Privacy Policy

Circo Tech LLC (“Circo,” “we,” “our,” or “us”) is committed to protecting the privacy of individuals who use our website, mobile applications, Dashboard, Exchange feature, products, and related services (collectively, the “Services”). This Privacy Policy describes the types of information we collect, how we use it, with whom we share it, and the choices you have regarding our processing of your personal information.

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By accessing or using the Services, you acknowledge that you have read, understood, and agreed to the terms of this Privacy Policy. If you do not agree, please discontinue the use of our Services immediately.

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We may in the course of providing our services to you be required to collect your personal information.

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Unless indicated otherwise, this Privacy Policy does not apply to third party products or services or the practices of companies that we do not own or control, including other companies you might interact with on or through our services.

As a global business, we also comply with various jurisdiction-specific privacy provisions outlined in this Privacy Policy.

 

What information is covered under this policy?

This Privacy Policy covers your personal information. Personal information is information or an opinion, whether true or not, and whether recorded in a material form or not, about an identified individual, or an individual who is reasonably identifiable. All personal information received in connection with our business is subject to strict rules of confidentiality.

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Common examples include your name, username, password, IP address, unique device identifiers, gender, signature, address, telephone number, email, date of birth, bank account and digital wallet details, billing and credit or debit card details, photos and videos of you, other identification credentials and biographical details, and commentary or opinions about you.

 

Information We May Collect From You

A. Information You Provide Directly

When you interact with our Services, you may provide us with:

• Account Registration Data: Name, email address, phone number, password, and other identifiers you choose to provide.

• Profile Content: Photos, links, or other content you upload to customize your Circo digital business card or profile.

• Payment Information: Payment card details are processed by trusted third-party payment processors; Circo does not directly store full payment card numbers.

• Support Communications: Information you provide when contacting our support team.

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B. Information Collected Automatically

When you use our Services, we automatically collect certain information, including:

• Device and browser type, operating system, IP address.

• Usage data such as access dates and times, clickstream data, and session analytics.

• Location data, if you choose to enable location services.

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C. Information from Third-Party Sources

We may receive limited data from third parties, including CRM integrations or analytics providers, to improve our Services, always in accordance with applicable privacy laws.

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Use of Information

You consent to the disclosure of your personal information to any of our related entities.

You consent to our collection of your personal information and disclosing it to third parties where necessary and for the purposes for which it was collected.

This may include:

• Provide, maintain, and improve our Services.

• Facilitate networking features and profile sharing at your direction.

• Analyzing the usage of, and improve our services.

• For consumer engagement and/or customer service purposes, including but not limited to identifying the effectiveness of advertising, allowing you to participate on website viral features such as sharing website content and other community features (for example, blogs)

• Process payments and manage your subscriptions.

• Using your personal information for marketing purposes to provide or offer services to you. This includes, but is not limited to, keeping you up to date with our latest news, events, special offers and promotion of our brand or other similar products that we think that you may be interested in. This includes both our direct marketing to you or another third party whom you have authorized us to disclose your personal information to.

• Notifying you about any changes to our products, website, App and/or other software and/or mobile applications, brand or services offered.

• Seeking your opinion and feedback on any of our services, including for the purposes of product improvement and customization, website/software improvement and personalization and other general services

• Detect, prevent, and investigate fraud or abuse.

• Comply with legal and regulatory obligations.

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Certain of your personal data may be shared with other players of the App as part of the normal operation of our services (such as email marketing service). Additionally, we may, from time to time, expand or withdraw our business which may involve the transfer of certain of our divisions or assets to other parties, and the data we store and use, where relevant, may be transferred to such third parties. 

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How personal information is collected

"Personal information" is data that identifies, relates to, describes, can be used to contact, or could reasonably be linked directly or indirectly to you. For the purposes of this Privacy Policy, there is no meaningful distinction between the terms "personal information" and "personal data".

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You may choose not to provide some of the personal information described above. Please note, however, that some of our services require some personal information to operate, so if you choose not to provide the personal information necessary to operate and provide you with a particular service or feature of that service, you may not be able to use that service or feature.

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Information that you give us

We may collect your personal information directly from our contact with you. This may include by you completing forms or parts of our Website, Social Media, App and/or other software and/or mobile applications, by you providing us with consent to access personal information such as photographs, videos or photo albums, by you providing us with consent to access the microphone and/or camera on your device, or by you contacting us via the email, telephone, through Social Media and other similar functions either directly through our website or the App or through third party host websites, in person, through various marketing channels or competitions either directly through our website or the App or through third party host websites, and surveys.

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You understand that any personal information that you provide to us must be accurate and up to date. We will assume this to be the case.

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Information that we collect about you

In this Privacy Policy "Social Media" means social media networking sites of any kind or nature including but not limited to web or internet based or mobile telephonic devices or medium such as facebook, twitter, Instagram and LinkedIn which enable the creation and exchange of user generated content.

Our website, Social Media, App and/or other software and/or mobile applications may automatically collect the following information about you each time you visit or otherwise use our website, Social Media, App and/or other software and/or mobile applications:

1. Technical information including but not limited to the Internet Protocol Address used to connect your device to the internet, the internet browser and version that you are using when accessing our website, Social Media, App or other software and/or mobile applications, any additional plug-ins that you are using, and your device's operating system and platform; and

2. Information about the time and date you accessed our website, Social Media, App or other software and/or mobile applications, and what you accessed on our website, Social Media, App or other software and/or mobile applications. This includes links that you clicked on, what content you accessed, how long you accessed that content for, whether you downloaded any content, whether supplied by us or downloaded from a third party host, and how you navigated to and from our website, Social Media, App or other software and/or mobile applications to other sites, apps or other pages hosted by us.

