public content: We provide features that let you communicate more privately. For example, you can use Messages to have non-public conversations on Circles, make your playlists private, or make your activity in a specific circle private. We use information about your Messages to better understand the use of our services, to protect the safety and integrity of our platform, and to recommend relevant content and accounts. If you interact with content shared with you via Messages in a way that would ordinarily be public, for instance by liking a post, that activity will be public. When you use features like Messages, remember that recipients have their own copy of your communications on Circles.

Address book and contact information: You can connect your Circles account to another service like Twitter, Google, or Facebook and sync your contact or friend list. You can also choose to upload and sync your address book on Circles. We use this information to help you connect with people you know and help others connect with you.

Payment information: You may provide us with payment information, including your credit or debit card number, card expiration date, CVV code, and billing address, in order to purchase advertising or other offerings provided as part of our services.

Other information we receive about you

We receive information when you use our services or other websites or mobile applications that include Circles content, and from third parties including advertisers. Like the information you share with us, we use the information below to operate our services and to personalize your experience.

Device and usage information: We collect information about how you use Circles, including information about the devices you use; the content, circles, and accounts you interact with; the features you use; and the time, frequency and duration of your activities. For example, when you visit our websites, sign into our services, interact with our email notifications, use your account to authenticate to a third-party service, or visit a third-party service that includes Circles content, we may receive information about you. This includes information such as your IP address, browser type, operating system, the referring web page, pages visited, location, your mobile carrier, device information (including device and application IDs), search terms, and cookie information. We also receive information when you click on, view, or interact with links on our services. We use this information to operate our services and ensure their secure, reliable, and robust performance. We use also use this information to make inferences like what topics you may be interested in and how old you are. This helps us better design our services for you and recommend relevant content and accounts to you.

Location information: We require information about your signup and current location, which we get from signals such as your IP address or device settings, to securely and reliably set up and maintain your account and to provide our services to you. Subject to your settings, we may collect, use, and store additional information about your location - such as your current precise position or places where you’ve used Circles - to operate or personalize our services including with more relevant content like local trends, stories, ads, and accounts.

Links: In order to operate our services, we keep track of how you interact with links across our services. This includes links in emails we send you and links in posts that appear on other websites or mobile applications. If you click on an external link or ad on our services, that advertiser or website operator might figure out that you came from Circles, along with other information associated with the ad you clicked such as characteristics of the audience it was intended to reach. They may also collect other personal data from you, such as cookie identifiers or your IP address.

Cookies: A cookie is a small piece of data that is stored on your computer or mobile device. Like many websites, we use cookies and similar technologies to collect additional website usage data and to operate our services. Although most web browsers automatically accept cookies, many browsers’ settings can be set to decline cookies or alert you when a website is attempting to place a cookie on your computer. However, some of our services may not function properly if you disable cookies. When your browser or device allows it, we use both session cookies and persistent cookies to better understand the use of our services and to personalize and otherwise operate our services such as by providing account security, personalizing the content we show you including ads, and remembering your preferences.

Advertisers and other ad partners: Advertising revenue allows us to support and improve our services. We use the information described in this Privacy Policy to help make our advertising more relevant to you, to measure its effectiveness, and to help recognize your devices to serve you ads on and off of Circles. Our ad partners and affiliates share information with us such as browser cookie IDs, mobile device IDs, hashed email addresses, demographic or interest data, and content viewed or actions taken on a website or app. Some of our ad partners, particularly our advertisers, also enable us to collect similar information directly from their website or app by integrating our advertising technology. If you are an advertiser or a prospective advertiser, we process your personal data to help offer and provide our advertising services.

Other third parties and affiliates: We may receive information about you from third parties who are not our ad partners, such as others on Circles, partners who help us evaluate the safety and quality of content on our platform, our corporate affiliates, and other services you link to your Circles account. You may choose to connect your Circles account to accounts on another service, and that other service may send us information about your account on that service. We use the information we receive to provide you features like cross-posting or cross-service authentication, and to operate our services.

