Privacy Policy

This Privacy Policy was updated on, and its effective date is: December 21, 2023.


Circle is an all-in-one, white-labeled community platform for creators and brands that helps them bring their discussions, memberships, and content to their audience and community, all under their own brand. This Privacy Policy explains how CircleCo, Inc. (“Circle” “we,” “us,” or “our”) collects, uses, and discloses information about you when you access or use our Circle Website (“Website”), https://circle.so, or our Circle Web Application (“App”) and other online products or services that link to this Privacy Policy through the Website or the App (collectively, the “Services”). This Privacy Policy does not apply to any other data gathered or used by Circle including data collected through websites that do not link to this Privacy Policy.

We reserve the right, at our discretion, to change, modify, add, or remove portions of this Privacy Policy at any time. If we make changes, we will notify you by revising the date at the top of the policy and, in some cases (for example if we plan to use your information in a way that materially differs from this Privacy Policy), we will provide you with additional notice (such as adding a statement to our website homepage or sending you a notification).

We encourage you to review the Privacy Policy whenever you access the Website, App, or Services or otherwise interact with Circle to stay informed about our information practices and the choices available to you.

When our customers and their admins use our Website, App, or Services to set up accounts for their users, or submit, manage, or otherwise use content relating to our customers’ data (“Customer Data”), we have contractually committed ourselves to only process such information on behalf of and under the instruction of the respective customer. Where applicable, this means that the customer is the "data controller" or "business" and we use such information as a "processor" or "service provider". This Privacy Policy does not apply to such processing, and we recommend you read the privacy policy of the respective customer if their processing concerns your personal information.

When you use the Website, App, or Services, we may collect the following types of information from and about you. Some of this information may be considered “personally identifiable information” (“PII”) or “personal information” (“PI”), meaning it reasonably identifies you or your device or could reasonably be linked or associated with you.

Information You Provide to Us:

When you open an account with us through the Services (“Account”), we may ask you to provide us with identifiers and contact information such as your name, email address, and any other information you may provide. We may also collect identifiers when you participate in any interactive features of the Services (like send us a message through the Services), fill out a form, publish statements on our platform, participate in a contest or promotion, make a purchase, apply for a job, communicate with us via third-party social media sites, request customer support, or otherwise communicate with us.

When you pay for our Services, we ask for your credit card information. Your credit card is passed directly to our payment processor. We do not store this information on our servers. We do store a record of the payment transaction, including the last 4 digits of the credit card number, for account history, invoicing, and billing support. We also store your billing address to calculate any sales tax due in the United States, to maintain records that may be used for investigations of potentially fraudulent credit card transactions, and to print on your invoices. We may collect commercial information such as your purchase history, including records of products or services you have purchased, provided, returned, or are considering purchasing from us.

Finally, we may collect other content and information you share through the Services when you submit information or content, such as by commenting on a blog or participating in online communities, or when you otherwise interact with our Services. When you interact with other users, our customers, their admins and their online communities on our Website, App or Services, they may collect any content or information you share with them. Circle may also collect any content or information you share with others through the Website, App or Services.

Information That May Be Collected Automatically Through Our Website, App, or Services:

When you access or use the Website, App, or Services or transact business with us, we and our third-party partners may automatically collect information you provide to us, information about how you access and use the Services and information about the device you use to access the Services, including:

Device Identifiers: Identifiers, such as your IP address, Internet service provider (“ISP”), the type of mobile device you use, the temporary or persistent unique device identifiers (sometimes called UDID), and identifiers associated with browser cookies, web beacons and similar technologies we deploy on our Website, App, or Services;

Internet or Other Electronic Network Activity Information: We and our third-party partners may collect information about the devices and computers you use to access our Services, such as browser type, language, operating system, the referring web page, pages visited, and hyperlinks clicked. When you use our Services, we may collect usage information sent to us by your computer, mobile, or other access device that tells us how you are using the Website, App, or Services and other information about your internet activity (“Usage Information”), including the pages you visit, the links you click, the ads you view and click on, videos you watch, purchase information and your checkout process, your location when you access or interact with our Services, and other similar actions. We may also use third-party tools to collect Usage Information you provide to us or information about how you use the Service and may record your mouse movements, scrolling, clicks and keystroke activity on the Service and other browsing, search or purchasing behavior. These tools may also record Usage Information you enter when you interact with our Services or engage in chat features through our Services.

