Privacy Policy
Version 1.0 · Effective date: September 23, 2026 · Last updated: September 23, 2026
Legal review status: Pending counsel review
Table of contents
Review the current legal document content below.
Overview
Effective Date: September 23, 2026 Last Updated: September 23, 2026 Circlo ("Circlo," "we," "us," or "our") respects your privacy and is committed to protecting the personal information you provide when you use the Circlo platform, website, applications, products, and services (collectively, the "Services"). This Privacy Policy explains what information we collect, how we use it, how we share it, how we protect it, and the choices and rights available to you. By using Circlo, you acknowledge that you have read and understood this Privacy Policy. Who We Are Circlo is a technology platform designed to connect brands, creators, and other business users for collaboration, discovery, campaign management, communication, and related services. For privacy-related questions, requests, or concerns, you may contact us at privacy@circlo.com.
Information Collected
Effective Date: September 23, 2026 Last Updated: September 23, 2026 Circlo collects information directly from you, automatically from your use of the Services, and, where permitted by law, from third parties. Information you provide Depending on how you use Circlo, we may collect: Account information - Full name - Email address - Password or authentication credentials - Profile photograph - Username - Account type, including Brand or Creator - Country - City or general location - Account preferences - Communication preferences Creator information - Creator name - Biography - Niche and content categories - Social media usernames and profile URLs - Platform information - Hashtags - Audience information - Follower counts - Engagement information - Content categories - Languages - Location - Collaboration preferences - Portfolio information - Rates or pricing information where provided - Availability - Campaign history or collaboration information - Information voluntarily included in a creator profile Brand information - Company or brand name - Company description - Website - Industry - Location - Contact information - Campaign requirements - Target audience - Budget information - Marketing objectives - Social media accounts - Preferred creator characteristics - Campaign materials - Brand preferences Communications We may collect information contained in messages, campaign communications, support requests, feedback, reports, forms, and other communications you send through or to Circlo. Payment information When you subscribe to Circlo or participate in transactions, payment processing may be performed by Stripe. Circlo may receive information such as transaction identifiers, subscription status, payment status, currency, amount, billing information, and limited payment-method information. Circlo does not intend to store complete payment-card numbers on its own systems. Information collected automatically When you use Circlo, we may automatically collect: - IP address - Browser type and version - Device type - Operating system - Device identifiers - Approximate geographic location - Pages and screens viewed - Features used - Search activity - Login activity - Session information - Referring URLs - Date and time of activity - Error logs - Performance information - Security and fraud indicators Information from third parties Depending on the functionality you use, Circlo may receive information from: - Authentication providers such as Google - Social-media platforms - Payment providers - Analytics providers - Advertising platforms - Business partners - Other Circlo users The information we receive depends on the service, your settings, and the permissions you grant.
Cookies
Circlo uses cookies and similar technologies to operate, secure, analyze, and improve the Services. Cookies are small files or pieces of information stored on your browser or device. Essential cookies Some cookies are necessary for Circlo to function. These may be used to: - Maintain your login session - Authenticate your account - Protect accounts against unauthorized access - Maintain security - Remember essential preferences - Maintain shopping, subscription, or transaction sessions where applicable - Detect suspicious activity - Protect against fraud Because these technologies are necessary for providing requested functionality, they may operate even if optional cookies are disabled. Preference cookies Preference technologies may remember settings such as: - Language - Interface preferences - Display settings - Previously selected options - Other configuration preferences Analytics cookies Analytics technologies help us understand how users interact with Circlo, including: - Which pages are visited - Which features are used - How users navigate the platform - How long sessions last - Whether errors occur - Which features require improvement Marketing and advertising technologies Where used and where required by law, Circlo may use pixels, tags, SDKs, or similar technologies to measure advertising performance and understand how users interact with Circlo following an advertisement. Where required, Circlo will request consent before using non-essential cookies or similar technologies. You may control cookies through your browser settings and, where provided, Circlo's cookie-preference controls.
