Circl App, Inc.
Privacy Policy
Last Updated: October 13, 2022
1. Introduction
Circl App, Inc. ("Circl App, "we," "us," or "our") respects the privacy of its Users ("User," "your," or "you"). This Privacy Policy (the "Privacy Policy") explains how we collect, use, disclose, and safeguard your information when you use the Circl App website at https://circlapp.io/ (the "Website") and our mobile application (the "App").
Circl App is committed to protecting the privacy of its Users whose information is collected and stored while using our Website or App.
The capitalized terms have the same meaning as ascribed in our Terms of Use as applicable, unless otherwise noted here.
PLEASE READ THIS PRIVACY POLICY CAREFULLY TO UNDERSTAND OUR POLICIES AND PRACTICES REGARDING YOUR INFORMATION AND HOW WE WILL TREAT IT. BY ACCESSING OR USING OUR WEBSITE AND APP, YOU AGREE TO ACCEPT ALL THE TERMS CONTAINED IN THIS PRIVACY POLICY AND ACKNOWLEDGE AND AGREE WITH THE PRACTICES DESCRIBED HEREIN. IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY, PLEASE DO NOT ACCESS AND USE OUR WEBSITE AND APP.
IF YOU HAVE ANY QUESTIONS REGARDING THIS PRIVACY POLICY, PLEASE SEND US AN EMAIL AT PRIVACY@CIRCLAPP.IO.
WE DO NOT SELL YOUR PERSONAL INFORMATION, NOR DO WE INTEND TO DO SO. WE DO NOT GIVE ACCESS TO YOUR PERSONAL INFORMATION TO THIRD PARTIES EXCEPT TO SUBPROCESSORS TO ASSIST US IN THE PROVISION OF OUR SERVICES TO YOU.
2. What Information Do We Collect?
When you register to use our Website or App, we collect personal information (also referred to as personally identifiable information or "PII") which may include your name, online contact information such as your email address or username, phone number, IP address, browsing history, and other personal information like a photograph, audio file, or video file. The information so collected will be stored on our servers. You are able to change your personal information via email by contacting us at privacy@circlapp.io or through your profile or account settings on our Website or App.
- Geolocation and Equipment Information. We may collect information that does not personally identify you such as (i) your geolocation, and (ii) information about your internet connection, the equipment you use to access our Website or App, and usage details.
- Google Calendar Data. Circl App can and may use your Google Calendar data given your permission. Circl App use and transfer to any other app of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.
3. How Do We Collect Information?
We collect personal information from you in the following ways:
- At registration on our Website or App.
- In email, text, and other electronic messages between you and our Website or App.
- Through mobile and desktop applications you download from our Website or App, which provides dedicated non-browser-based interaction between you and our Website or App;
- When you interact with our advertising and applications on third-party website and services, if those applications or advertising include a link to this Privacy Policy;
- Responding to a survey;
- From forms filled out by you;
- From records or copies of correspondences (including email addresses) if you contact us;
- From search queries on our Website; and
- When you post information to be published or displayed on our Website or App.
We collect information from you automatically when you navigate through our Website or App in the following ways:
- Usage details;
- IP addresses;
- Information obtained through browser cookie;
- Information obtained through flash cookies;
- Web beacons on our Website or App; and
- Web beacons on emails sent by us.
4. How Do We Use Your Information?
We use the information that you provide to:
- Personalize your experience in using our App;
- Provide you with information, products, or services requested from us;
- Present our Website and App and their contents to you;
- Carry out obligations and enforce rights arising from contracts entered into between you and us, including billing and collection;
- Notify you about changes to our Website and App and any products or services;
- Allow you to participate in interactive features on our Website and App;
- Improve the Website and App;
- Improve customer service;
- Process transactions;
- Anonymize data and aggregate data for statistics;
- Contact you about our products and services that may be of interest;
- Contact you about third parties' goods and services; and
- Enable the display of advertisements to our advertisers' target audiences, although personal information is not shared with advertisers without your consent.