Commercial Information such as your purchase history, including records of products you have purchased or are considering purchasing from us, services you have provided or have had provided to you, such as transactional information when you make a purchase, we collect information about the transaction, such as services provided, product details, purchase price, and date and location of the transaction.

Geolocation Information. We may derive the approximate location of your device from your IP address. We may combine this information with other location-based information, such as your billing or postal code. You have the ability to stop the collection of precise location information at any time (see “Your Choices” below for details).

We (and our third-party partners and service providers) use different technologies to collect information, including cookies, embedded scripts, mobile SDKs, location-identifying technologies and web beacons. For reference, cookies are small data files stored on your hard drive or in device memory that help us improve our Services and your experience, see which areas and features of our Services are popular, and count visits and web beacons (also known as “pixel tags” or “clear GIFs”) are electronic images that may be used in our Services or emails and help deliver cookies, count visits, and understand usage and campaign effectiveness. For more information about cookies and how to disable them, see our Cookie Policy.

Information Collected from Third Parties:

We may also obtain information about you from other sources. For example, we may collect information about you from third parties, including but not limited to mailing list providers and publicly available sources. When you interact with our customers, their admins, online communities and other users on our Website, App or Services, we may collect from them any content or information you choose to share or provide. We may also obtain information about you from other sources, including but not limited to social media platforms, marketing partners, and other third parties. For example, if you connect your social media account to your Account or create or log into your Account through a social media site, certain information from your social media account will be shared with us, which may include information that is part of your profile or your friends’ profiles. In addition, we may supplement the information that you provide us and/or the information we collect from you with demographic, social, and other information about you that we receive from other sources. Once we combine information from other sources with your information collected pursuant to this policy, we apply this policy to the combined information as long as it is combined.

Information Usage

We use the information we collect about you for a variety of business and commercial purposes, including, but not limited to:

  • provide, maintain, and improve the Website, App, or Services and to enhance and personalize your experience;
  • process, complete, and maintain records on transactions;
  • provide our users, our customers and their admins, and the online communities with the Website, App or Services. Other users, our customers and their admins may use your personal information for their own purposes, such as to provide you with content, discussions, events and memberships;
  • send you technical notices, updates, security alerts, and support and administrative messages;
  • respond to your comments, questions, and requests, and to provide customer service;
  • communicate with you about products, services, offers, promotions, rewards, and events offered by Circle and others, and provide news and information we think will be of interest to you;
  • monitor and analyze trends, usage, effectiveness and activities in connection with our Website, App, or Services, including our offers, advertising, communications features, and customer service;
  • detect, investigate and prevent fraudulent transactions and other illegal activities and protect the rights and property of Circle;
  • facilitate contests, sweepstakes and promotions and process and deliver entries and rewards;
  • link or combine with information we get from our Website, App, or Services and from others to help understand your needs and provide you with better service;
  • maintain appropriate records for internal administrative purposes;
  • carry out any other purpose described to you at the time the information was collected or permitted by law.

Information Sharing

We may share information about you, including personal information, as follows or as otherwise described in this Privacy Policy.

With Service Providers or Customers. We may disclose your information to vendors, consultants and other service providers under contract who help with our business operations or who we provide services to (such as web hosting and operations of the App, IT, to process opt-out requests, to assist us in responding to consumer requests for access, deletion, or correction of information, direct mail and email distribution, site analytics, operations or legal and compliance services, and customers purchasing services from Circle). With your permission, we may also disclose your information to our customers.

With Data Analytics and Aggregation Vendors. We may share aggregated information that does not include your PII or PI, and we may otherwise disclose non-identifying information such as general (non-specific) geographic location, device/browser technology, onsite behavior, population data, user segmentation, survey results, and log data, with third parties for data analysis, demographic profiling, and other purposes. Any aggregated information shared in this manner will not contain your personal information.

With Other Users of the Website, App, or Services. If you provide or share information with other users on the Website, App or Services, they may use it for their own purposes. If you post information or content, such as by posting photos, commenting on a blog, or participating in online communities, or when you interact with the Website, App, or Services through social media sites, plug-ins or other applications, depending upon your privacy settings, this information may become public on the Internet. We cannot prevent further use of this information. You can control what data you share through privacy settings available on some social media sites. Please refer to those third-party sites’ privacy policies and terms of use to learn more about their privacy practices, which we do not control.

