Privacy

General Privacy Issues and Circle Privacy Policies

Effective date: July 8, 2019

Welcome to Circle, provided and maintained by Circle Media Labs, Inc., (referred to hereinafter as, “Circle,” or “Company,” or “We,” or “Us,” or “Our”), a service that provides individuals and families with a means of managing the internet activity on devices of family members, visitors, and others within their home network (“Network”) through Our website located at https://meetcircle.com (“Site”), Our Circle application (“App”), and related device and products (“Products” or “Device”) (collectively referred to as “Circle Services”).

Please read this document carefully because this Privacy Policy (“Policy”), along with Our Terms of Use, incorporated by reference, describe the legally binding agreement between You (referred to hereinafter as, “You,” or “User,” or “Your”, or “Visitor”) and Us.

This Privacy Policy has been developed by Circle to describe Our intended use of any of Your Data, navigational data, personal or sensitive information acquired, stored and/or maintained through Your use of Circle Service’s including the Site, App and/or Products. This Policy applies to all data, including navigational data, Personal Data, and sensitive data collected by Circle from Users. It also describes Your choices regarding use, access, rights and correction of Your personal information. If You do not agree with the data practices described in this Privacy Policy, You shall not use any of the Circle Services.

You acknowledge and agree that Your access and use of the Circle Services, and acceptance of the Privacy Policy herein, are subject to Our respective Terms of Use and End User License Agreement, incorporated herein by reference.

By accessing the Circle Services, You agree to comply with this Policy, and that Your visit and use of the Circle Services, and any dispute directly arising out of Your use or misuse, shall be governed by this Policy. We may modify the terms of this Policy (including Our Terms of Use and End User License Agreement located at https://meetcircle.com/legal) at any time at Our sole discretion, by posting amended terms to this Policy to the Site. If We believe a change to the Policy materially affects You, We will send You an email, notifying You of the change made to this Policy.

Your continued use of the Circle Services thereafter shall constitute immediate acceptance of all revised, modified and/or amended terms to this Policy. However, You should review the most up-to-date version of the Policy from time-to-time on the Site. We will notify You of any material changes, amendments or modifications to the Policy through the Site, or through other communication. In the event You choose not to agree and accept the new, modified or amended Terms, You shall cease use of all the Circle Services and provide Us with written notice.

Nothing in this Policy shall be deemed to confer any third-party rights or benefits. Additional terms may apply to certain Circle Services and Products, and those additional terms shall become part of Your agreement with Us if You use those Services and/or Products. Our partners, affiliates, vendors, manufacturers, distributors, licensors and/or third party websites may have additional privacy policy terms, restrictions, limitations and data collection and protection practices that You should review separately and independently from this Policy. We are not liable for the data collection, storage and usage practices of any third party affiliate, vendor, licensor or the like.

This Policy constitute a binding agreement between You and Us. By accessing and/or using the Circle Services, either through the Site or the App, You agree to the terms of this Policy.


This Privacy Statement describes


DEFINITIONS

Navigational Information: Navigational information refers to information about Your computer, device, IP address, the date and time of the visit and how long You remained on Our websites, the referral URL (the site from which the visitor has come), the pages visited on Our websites and information about the device and browser (such as, browser type and version and operating system), browser history, Your Device ID, and geographical location.

Personal Data: This refers to full name, email address, phone numbers, credit or debit card numbers, personal financial account information, driver's license numbers or similar personal identifiers, racial or ethnic origin, or any information that can be used to identify You or that Circle can link to You.

User Content: Content uploaded or submitted by Users such as feedback, information, updates, comments, text, images, photographs, videos, notes, sounds, data, posts and suggestions.

Circle ID: An identifying string of characters associated with Your Circle device or any other Circle account created via Circle Applications

Device ID: An identifying string of characters that is associated with any device that has Circle software installed on it or is otherwise interacting with Circle services.

User Information: Information such as, name, email address, username, passwords, census data, and payment information.

Registered User: A user of Circle Services subject to the End User License Agreement.

Unregistered User: A user of Circle Services other than a Registered User who uses the App, a Device, or a Network.

Visitor: A user of Circle Services other than a Registered User or an Unregistered User.

THE TYPE OF INFORMATION WE COLLECT

a. When You Visit the Site:

  1. If You are a Visitor, We may automatically collect Navigational Information, such as Your IP address, the date and time of the visit, how long You remained on Our Site, the referral URL (the site from which the Visitor has come), the pages visited on Our Site and information about the device and browser (such as, browser type and version and operating system). We may also collect visitor data through third party services such as Google Analytics, in order to better understand visitor behavior, demographics, locations, page views, time spent on the Site, and other metrics and analytics used to provide and improve the Circle Services.