5. Our Cookie Policy
Cookies are small pieces of text used to store information on web browsers. Cookies are used to store and receive identifiers and other information on computers, phones, and other devices. Other technologies, including data we store on your web browser or device, identifiers associated with your device, and other software, are used for similar purposes. In this Privacy Policy, we refer to all of these technologies as "Cookies."
We use Cookies on our Website to (a) understand and save your preferences for future visits, (b) keep track of advertisements, (c) compile aggregate data about site traffic and site interactions in order to offer better site experiences and tools in the future; and (d) allow trusted third-party services that track this information on our behalf. You can set your browser to refuse all or some browser Cookies, but it may affect your user experience. We honor Do Not Track signals and, if one is in place, we will not track, plant cookies, or use advertising.
We allow third party behavioral tracking and links to third-party web pages. Occasionally, at our discretion, we may include or offer third-party products or services on our Website or App. These third-party sites have separate and independent privacy policies. We, therefore, have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our Website or App and welcome any feedback at about these sites. We may sell or otherwise give personal information that we keep on our visitors, users, and/or clients to third parties. Please contact us at privacy@circlapp.io.
6. How Do We Protect Information We Collect?
We actively prevent third parties from getting access to your personal information that we store and/or process on our App and servers.
7. Data Security Measures.
- Security Measures. We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website or App, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website or App. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on our Website or App.
- Fair Information Practice Principles. In the event of a personal data breach, we will notify you within twenty-four (24) hours via (i) email and/or (ii) our notification system on our Website or App and/or (iii) notify the FTC, FCC, and/or state regulatory agency. We agree to the individual redress principle, which requires that individuals have a right to pursue legally enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that that individuals have recourse to courts or a government agency to investigate and/or prosecute non-compliance by data processors.
8. Disclosure Of Personal Information
There are times when we may share Personal Information that you have shared with us may be shared by Circl App with others to enable us to provide you over Services, including contractors, service providers, and third parties ("Partners"). This section discusses only how Circl App may share such information with Partners. We will ensure that our Partners protect your Personal Information. The following describe how and with whom we may share your Personal Information:
Disclosure of Personal Information.
- We may disclose aggregated, de-personalized information about you that does not identify any individual to other parties without restriction, such as for marketing, advertising, or other uses.
- We may disclose personal information to our subsidiaries and affiliates.
- We may disclose personal information to contractors, services providers, and other third parties.
- We require all contractors, service providers, and other third parties to whom we disclose your personal information to be under contractual obligations to keep personal information confidential and to use it only for the purposes for which we disclose them.
- We may disclose personal information in the event of a merger, sale of business, etc.
- We may disclose to third parties to market their products and services to you if you have either consented or not opted out of these disclosures.
- We require all other Partners, to whom we disclose your personal information, to enter into contracts with us to keep personal information confidential and use it only for the purposes for which we disclose it to such Partners.
- We disclose personal information to fulfill the purpose for which you have provided it, for instance, if you gave us an email address to use the "email a friend" feature of the App.
- We may disclose personal information for any other purpose for which you have provided it.
- We may only disclose personal information as described in this Privacy Policy or your consent.
Other Disclosure of Personal Information.
- We will disclose personal information (i) to comply with any court order, law, or legal process, including to respond to any government or regulatory request, (ii) to enforce or apply our Terms of Use and other agreements, including for billing and collection purposes, (iii) if we believe it is necessary or appropriate to protect the rights, property, or safety of Circl App, our customers or others, and/or (iv) if it is necessary or appropriate to protect the rights, property, or safety of Circl App, our customers, or others, and this includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
Third Party Disclosure.
- We do not provide non-personally identifiable visitor information for marketing, advertising, or other purposes.
Choices Users Have About How Circl App Uses and Discloses Information
- Disclosure of Users' Information for Third-Party Advertising. Users can opt-out by emailing us their opt-out request at privacy@circlapp.io. Users receiving promotional email can opt-out by sending a return email requesting to be omitted from future promotional email distributions. This opt-out will not apply to information provided by Circl App for product purchases, warranty registration, or other transactions.
- Disclosure of User's Information for Targeted Advertising. Users can opt-out by emailing us their opt-out request at privacy@circlapp.io.