With Legal and Law Enforcement. We may share information collected about you with law enforcement, governmental agencies, or authorized third parties, in response to a verified request relating to a criminal investigation or alleged illegal activity or any other activity that may expose us, you, or any other Website, App, or Services user to legal liability or if we believe disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements.

In Connection with a Change of Control. We may transfer or disclose your information in connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company.

With your Consent. Where applicable, we may share your information with your consent or at your specific direction.

Children’s Privacy

Our App and Services are not intended for individuals under the age of 16. No one under the age of 16 is authorized to provide any personal information through the Website, App, or Services. We do not knowingly collect personal information from our Website, App, or Services from users in this age group. If we learn that we have collected or received personal information from a child under the age of 16, we will take reasonable steps to delete that information. If you believe we might have any information from or about a child under 16, please contact us at the email address below.


Social Sharing Features

The Website, App, or Services may offer social sharing features and other integrated tools, which let you share actions you take on our Website, App, or Services with other media, and vice versa. Your use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the entity that provides the social sharing feature. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of the entities that provide these features.

Links to Third-Party Sites

Our Website, App, or Services may contain links to other websites, including our affiliated or co-branded web sites. Other websites may also reference or link to our Website, App, or Services. These other websites may not be controlled by us. We encourage our users to read the privacy policies of every website or mobile application that collects PII or PI. We do not endorse, screen or approve, and are not responsible for the privacy practices or content of other websites or mobile applications. Visiting these other websites is at your own risk.

Advertising and Analytics Services Provided by Others

We may allow third-party partners and tools to provide analytics services and serve advertisements on our behalf across the Internet and in the Website, App, or Services. These partners may automatically collect Device Identifiers and Usage Information through technologies such as cookies and web beacons, including mouse clicks and movements, page scrolling and any text keyed into website forms and other browsing, search or purchasing behavior. These tools may also record information you enter when you interact with our Services and other websites and applications. This information may be used by Circle and our third-party partners to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our Website, App, or Services, and better understand your online activity. Please see our Cookie Policy for more information about these practices and any choices you may have regarding cookies.

We participate in interest-based advertising and use third-party advertising partners to serve you targeted advertisements based on your browsing history. Typically, though not always, the information used for interest-based advertising is collected through cookies or similar technologies. We may share a common account identifier (such as an email address or user ID) with our third-party advertising partners to help identify you across devices. We and our third-party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics and market research.

To learn about interest-based advertising and how you may be able to opt-out of some of this advertising, you may wish to visit the Network Advertising Initiative’s online resources, at http://www.networkadvertising.org/choices, and/or the DAA’s resources at http://www.aboutads.info/choices.

Transfer of Information to the U.S. from Other Countries

Circle is based in the United States and we may process and store information in the U.S. and other countries. Therefore, we and our service providers may transfer your information to, or store or access it in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction.

Your Choices

Account Information:

You may update and correct certain Account information you provide to us at any time by logging into your Account. If you wish to delete or deactivate your Account, you may email us at [email protected], but note that we may retain certain information as required by law or for legitimate business purposes. We may also retain cached or archived copies of information about you for a certain period of time.

Location Information:

If you initially consent to our collection of this location information through the Website, App, or Services, you can subsequently stop the collection of this information at any time by changing the preferences on your computer or device. If you do so, certain features may no longer function properly.

Cookies:

For more information about our and our third-party partners’ use of cookies and related technologies to collect information automatically, and any choices you may have in relation to cookies, please see our Cookie Policy.

Communications with Circle:

We want to communicate with you in ways you want to hear from us. Examples include email, which may contain special offers and new product announcements. To the extent that you are receiving marketing communications from the Website, App, or Services you may unsubscribe or opt-out of future communications as follows: If you no longer wish to receive emails you may click on the hyperlink titled “Unsubscribe” at the bottom of any marketing related email Circle sends to you, and then follow the directions to unsubscribe from email, or you can modify your preferences in your Account settings. Please note that if you opt out of receiving promotional communications from us, we may still send you transactional communications, including emails about your account or purchases.

Mobile Push Notifications/Alerts:

With your consent, we may send promotional and non-promotional push notifications or alerts to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device. By downloading and using our App, you may also receive promotional messages, offers, news and information about Circle. If you do not want to receive “in app” messages, offers, news and information, do not download or use our App.

Additional Notice to European Residents

If you are located in the European Economic Area (“EEA”), United Kingdom (“UK”) or Switzerland, or otherwise engage with our European operations, please see the European Privacy Policy for additional European-specific privacy information, including what constitutes your personal data, the lawful bases we rely on to process your personal data, how we use cookies when you access our Website from the EEA, UK or Switzerland, and your rights in respect of your personal data.