Analytics
Circlo may use analytics technologies to understand and improve the Services. Analytics information may include: - Pages visited - Features used - Search interactions - Button clicks - Account activity - Session duration - Device information - Browser information - Approximate location - Traffic sources - Error information - Performance information Analytics may help us: - Identify technical problems - Improve user experience - Understand which features are useful - Measure product performance - Monitor platform stability - Develop new features - Understand campaign and conversion performance - Detect unusual or potentially fraudulent activity Analytics information may be aggregated or de-identified where appropriate. Circlo may use third-party analytics providers to perform these services. Such providers may process information on our behalf or independently according to their own terms and privacy policies. Where analytics technologies constitute non-essential cookies or similar technologies under applicable law, we will obtain consent where required.
Stripe
Circlo uses Stripe for payment processing and related financial functionality. When you make a payment, subscribe to a Circlo plan, or participate in a transaction through Circlo, Stripe may collect and process information necessary to complete and secure the transaction. This may include: - Name - Email address - Billing address - Payment-card information - Bank or payment-account information where applicable - Transaction information - Currency - Amount - Subscription information - Fraud-prevention information - Device and technical information - Payment status Circlo does not intentionally store complete payment-card numbers or security codes on its own infrastructure. Stripe may act as a processor or controller depending on the particular processing activity. Stripe explains that it may operate in both capacities depending on the service being provided. Stripe may use information for purposes including: - Processing payments - Authentication - Fraud prevention - Security - Compliance - Providing Stripe services - Maintaining financial records Stripe maintains its own privacy practices and data-access mechanisms. You can review Stripe's current privacy documentation through its official Privacy Center. Your use of Circlo does not give Circlo control over Stripe's independent processing activities.
AI Processing
Circlo may provide artificial-intelligence-powered features. AI functionality may assist with: - Brand-creator matching - Search and recommendations - Creator discovery - Campaign discovery - Profile analysis - Match scoring - Outreach drafting - Campaign assistance - Content suggestions - Business insights - Platform assistance - Other AI-assisted functionality introduced by Circlo Information that may be processed Depending on the feature you use, AI systems may process information such as: - Profile information - Creator niche - Brand industry - Campaign requirements - Location - Hashtags - Audience characteristics - Public professional information - User preferences - Search queries - Campaign information - Information you deliberately submit to an AI feature - Content necessary to generate an AI response Circlo will use information submitted to an AI feature only as reasonably necessary to provide, secure, improve, or maintain that feature, subject to applicable law and the terms governing the particular service. AI-generated recommendations Circlo's AI systems may generate: - Recommendations - Match scores - Suggested creators - Suggested brands - Campaign suggestions - Outreach drafts - Summaries - Other generated content AI outputs may be inaccurate, incomplete, outdated, or unsuitable for a particular purpose. Users should independently review AI-generated information before relying upon it. Automated decisions Circlo may use automated processing to organize, rank, recommend, or score potential matches. These systems are intended primarily to assist users in discovering relevant opportunities rather than make legally binding decisions about users. Circlo does not intend to make decisions producing legal or similarly significant effects solely through automated processing where applicable law prohibits such processing without appropriate safeguards. Where applicable law provides a right to human intervention, explanation, objection, or review, Circlo will provide those rights. GDPR Article 22 provides specific protections concerning decisions based solely on automated processing that produce legal or similarly significant effects. AI providers Circlo may use third-party AI infrastructure to provide certain AI functionality. Where third-party AI providers process personal information on Circlo's behalf, Circlo will use appropriate contractual, technical, and organizational safeguards as required by applicable law.