9. COPPA Compliance (For Children Under 13 Users Only)
The Children's Online Privacy Protection Act ("COPPA") is a federal legislation that applies to entities that collect and store "Personal Information," as the term is defined under COPPA, from children under the age of 13. We are committed to ensure compliance with COPPA. Our Website and App are not meant for use by children under the age of 13. Our Website and App do not target children under the age of 13, but we do not age-screen or otherwise prevent the collection, use, and personal disclosure of persons identified as under 13. If you would like to know more about our practices and specifically our practices in relation to COPPA compliance, please email us at privacy@circlapp.io.
IF YOU ARE UNDER 13, PLEASE DO NOT ACCESS OR USE OUR WEBSITE OR APP.
10. CAN-SPAM Act of 2003
The CAN-SPAM Act establishes requirements for commercial messages, gives recipients the right to have businesses stop emailing them, and spells out penalties for violations. Per the CAN-SPAM Act, we will:
- not use false or misleading subjects or email addresses;
- identify the email message as an advertisement in some reasonable way;
- include the physical address of Circl App, Inc. which is 10629 Hardin Valley Road #179, Knoxville, TN 37932
- monitor third-party email marketing services for compliance, if one is used;
- honor opt-out/unsubscribe requests quickly; and
- give an "opt-out" or "unsubscribe" option.
If you wish to opt out of email marketing, follow the instructions at the bottom of each email or contact us at privacy@circlapp.io and we will promptly remove you from all future marketing correspondences.
11. Modifications to Our Privacy Policy
Circl App reserves the right, at its sole discretion, to change or modify this Privacy Policy at any time. In the event we modify this Privacy Policy, such modifications shall be binding on you only upon your acceptance of the modified Privacy Policy. We will inform you about the modifications on our Privacy Policy page by posting a modified version of the Privacy Policy page, or by a comparable means within a reasonable time period. Your continued use of our Website or App shall constitute your consent to such changes.
12. Copyright Infringement/DMCA Notice
If you believe that any content on our Website or App violates your copyright, and you wish to have the allegedly infringing material removed, the following information in the form of a written notification (pursuant to the Digital Millennium Copyright Act of 1998 ("DMCA Takedown Notice")) must be provided to our designated Copyright Agent.
- Your physical or electronic signature;
- Identification of the copyrighted work(s) that you claim to have been infringed;
- Identification of the material on our Website or App that you claim is infringing and that you request us to remove;
- Sufficient information to permit us to locate such material;
- Your address, telephone number, and email address;
- A statement that you have a good faith belief that use of the objectionable material is not authorized by the copyright owner, its agent, or under the law; and
- A statement that the information in the notification is accurate, and under penalty of perjury, that you are either the owner of the copyright that has allegedly been infringed or that you are authorized to act on behalf of the copyright owner.
Circl App's Copyright Agent to receive DMCA Takedown Notices is Designated Copyright Agent, at support@circlapp.io and at Circl App, Inc. Attn: DMCA Notice, 10629 Hardin Valley Road #179, Knoxville, TN 37932. You acknowledge that for us to be authorized to take down any content, your DMCA Takedown Notice must comply with all the requirements of this Section. Please note that, pursuant to 17 U.S.C. ยง 512(f), any misrepresentation of material fact (falsities) in a written notification automatically subjects the complaining party to liability for any damages, costs and attorney's fees incurred by Circl App in connection with the written notification and allegation of copyright infringement.
13. Contact Us
To ask questions or comment about this Privacy Policy and our privacy practices, contact us at:
- Email: support@circlapp.io
- Address: 10629 Hardin Valley Road #179, Knoxville, TN 37932.
PLEASE NOTE: IF YOU USE OUR WEBSITE OR APP, YOU HAVE AGREED TO AND ACCEPTED THE PRACTICES DESCRIBED IN THIS PRIVACY POLICY AND THE TERMS AND CONDITIONS SET FORTH IN OUR Terms of Use, AS APPLICABLE. IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY OR OUR TERMS OF SERVICE, PLEASE DO NOT USE OUR WEBSITE OR APP.