Personalizing across your devices: When you log into Circles on a browser or device, we will associate that browser or device with your account for purposes such as authentication, security, and personalization. Subject to your settings, we may also associate your account with browsers or devices other than those you use to log into Circles (or associate your logged-out device or browser with other browsers or devices. We do this to operate and personalize our services.

2. What information do we share and disclose?

Sharing you control: We share or disclose your personal data with your consent or at your direction, such as when you authorize a third-party web client or application to access your account or when you direct us to share your feedback with a business.

Subject to your settings, we also provide certain third parties with personal data to help us offer or operate our services. For example, we share with advertisers the identifiers of devices that saw their ads, to enable them to measure the effectiveness of our advertising business. We also share device identifiers, along with the interests or other characteristics of a device or the person using it, to help partners decide whether to serve an ad to that device or to enable them to conduct marketing, brand analysis, interest-based advertising, or similar activities. The information we share with these partners does not include your name, email address, phone number, or Circles username, but some of these partnerships allow the information we share to be linked to other personal information if the partner gets your consent first.

Service providers: We engage service providers to perform functions and provide services to us in the United States, Ireland, and other countries. For example, we use a variety of third-party services to help operate our services, such as hosting our various blogs and wikis, and to help us understand the use of our services, such as Mixpanel. We may share your private personal data with such service providers subject to obligations consistent with this Privacy Policy and any other appropriate confidentiality and security measures, and on the condition that the third parties use your private personal data only on our behalf and pursuant to our instructions. We share your payment information with payment services providers to process payments; prevent, detect, and investigate fraud or other prohibited activities; facilitate dispute resolution such as chargebacks or refunds; and for other purposes associated with the acceptance of credit and debit cards.

Legal requests, harm, and the public interest: Notwithstanding anything to the contrary in this Privacy Policy or controls we may otherwise offer to you, we may save, use, or disclose your personal data if we believe that it is reasonably necessary to comply with a law, regulation, legal process, or governmental request; to protect the safety of any person; to protect the safety or integrity of our platform, including to help prevent spam, abuse, or malicious actors on our services, or to explain why we have removed content or accounts from our services; to address fraud, security, or technical issues; or to protect our rights or property or the rights or property of those who use our services. However, nothing in this Privacy Policy is intended to limit any legal defenses or objections that you may have to a third party’s, including a government’s, request to disclose your personal data.

Information we receive about you (including financial transaction data related to purchases made with Circles) can be accessed and preserved for an extended period when it is the subject of a legal request or obligation, governmental investigation, or investigations of possible violations of our terms or policies, or otherwise to prevent harm. We also retain some information from accounts disabled for terms violations to prevent repeat abuse or other term violations.

Change of ownership and affiliates: If we are involved in a bankruptcy, merger, acquisition, reorganization, or sale of assets, your personal data may be sold or transferred as part of that transaction. This Privacy Policy will apply to your personal data as transferred to the new entity. We may also disclose personal data about you to our corporate affiliates in order to help operate our services and our affiliates’ services, including the delivery of ads.

Non-personal information: We share or disclose non-personal data, such as aggregated information like the total number of times people interacted with a post, the number of people who clicked on a particular link, the circles that people are posting to in a particular location, or reports to advertisers about how many people saw or clicked on their ads.

3. Additional details about our Privacy Policy

Children and our services: Our services are not directed to children, and you may not use our services if you are under the age of 13. You must also be old enough to consent to the processing of your personal data in your country (in some countries we may allow your parent or guardian to do so on your behalf).

Changes to this privacy policy: We may revise this Privacy Policy from time to time. The most current version of the policy will govern our processing of your personal data. If we make a change to this policy that, in our sole discretion, is material, we will notify you via a Circles update or email to the email address associated with your account. By continuing to access or use ourservices after those changes become effective, you agree to be bound by the revised Privacy Policy.

Contact us: You can contact us with questions at hello@getcirclesapp.com.

Effective: June 20, 2019