Geolocation
Circlo may use location information to improve discovery, matching, search, recommendations, fraud prevention, and other platform functionality. Information that may be used Depending on your use of Circlo, location information may include: - Country - State, province, or region - City - General geographic area - IP-derived approximate location - Location voluntarily entered into your profile - Location information associated with connected services Circlo may use location information to help users discover relevant opportunities. For example, a brand may search for creators based in a particular country or region, while creators may discover brands or campaigns relevant to their location. Precise location Circlo does not require you to provide precise GPS coordinates merely to create an ordinary account unless a particular feature specifically requires it and you provide the necessary permission. If Circlo introduces a feature that requires precise geolocation, we will explain the purpose of that collection and request permission where required by law. You may be able to disable device-level location permissions through your device or browser settings. Location visibility Information displayed on a public or user-facing profile depends on the information you choose to provide and the functionality of your account. You should avoid publishing a precise residential address or other highly sensitive location information unless it is necessary for a particular Circlo transaction or service.
Data Storage
Circlo stores personal information using third-party infrastructure and technology providers. Circlo's infrastructure may include cloud database, authentication, storage, hosting, payment, email, analytics, and security providers. Depending on the Service architecture, personal information may be stored or processed in countries other than your country of residence. Circlo may use providers such as Supabase and other infrastructure providers to operate the platform. Security of stored information We use reasonable technical and organizational measures designed to protect stored information, including: - Access controls - Authentication - Encryption in transit - Appropriate encryption or protection for sensitive information - Role-based permissions - Database security controls - Logging - Monitoring - Backup and recovery measures where appropriate - Security incident procedures No online service can guarantee that information will be completely secure. International storage Because Circlo is designed to operate internationally, information may be processed in jurisdictions different from your own. Where applicable law requires safeguards for international transfers, Circlo will use legally recognized transfer mechanisms and appropriate contractual or organizational safeguards.
Data Sharing
Circlo does not sell your personal information as a data-broker business. We may disclose personal information when reasonably necessary to provide, secure, maintain, or improve the Services. Sharing between Circlo users Circlo is a marketplace platform. Certain information is intentionally made available to other users to enable the platform's core functionality. For example: Creators may make available to brands: - Name - Profile information - Niche - Location - Social-media information - Portfolio - Audience information - Professional information - Collaboration preferences Brands may make available to creators: - Brand name - Company information - Industry - Campaign information - Campaign requirements - Budget information where disclosed - Target audience - Public brand information The information visible to other users depends on account settings, product functionality, and information voluntarily submitted. Service providers We may share information with service providers that assist with: - Hosting - Databases - Authentication - Payments - Email - AI processing - Analytics - Security - Fraud detection - Customer support - Infrastructure - Error monitoring - Technical operations Service providers receive only information reasonably necessary for the service they provide, subject to applicable contractual and legal requirements. Legal disclosures We may disclose information when reasonably necessary to: - Comply with applicable law - Respond to valid legal process - Protect Circlo's rights - Protect users - Investigate fraud - Prevent abuse - Protect platform security - Enforce agreements - Establish or defend legal claims Corporate transactions If Circlo undergoes a merger, acquisition, financing, restructuring, sale of assets, bankruptcy, or similar transaction, personal information may be transferred as part of that transaction subject to applicable law. Aggregated and de-identified information Circlo may use and disclose information that has been aggregated or de-identified so that it cannot reasonably be used to identify an individual.
User Rights
Depending on your jurisdiction, you may have rights regarding your personal information. These may include: Access You may request information about whether Circlo processes your personal information and, where applicable, obtain a copy of that information. Correction You may request correction of inaccurate or incomplete personal information. Deletion You may request deletion of personal information, subject to legal and operational exceptions. Data portability Where applicable, you may request your information in a structured, commonly used, and machine-readable format. Restriction Where applicable, you may request that we restrict certain processing. Objection You may object to certain processing where the law provides such a right. Withdrawal of consent Where processing is based on consent, you may withdraw that consent. Withdrawal does not affect processing that occurred before withdrawal. Marketing You may unsubscribe from promotional emails at any time using the unsubscribe mechanism contained in the communication. Automated processing Where applicable law provides protections regarding automated decision-making or profiling, you may exercise those rights. To exercise a privacy right, contact: privacy@circlo.com We may request reasonable information to verify your identity before processing certain requests. We will not use identity-verification information for unrelated purposes.
