Circle Privacy Policy

This Privacy Policy was updated on, and its effective date is: 31 March 2021

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”),, or our Circle Web Application (“App”) and other online products or services that link to this Privacy Policy (collectively, the “Services”) through the Website or the App. 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.

By using the Website, App, or Services or by otherwise interacting with them, you assent to this Privacy Policy.

If you do not assent to this Privacy Policy, do not use the Website, App, or Services or otherwise interact with or submit personally identifiable information (“PII”) or personal information (“PI”) to the Website, App, or Services.

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 may 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. Your continued use of the Website, App, or Services following the posting of any changes to this policy verifies that you accept such changes.

Information Collection

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 it is reasonably associated with you. It does not include transactional data related to purchases at or through the Website, App, or Services, unless we combine such transactional data with your PII or PI, which we may do. We also collect, use, and disclose aggregated or deidentified data that does not identify you or your device.

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 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.

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 may automatically collect information about you, including:

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 may collect information about the devices and computers you use to access our Website, App, or Services, such as browser type, language, operating system, the referring web page, pages visited, and hyperlinks clicked. When you use our Website, App, or 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”).

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).

Information Collected by Cookies and Other Tracking Technology:

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 identity verification services, credit bureaus, mailing list providers, and publicly available sources. We may also obtain information about you from other sources, including but not limited to joint marketing partners, social media platforms, people with whom you are friends or otherwise connected to on social media platforms, 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 Collected by Cookies and Other Tracking Technology:

We (and our third-party partners and service providers) use different technologies to collect information, including cookies and web beacons. Cookies are small data files stored on your hard drive or in device memory that help us improve our Website, App, or Services and your experience, see which areas and features of our Website, App, or Services are popular, and count visits. Web beacons (also known as “pixel tags” or “clear GIFs”) are electronic images that may be used in our Website, App, or 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 Your Choices below.

“Do Not Sell” Opt-Out: Neither we nor our partners sell, share, or rent your personal information in any way.

Information Usage

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

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

With the Circle Corporate Family. We may share the information we collect about you between and among our current and future parents, affiliates, subsidiaries, and other companies under common control and ownership.

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 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 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. 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 others to provide analytics services and serve advertisements on our behalf across the Internet and in the Website, App, or Services. These entities may use cookies, web beacons, device identifiers and other technologies to collect information about your use of the Website, App, or Services and other websites and applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in apps, links clicked, and conversion information. This information may be used by Circle and others 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.

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.

Additional Notice to European Union Residents

If Circle holds any information about you and the European Union’s General Data Protection Regulation (“GDPR”) applies to you, you have the right to (a) request information about how Circle processes your information; (b) request a copy of your personal data that Circle holds; (c) request a correction to your personal data that Circle holds; (d) object to the ways Circle processes your information; (e) request that Circle erase your information from its business records if there is no longer a legal or business need for Circle to maintain a copy; (f) request that Circle limit the ways it processes your information in certain circumstances; or (g) opt out of allowing Circle to use your information for one of the purposes described in this Privacy Policy. To exercise any of your applicable rights under the GPDR, please email us at

Additional Notice to California Residents

In accordance with the California Consumer Privacy Act (the “CCPA”), the following table summarizes our personal information collection, use, and sharing practices in the preceding twelve (12) months since we last updated this Privacy Policy.

Personal Identifiers & Contact Information

Internet Activity & Technical Data

Geolocation Data

Financial Data

Transaction Data

Profile Data

Usage Data

Marketing and Communications Data

Sale of Personal Information:

We do not sell your information. We and our business partners may use tracking technologies to help us to understand our customers and users of the Website, App, or Services, to enhance your online experience, and customize our offerings in ways that may be deemed a “sale” of personal information under the applicable law.

We do not knowingly sell or otherwise disclose the PII or PI of minors under 16.

Choices for Access, Deletion, Opt-Out of Sale, and Right to Non-Discrimination for California Residents or As Required by Law:

If you are a California resident, you have the right to know what personal information we collect, disclose, and “sell” about you (as that term is defined in the CCPA). Additionally, you have the right to access, delete and opt out from the “sale” of your personal information.

Your Rights:
  1. Right to Know. The right to request, up to 2 times in a 12-month period, that we 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;
  2. Right to Access. The right to request, up to 2 times in a 12-month period, that we provide you access to or disclose to you, free of charge, the specific pieces of personal information we have collected about you in the last 12 months;
  3. Right to Delete. The right to request, up to 2 times in a 12-month period, that we delete personal information that we collected from you, subject to certain exceptions;
  4. Right to Opt-Out. The right to opt-out of the sale of your personal information to third parties (Note: we do NOT sell your personal information to third parties.);
  5. The right to designate an authorized agent to submit one of the above requests on your behalf; and
  6. The right to not be discriminated against in receiving different or less favorable pricing, service or financial incentive for exercising any of the above rights.

To exercise these privacy rights and choices, please follow the instructions below:


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.

Do Not Track Signals:

The Website, App, and Services do not respond to Do Not Track (“DNT”) signals to the extent received from a web browser. Because Circle is not aware of a universally accepted technological or legal standard for recognizing or honoring DNT signals as reflections of user choice, we do not respond to them at this time.

Consumers with Disabilities:

This policy is in a form that is accessible to consumers with disabilities.

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, 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.


Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Website, App, or Services.

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.

Contact Us

If you have any questions, comments or concerns about our Privacy Policy, you may email us at 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.
411 Lafayette Street
6th Floor
New York, NY 10003