  2. In addition to information We collect on Our Site, We may also collect Your city location, device model and version, device identifier (or “UDID”), and OS version.

b. When You Are on the Network:

  1. If You are on the Circle Network, whether You are a Registered User or Unregistered User, We collect certain information about You and Your device associated and connected to the Network. Such information may include, without limitation, Navigational Information, network preferences, Personal Data, and sensitive data collected by Circle from Users.

  2. Circle uses technology including establishing a virtual private network (“VPN”) with mobile devices on a Network which conveys information about the sites you access on the internet to the Circle cloud. The VPN allows Circle to manage content and time online for this mobile device, and creates data about use of that device that is used by Circle App. The Circle App displays information collected via VPN on admin devices through Circle App. Circle never shares data collected through the VPN with any third-party.

c. When You Register for Circle Services:

  1. When You register to use the Circle Services, You will need to provide Us with User Information, Personal Data, Circle ID, and Device ID. You will also be required to verify Your account through the email Your provided upon sign up. Once You’ve been verified, You may opt in to receive promotional offers and communications from Us, and a free trial for the Circle Home Plus. These preferences and choices may be collected and analyzed for business purposes only.

  2. Circle only collects User Information and Your Personal Data when You voluntarily provide it to Us, for instance by using Circle App, contacting Our customer service or by purchasing Products through Our Site. You do not need to provide Us with Personal Data. However, without providing certain data, for instance Your email address, We may not be able to respond to Your request or provide the Circle Services.

d. When You Use Circle Services or Web Shop.

  1. When You use the Circle Services, We will ask for User Information and Personal Data (at the moment of collection We will explain what information is required in order for Us to provide the particular product or service, and what information You may choose to provide). We will also collect Navigational Information, Device ID and Circle ID.

  2. Circle collects the following information when You use Our Web Shop located at meetcircle.com: Your name, email address, phone number, postal address and payment information; and where necessary for proper functioning, Circle collects the following information when You use one of Circle's Applications and/or devices: Device ID and Circle ID.

  3. The User Information and Personal Data provided for the Circle Services is stored and managed on servers and third party hosting services, including without limitation, Amazon Web Services.

  4. You may also be prompted to pay for Circle Services, which will require financial information such as credit card and banking information, and Personal Information. All payments are processed through a secure third party payment gateway. We are not liable for the data and privacy practices of any third party payment gateway used.

e. When You Provide Feedback or User Content:

  1. We also keep a record of Our correspondence with You, including without limitation, any feedback and/or testimonials You have provided on any of the Circle Services, information provided to Our customer service, and/or User Content.

f. Information We Collect Automatically When You Use Circle Services.

  1. When you are visiting our Site, We use browser cookies and similar technologies to collect and store certain information when You (“Cookies”).

  2. While You are using Our App, We may collect Your email address, name, phone number, specific app interactions (i.e. if You use the pause feature), Your device type including OS and app versions, information about Your Circle app profiles including profile count and the number of devices discovered by Circle, as well as Your location (when available) via third-party tools. The App also collects analytic information regarding your use through third party tools.

g. Information of children.

  1. Although the Circle Services are designed to support families with children of all ages, the administration, configuration, and management of the Circle Services are intended for use by persons over the age of 16. Circle does not knowingly collect Personal Data from anyone under the age of 16 without parental or legal guardian consent.

  2. If You become aware that Circle has collected Personal Data from a child under the age of 16 without parental or legal guardian consent, please let Us know by contacting Us at privacy@meetcircle.com so Circle can take appropriate action. To prevent inadvertent disclosure of Personal Data while using Circle Services, assist in effective use of information, and ensure appropriate use of the Circle Services, We strongly encourage the parent or guardian of any child under the age of 16 to actively guide any interactions with and/or use of the Circle Services.

  3. Some versions of the MyCircle application (“MyCircle”) provide a secure platform for family members to send messages to one another via the Circle Services. Where MyCircle messages include Personal Data of children under the age of 16, prior consent of the parent or legal guardian of any such children under the age of 16 is required. Therefore, when the MyCircle messaging feature is activated by a User, the User shall verify the MyCircle Users under the age of 16, and shall provide consent for Circle’s Personal Data collection practices for children under the age of 16. Failure to provide the necessary and required consent shall be a material breach of this Agreement, and grounds for termination of this Policy and Your use of Circle Services.