GDPR
Where the General Data Protection Regulation ("GDPR") applies to Circlo's processing of your personal information, Circlo will process personal data in accordance with applicable GDPR requirements. The GDPR requires principles including lawfulness, fairness and transparency, purpose limitation, data minimization, accuracy, storage limitation, integrity/confidentiality, and accountability. Lawful bases Depending on the circumstances, Circlo may process personal information based on: - Performance of a contract - Compliance with a legal obligation - Consent - Legitimate interests - Protection of vital interests - Other lawful bases recognized by applicable law GDPR rights Subject to applicable exceptions, you may have the right to: - Access your personal data - Correct inaccurate personal data - Request deletion - Restrict processing - Object to processing - Receive portable data - Withdraw consent - Object to certain direct marketing - Request information concerning automated decision-making - Lodge a complaint with a competent supervisory authority The GDPR provides a right of access that includes information about processing purposes, categories of data, recipients, retention periods, and automated decision-making where applicable. International transfers If personal data is transferred outside the European Economic Area or another jurisdiction with transfer restrictions, Circlo will use an applicable lawful transfer mechanism where required. These may include: - Adequacy decisions - Standard Contractual Clauses - Other legally recognized safeguards Supervisory authority You may lodge a complaint with the data-protection supervisory authority in the jurisdiction where you live, work, or where you believe an infringement occurred.
POPIA
Where applicable, Circlo will process personal information in accordance with South Africa's Protection of Personal Information Act 4 of 2013 ("POPIA"). POPIA establishes requirements for the lawful processing of personal information and regulates, among other things, processing limitation, purpose specification, information quality, openness, security safeguards, data-subject participation, direct marketing, automated decision-making, and cross-border transfers. Rights under POPIA Subject to applicable exceptions, data subjects may have the right to: - Be notified that their personal information is being collected - Establish whether Circlo holds personal information about them - Request access to personal information - Request correction - Request deletion or destruction where appropriate - Object to processing on reasonable grounds - Object to direct marketing - Object to certain automated decision-making - Lodge a complaint with the South African Information Regulator - Exercise applicable civil remedies These rights are expressly recognized under POPIA's data-subject provisions. Security compromises Where required by POPIA, Circlo will take appropriate steps concerning unauthorized access or acquisition of personal information, including notification requirements applicable to security compromises. Cross-border transfers POPIA regulates certain transfers of personal information outside South Africa. Where POPIA applies, Circlo will use appropriate safeguards and comply with applicable requirements governing international transfers.
CCPA
If you are a California resident and Circlo is subject to the California Consumer Privacy Act, as amended by the California Privacy Rights Act ("CCPA"), you may have additional privacy rights. The CCPA provides qualifying California consumers rights including the right to know, delete, correct, opt out of sale or sharing, limit certain uses of sensitive personal information, and receive non-discriminatory treatment for exercising applicable rights. Categories of information Depending on your interaction with Circlo, categories of personal information we may collect include: - Identifiers - Contact information - Commercial information - Internet or network activity - Geolocation information - Professional information - Inferences derived from information - Account credentials - Transaction information - Profile information - Other categories of information described in this Privacy Policy Sources We may obtain personal information from: - You - Your device - Your browser - Your use of Circlo - Authentication providers - Payment providers - Connected social platforms - Other Circlo users - Service providers - Publicly available sources where permitted Purposes We may use personal information to: - Provide Services - Create and maintain accounts - Process payments - Provide matching and recommendations - Operate AI features - Communicate with users - Provide customer support - Maintain security - Detect fraud - Analyze and improve the Services - Measure marketing - Comply with legal obligations Sale and sharing Circlo does not operate as a business that sells personal information to data brokers for monetary consideration. If Circlo introduces practices that constitute "sale" or "sharing" under applicable California law, we will update this Privacy Policy and provide the disclosures and opt-out mechanisms required by law. California law specifically defines "sharing" in the relevant context to include certain disclosures for cross-context behavioral advertising. California requests California consumers may contact us to exercise applicable rights. Requests may be submitted to: privacy@circlo.com We may verify requests using information reasonably necessary to confirm identity. The CCPA generally permits businesses covered by the law to take up to 45 calendar days to respond to certain consumer requests, with a possible extension where permitted and properly communicated. Non-discrimination Circlo will not discriminate against a California consumer for exercising privacy rights provided by applicable law.