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What and how we store your personal information

We maintain commercially reasonable technical, administrative, and physical security measures designed to protect your information from loss, misuse, unauthorized access, disclosure, alteration, and destruction.

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When your credit or debit card account, financial account, or digital wallet information is being transmitted to our services or through our services, it will be protected by cryptographic protocols. To be clear, we do not ourselves store your credit or debit card account information, and we do not have direct control over or responsibility for your credit or debit card account information. We may use third-party payment processors that are the controllers of your information. Our contracts with these third parties require them to keep your information secure and confidential.

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In addition, contact information exchanged through the Circo Exchange feature is stored on our servers in encrypted form. Circo does not use, access, or process this information for any purpose other than to facilitate the requested exchange between users. This data remains fully encrypted and inaccessible to Circo’s team and is never used for marketing, analytics, or other secondary purposes.

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Similarly, digital business card profile information, which includes the data you choose to display on your Circo digital business card, is also stored securely and encrypted. Circo does not use or process this information beyond providing the core Services and ensuring that your profile functions as intended.

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However, no method of data transmission or storage can be guaranteed as completely secure. While we employ strict procedures and security measures, we cannot guarantee that transmissions of your information will always be secure or that unauthorized third parties will never be able to defeat these measures. Except to the extent that liability cannot be excluded or limited due to applicable law, we assume no liability or responsibility for disclosure of your information due to errors in transmission, unauthorized third-party access, or other causes beyond our control.

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We will only keep your information for as long as reasonably necessary to fulfill the purposes for which your personal information was originally collected. We will delete your information after a reasonable time. You may be required to re-enter your personal information if it has been deleted.

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We take all reasonable steps and precautions to ensure that any transmission of your personal information via the internet is secure. However, we cannot guarantee the security of any data transmitted to our website, and you agree and acknowledge that such transmissions are at your own risk. Once we receive your information, we take reasonable steps to protect it. This includes storing any information on secure servers and employing strict procedures and security features to protect your personal information from any unauthorized recipients.

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All employees with access to your information are bound by strict confidentiality obligations as outlined in this Privacy Policy.

 

Legal obligations to disclose

We may be required to disclose your personal information for the purposes for which it was collected and also subject to our legal obligations:

1. As required by law;

2. To any person where necessary or desirable in connection with our provision of services; and

3. On a confidential basis to our external service providers and advisors.

 

To be clear, you consent to our disclosure of your personal information to any of our business partners, suppliers, subcontractors or the like, advertisers and other advertising networks, analytics and search engine providers and other third parties provided the disclosure of your personal information is for the purpose or ancillary to the services that we or these third parties offer you and for the purposes the information was originally collected.

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We may share your information with other third party business partners for their own marketing purposes. These third parties include online advertisers or ad tech companies, who may provide you with targeted advertising and marketing communications, where permitted under law. The information we share includes information collected through your use of our services and information we collect about you through the use of cookies and similar technologies.

You understand that we are authorized to disclose your personal information to third parties if we buy or sell any business or assets, including our business, if we are under a duty to disclose your information, or if the disclosure of your personal information is necessary for us to conduct an investigation into any unlawful activity that we know or suspect has or may be engaged in.

 

Collections of your information using cookies and other tracking technologies

Our website and/or App and/or other mobile applications use "cookies". Cookies are small pieces of data sent from a website and stored in your web browser. These pieces of data will allow our website and/or App and/or other mobile applications to remember who you are and to obtain information from you which allows us to deliver you a better and more customized service.

As a result of our website and/or App and/or other mobile applications' use of cookies, we may collect information such as your IP address, online activity and your web browser details. Information that we will not collect or store includes your passwords or other sensitive information.

We will use both persistent cookies, which could remain on your device until their expiration (which can be, in some cases, up to 10 years), and session cookies, which are temporary files removed from your device once your browser is closed.

The types of cookies we may use include analytical and tracking cookies, which allow us to recognize and count the number of visitors and analyze use of the services, as well as to verify transactions, and advertising and retargeting cookies, which allow us to generate appropriate advertising directed to you on our website as well as on the App.

If you enable cookies when accessing our website and/or App and/or other mobile applications, we will take this as consent to our use of cookies and other technologies mentioned in our Privacy Policy.

Please note that you should also refer to our website's Terms of Use for further information on this issue.

 

Your rights

You have the right to request access to the personal information we hold about you by contacting us or our support department by emailing support@getcirco.com.

 

If we cannot provide you with access, we will write to you and provide you with the reasons why we are unable to provide you with access.

If any personal information that we hold about you is inaccurate, incomplete or not up to date, you may write to us or our Privacy Officer and request that we correct the information at the above address.

You have the right to request that we do not disclose your personal information (for example, for marketing purposes). You can exercise your rights by unchecking the relevant check boxes on our website and/or App and/or other mobile applications when you provide us with your personal information, or by writing to us at the above address.

You may choose to opt out of receiving any further correspondence from us by writing to us at the above address or emailing us at the above email address.

 

Complaints

If you are concerned about a possible interference with your privacy or about the potential misuse of your personal information, please contact us at the above email address.

We take all complaints very seriously. It is our policy to handle complaints in a timely, effective, fair and consistent manner.