Additional Notice to Nevada Residents

If you are a resident of the state of Nevada in the United States, you have the right to opt out of the sale of your personal data. Although we do not currently sell personal data of Nevada residents (as defined under Nevada law), you may submit a request to opt-out of the sale of your personal data by [email protected].

Additional Notice to California Residents

California law requires we provide disclosures to you about what PI we collect by reference to the enumerated categories of PI set forth within California law. To address this obligation, we have identified the relevant enumerated California category for the PI described in the Information Collection section of our Privacy Policy above:

  • Identifiers, including name and email address.
  • User records, including password, email address, user ID.
  • Internet / network information, including information about your device, browser and network and information about how you use our service and interact with us.
  • Geolocation data, including general geographic information based on IP address.
  • Sensory information, including profile picture.
  • Professional / employment information, including the business or organization an individual represents, their title with that business or organization and information relating to their role with the business or organization, which we use to communicate with the individual about the business or organization they represent.
  • Sensitive personal data, including account log-in information in combination with any required security or access code, password or credentials allowing access to an account.
  • Other Personal Data, including communication preferences, inquiry information, personal information an individual permits us to see when interacting with us through social media, and personal information an individual provides us in relation to a question, request, inquiry, survey, contest or promotion.
  • Inferences, including our predictions about interests and preferences and related information from the Services.

We only use or disclose sensitive information for the following purposes, where such use or disclosure is necessary and proportionate for those purposes: for performing services you have requested, to comply with our legal and regulatory obligations, for detecting security incidents, fraud and other illegal actions, to ensure the safety of natural persons, to perform services on behalf of the business, or for solely internal purposes, consistent with our Privacy Policy and any other expectations we’ve set with you. We only collect and process sensitive information without the purpose of inferring characteristics about a consumer.

We do not sell any of your information, and we do not process or otherwise share sensitive information for the purpose of targeted advertising.

Information Usage. As described in the Information Usage section of our Privacy Policy, we use personal information for business and commercial purposes, such as fulfilling the purpose for which you provided the information, and to improve our Services and customer support.

Deidentified Information. We may at times receive, or process personal information to create, deidentified data that can no longer reasonably be used to infer information about, or otherwise be linked to, a particular individual or household. Where we maintain deidentified data, we will maintain and use the data in deidentified form and not attempt to reidentify the data except as required or permitted by law.

Information Sharing. In the previous 12 months, we have disclosed the following categories of personal information to third parties for a business purpose:

  • All of the categories of personal information we collect, explained above.

The categories of third parties to whom we disclose your personal information for a business purpose include those described in the Information Sharing section of our Privacy Policy

Sale and Sharing of Personal Information. As is common practice among companies that operate online, we do allow certain advertising networks, social media companies and other third-party businesses to collect and disclose your personal information directly from your browser or device through cookies and related technologies when you visit or interact with our websites and otherwise engage with us online. For example, they may collect Internet/Network information, such as a cookie or device ID, browsing history and website usage, geolocation data, and Inferences generated from your browsing history and interactions with our service as well as other sites and services.

These third parties use this personal information to serve relevant ads on other websites or mobile apps, or on other devices you may use, or to personalize content and perform other advertising-related services such as reporting, attribution, analytics and market research. These third-party businesses may use such information for their own purposes in accordance with their own privacy statements, which may include reselling this information to additional third parties, including other advertising networks. Please see the Advertising and Analytics Services Provided by Others section of our Privacy Policy for more information about how third parties use cookies and related technologies to collect information automatically on our websites and other online services, and the choices you may have in relation to those practices.

We do not sell the personal information any of our consumers or share the personal information of consumers we know to be less than 16 years of age.

Your Privacy Choices. If you are a California resident, subject to certain legal limitations and exceptions, you may be able to exercise some or all of the following rights:

The Right to Know

The right to confirm whether we are processing personal information about you and, under California law only, to obtain certain personalized details about the personal information we have collected about you, including: The categories of personal information collected; The categories of sources of the personal information; The purposes for which the personal information were collected; The categories of personal information disclosed to third parties (if any), and the categories of recipients to whom the personal information were disclosed; The categories of personal information shared for cross-context behavioral advertising purposes (if any), and the categories of recipients to whom the personal information were disclosed for those purposes.