HOW WE USE THE INFORMATION WE COLLECT

Circle will only process Personal Data where it has a legal basis to do so. Circle may use the information Circle collects:

a. To enter into a contract, or to take steps at Your request prior to entering into a contract (such as account registration);

b. To process Your order: We use relevant Personal Data described above (including Your name, address and payment details) to process and deliver Your order, and to notify You of the status of Your order.

c. To respond to Your inquiries and provide You with customer support services, to communicate with third parties in the handling of claims or complaints, to maintain business administration records and prevent fraud, which is Our legitimate business interest to properly provide Circle Services to You;

d. To keep records and administration on how products and services were provided, claims and complaints were handled, including the documents underlying such services, claims and complaints, which is Our legitimate business interest to maintain proper administration of disputes;

e. To understand how people use Our Site, App and Circle Services, to learn more about Our Users and their preferences, to operate, maintain and improve Our Site, App and Circle Services, to develop new products and services, to send You direct marketing or product-specific communications, which is Our legitimate business interest to improve Your customer experience with Us;

f. To comply with legal obligations applicable to Circle, such as respond to legal process or requests for information issued by government authorities or other third parties or to protect Your, Our or other parties' rights;

g. For analytics tracking as well as ad-targeting via marketing channels;

h. Contact You to inform You of important changes or additions to Our App, Site or Circle Services offered;

  1. Amalgamate data and information for analysis and research;

  2. Collect and segment data to optimize and improve the Circle Services;

  3. Operate, improve and maintain the Circle Services, including analyzing user behavior;

  4. Enforce the Policy and Terms of Use, to comply with legal obligations, and otherwise manage Our business; and

  5. Process payments and refunds, if applicable

  6. We may post user testimonials and comments on Our App or Site upon written notice to You, which may contain User Information. You have the right to request removal of such testimonial and/or comment(s) upon receiving Our written notice.

HOW WE SHARE INFORMATION

a. Service Providers and Affiliates.

  1. With the exception of data collected through the VPN, we reserve the right to disclose parts or all of Personal Data, User Content and User Information that We collect about You to service providers and affiliates who assist Us in Our business purpose either through partnerships, affiliations, contractors and/or licensors. Some service providers and contractors used on Our App and Site include, without limitation, processing payment services, analytics services, customer support services, claim handling, billing, internal administrative services, maintenance of the Service, and providing business services to Us or to You. In all cases where We share Your Personal Data with such partners, affiliates, and service providers, We explicitly require them to acknowledge and adhere to Our Privacy Policy and customer data handling policies. Such third parties are prohibited from using Your Personal Data except for these stated purposes, and they are required to maintain the confidentiality of Your User Information.

  2. Circle and its affiliated entities may share information with third-party data controllers (including NETGEAR for NETGEAR with Circle customers, law enforcement agencies and potential transaction partners) where Circle and its affiliated entities have a legal basis to do so.

b. We Never Sell Your Personal Data:

  1. Circle does not sell, license, or otherwise share User Information, User Content, Navigational Information or Personal Data, with information that reasonably identifies You for their independent use except as expressly described in this Policy or when Circle has a legal basis to do so, for instance with Your prior written consent.

c. By Law or Protected Right.

  1. We may disclose part or all User Information, User Content and/or Personal Data collected through Circle Services, if (1) required by law; (2) if We believe that disclosure is necessary to comply with the law; (3) to enforce Our intellectual property rights; (4) to protect the rights, property or safety of Us and Our employees or agents; and (5) if necessary to defend against third-party claims. We may also disclose User Information collected on the App when requested to comply with a court order, investigation, subpoena or governmental request. We will notify You of such use, either by a notification on the App or by email to Our Users.

d. Business Transfers.

  1. If We go through a business transfer, such as consolidation, merger, restructuring, acquisition, or sale of part or all of Our assets, You acknowledge and consent to the transfer of Your User Information, Personal Data and User Content. You further acknowledge and consent to the continued use of Your Personal Data, User Information and User Content by the recipient, so long as they comply with this Privacy Policy. In this event, You will be notified via email and/or a prominent notice on Our App or Site, of any change in ownership, use of Your Personal Data, and the choices You may have regarding Your Personal Data.

If Circle transfers Your Personal Data to a recipient outside the EEA, it will only do so in compliance with the General Data Protection Regulation ("GDPR"). In these circumstances, We will take appropriate steps to ensure that Your Personal Data is adequately protected. Typically, such steps include carrying out data security reviews of any recipients and putting in place contracts with such recipients to ensure they employ the same or similar appropriate technical and organizational measures as Circle, so Your data is adequately protected.

Circle will encrypt Personal Data when the data is transferred. Your Personal Data will be transferred to and stored in countries outside the European Economic Area ("EEA") (such as the United States of America) at a server of Circle in compliance with the European GDPR.

For more information on the international transfers of Your Personal Data or the appropriate safeguards in place, please contact Us via privacy@meetcircle.com.