Data Retention
Circlo retains personal information only for as long as reasonably necessary for the purposes described in this Privacy Policy, unless a longer period is required or permitted by law. Retention periods depend on factors including: - The type of information - The reason the information was collected - Whether you maintain an active account - Whether information is necessary to provide Services - Legal obligations - Tax and accounting requirements - Fraud-prevention requirements - Dispute resolution - Security requirements - Enforcement of agreements - Legitimate business needs Account information We generally retain account information while your account remains active. After account deletion, we may retain limited information where reasonably necessary for: - Legal compliance - Fraud prevention - Security - Accounting - Tax obligations - Dispute resolution - Enforcement of legal rights Transaction information Transaction and payment-related information may be retained for the period necessary to satisfy financial, accounting, tax, fraud-prevention, and legal requirements. Communications Support and communication records may be retained for a reasonable period to provide customer service, investigate disputes, maintain security, and meet legal requirements. Backups Information deleted from active systems may remain temporarily in encrypted or otherwise protected backup systems until those backups are rotated or securely deleted according to our retention procedures.
Security
Circlo takes reasonable technical and organizational measures designed to protect personal information. Depending on the information and risks involved, our security measures may include: Encryption We use encryption in transit for communications between your device and Circlo's systems. Where appropriate, sensitive information is also protected through encryption or equivalent security mechanisms at rest. Authentication We use authentication mechanisms designed to prevent unauthorized account access. Depending on the functionality available, Circlo may support: - Password authentication - OAuth authentication - Multi-factor authentication - Session controls - Security notifications Access controls Access to personal information is restricted based on role, business necessity, and appropriate permissions. Monitoring We may monitor systems for: - Unauthorized access - Suspicious activity - Fraud - Abuse - Security incidents - Technical failures - Infrastructure security Circlo uses third-party infrastructure providers that maintain their own security programs and controls. We evaluate service providers based on the requirements relevant to the services they provide. Incident response If Circlo determines that a security incident has occurred, we will investigate the incident and take reasonable steps to contain, remediate, and prevent recurrence. Where applicable law requires notification to affected individuals, regulators, or other parties, Circlo will provide notification within the time and manner required by law. Your responsibility You are responsible for maintaining the confidentiality of your login credentials. You should: - Use a strong password - Avoid sharing your credentials - Enable multi-factor authentication where available - Log out of shared devices - Notify Circlo if you suspect unauthorized account activity No security system can guarantee absolute security.
Contact
If you have questions about this Privacy Policy, want to exercise a privacy right, or believe your personal information has been processed improperly, contact Circlo. Privacy Contact Email: privacy@circlo.com Website: https://www.circlo.com Privacy requests When submitting a privacy request, please provide enough information for us to understand your request and identify the relevant account or information. We may request additional information where reasonably necessary to verify your identity and protect against fraudulent requests. If you are making a request on behalf of another individual, we may require evidence that you are authorized to act on that person's behalf. Regulatory complaints Depending on your location, you may also have the right to lodge a complaint with the relevant data-protection authority. For example: - EU/EEA residents may contact their applicable data-protection supervisory authority. - South African data subjects may contact the Information Regulator. - California residents may have rights to submit complaints to the California Privacy Protection Agency or California Attorney General where applicable. Changes to This Privacy Policy Circlo may update this Privacy Policy as the Services, technologies, laws, or business practices change. When we update this Privacy Policy, we will update the "Last Updated" date. If we make material changes, we may provide additional notice through the Services, email, or another appropriate method where required by law. Your continued use of Circlo after an updated Privacy Policy becomes effective will be subject to the updated policy, to the extent permitted by applicable law. Last Updated: September 23, 2026