The Right to Access & Portability

The right to obtain access to the personal information we have collected about you and, where required by law, the right to obtain a copy of the personal information in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance.

The Right to Correction

The right to correct inaccuracies in your personal information, taking into account the nature of the personal information and the purposes of the processing of the personal information.

The Right to Control Over Sensitive Information

The right to exercise control over our collection and processing of certain sensitive information.

The Right to Deletion

The right to have us delete the personal information we maintain about you.

The Right to Opt-Out of Sales or Sharing of Personal Information

The right to direct us not to “sell” your personal information to third parties for monetary or other valuable consideration, or “share” your personal information to third parties for cross-context behavioral advertising and targeted advertising purposes.

The Right to Control Over Automated Decision-Making / Profiling

The right to direct us not to use automated decision-making or profiling for certain purposes.


Non-Discrimination / Non-Retaliation. If you are a California resident, subject to certain legal limitations and exceptions, you may be able to exercise some or all of the following rights:

Note that in relation to Customer Data, we act as a “service provider” and have contractually committed ourselves to only process such information on behalf of and under the instruction of the respective customer. Please contact the respective customer to exercise your privacy rights with respect to Customer Data.

How to Exercise Your Privacy Rights. To exercise these privacy rights and choices, please follow the instructions below:

  • How to Request That We Identify or Provide You Access to Personal Information: You may request that we identify or provide you access to your personal information twice in a 12-month period. To do so, please email us at [email protected]. In response to a request to identify your personal information, we will identify to you (1) the categories of personal information we have collected, disclosed or sold about you in the last 12 months, (2) the categories of sources from which the personal information was collected, (3) the business purpose for which we use this information, and (4) the categories of third parties with whom we share or have shared your personal information in the last 12 months. In response to a request to access your personal information, we will produce an “Access Report” detailing the personal information we have collected and disclosed about you. This Access Report will be delivered electronically at your request.
  • How to Request Deletion of Personal Information: You may request that Circle delete the personal information it has collected and/or maintained about you. To do so, please email [email protected]. Note, we may need to retain certain personal information as permitted by law, such as to complete the transaction for which the personal information was collected, provide a requested good or service, detect security incidents, protect against malicious, deceptive, fraudulent or illegal activities, comply with legal obligations or to enable solely internal uses that are reasonably aligned with your expectations or lawful within the context in which you provided the information.
  • How to Opt-Out of the Sale or Sharing of Personal Information:
    • For Cookie-Based Sales & Targeted Advertising Opt-Outs: To exercise your right to opt-out as it relates to the use of cookies and other third-party tracking technologies and targeted ads, please reference our Cookie Policy.
    • For Non-Cookie-Based Opt-Outs: You may submit a request by emailing us at [email protected].
    • For App-Based Opt-Outs: You may download the DAA’s CCPA App-Based Opt-Out Tool, which opts out of data processing by third parties enrolled in the DAA’s program. Please note that this opt-out is device-specific and will not be effective on your visits to the services from other devices or through the website.

Verification. Please note, we will take steps to verify your identity before fulfilling any of the above requests. If you maintain an Account with us, we will verify your identity through existing authentication practices for the Account (e.g., login and password). If you are not a registered Website, App, or Services user, we will verify your identity by matching two or three data points that you provide with data points that we maintain and have determined to be reliable for the purposes of verification.

Authorized Agents. In certain circumstances, you may permit an authorized agent to submit requests on your behalf. The authorized agent must provide a letter signed by you confirming the agent has permission to submit a request on your behalf, or must provide sufficient evidence to show that the authorized agent has been lawfully vested with power of attorney.

Retention of Personal Information. We retain personal information only for as long as is reasonably necessary to fulfil the purpose for which it was collected. However, if necessary, we may retain personal information for longer periods of time, until set retention periods and deadlines expire, for instance where we are required to do so in accordance with legal, tax and accounting requirements set by a legislature, regulator or other government authority.

To determine the appropriate duration of the retention of personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of personal information and if we can attain our objectives by other means, as well as our legal, regulatory, tax, accounting and other applicable obligations.

Contact Us

If you have any questions, comments or concerns about our Privacy Policy, you may email us at [email protected]. Please do not email any confidential, sensitive or personal information to this email. Additionally, if you have any questions, comments or concerns about our Privacy Policy feel free to send correspondence to the following address:

CircleCo, Inc.
228 Park Ave S
PMB 52933
New York, NY 10003