THIRD PARTY SERVICES AND CONTENT ON THE APP AND SITE

a. Our Site may include integrated content or links to content provided by third parties (such as payment processors). This Policy does not address the privacy, security, or other practices of the third parties that provide such content. We recommend considering the privacy statements applicable to third-party websites prior to visiting those websites. We are not responsible for the privacy practices, other content and/or services operated by third parties that are linked to or integrated with Circle Service or for the privacy practices of any third party.

b. Circle engages third parties that support the operation of Our Site and Circle Applications, such as analytics providers like the Apple App Store, Google Play, and payment gateways like Chargify and Shopify. These third parties may use technologies to track Your online activities over time and across different websites, online or app platforms.

c. Our provision of such third party links, content and/or services does not constitute Our endorsement of these third parties, their content, their owners, or their practices.

d. Once You leave the Site via such a link, access a third party application, or click on a third party offer, You should check the applicable privacy policy of the third party or advertiser website to determine, among other things, how they will handle any personal information they collect from You.

PROTECTION AND RETENTION OF INFORMATION WE COLLECT

a. Circle is committed to protecting Your Personal Data and We implement appropriate administrative, technical, and physical safeguards designed to safeguard the information that Circle collects. For instance, Circle encrypts all data when in transit. However, no information system can be 100% secure. This means that Circle cannot guarantee the absolute security of Your Personal Data. Moreover, Circle is not responsible for the security of information You transmit to Us over networks that Circle does not control, including the internet and wireless networks, or the data that is stored on Your Circle device.

b. Circle works to protect Your User Content and/or Personal Data by using reasonable and appropriate technical, administrative and physical procedures to protect against loss, misuse, unauthorized access, disclosure, destruction or alteration. We also take precautions to protect Users' Personal Data off-line, and We follow generally accepted industry standards to protect the information submitted to Us, both during transmission and once We receive it. However, We cannot fully ensure or guarantee the security of any information You send to Us, and You do so at Your own risk.

c. If, and when, a User accesses secured areas of Our Sites, Secure Sockets Layer (SSL) technology protects user information using both server authentication and data encryption, ensuring that user data is safe, secure, and available only to authorized persons.

d. Our computer systems are hosted in a secure data center environment that uses a firewall, intrusion detection systems, and other advanced technology to prevent interference or access from outside intruders.

e. Circle retains the information collected in an identifiable form as long as reasonably necessary and only for as long as required to fulfill the purposes and on the lawful grounds described above for which Circle collects the information and to comply with Our legal obligations. This means that We will keep Your Personal Data as long as necessary to be able to provide You with Our products and services and to be able to respond to Your requests.

f. When We have no ongoing legitimate business need to process Your Personal Data, Navigation Information, and/or User Information, We securely delete the information or anonymize it or, if this is not possible, then We will securely store Your User Information and/or Personal Data and isolate it from any further processing until deletion is possible. We will delete this information from the servers at an earlier date if You so request, as described above.

g. Without explicitly contacting Circle, the company is unable to judge if a customer has discontinued use of the hardware device. As such, Circle retains the information required to regain access to the device (phone number, Circle ID, and email address) until deletion of that information is requested.

h. Please bear in mind that whenever You voluntarily make Your Personal Data available for viewing by third parties online - for example through email or registering on a App - that information can be seen, collected and used by others besides Us. We are not responsible for any unauthorized third-party use of such Personal Data.

i. If You have elected to receive marketing communications from Us, We retain information about Your marketing preferences for a reasonable period of time from the date You last expressed interest in Our content or Services, such as when You last opened an email from Us or ceased using Your Account. We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created.


The following are examples to illustrate how Circle keeps Your Personal Data for as long as necessary for a particular purpose:

  • We may keep Your Personal Data collected during a purchase for as long as required by national tax laws;

  • We may keep the Personal Data in Your subscription account for 6 months after the date You deleted Your account to enable You to reactivate the account if preferred;

  • We may keep the personal account data associated with Your hardware so You can regain access to Your hardware device;

  • We delete Your email address used for direct marketing purposes (such as newsletters) after You have requested removal. We will retain Your email address for product-specific messaging unless You request removal.


GLOBAL DIGITAL PRIVACY REGULATIONS (GDPR) COMPLIANCE

a. Our legal basis for collecting and using information described herein will depend on the User Information and Personal Data concerned, and the specific context in which We collect it. However, We will normally collect Personal Information and Personal Data from You only where We have Your consent to do so, where We need the Personal Information and/or Personal Data to perform a contract with You, or where the processing is in Our legitimate interests is not outweighed by Your data protection interests or fundamental rights and freedoms. In some cases, We may also have a legal obligation to collect and maintain Personal Information and/or Personal Data from You.

b. If We ask You to provide Personal Information and/or Personal Data to comply with a legal requirement or to perform a contract with You, We will make this clear at the relevant time and advise You whether the provision of Your Personal Information and/or Personal Data is mandatory or not (as well as of the possible consequences if You do not provide Your Personal Information and/or User Data). Similarly, if We collect and use Your Personal Information and/or Personal Data in reliance on Our legitimate interests (or those of any third party), We will make clear to You at the relevant time what those legitimate interests are.

c. Processing shall be lawful only if and to the extent that at least one of the following applies:

  1. the data subject has given consent to the processing of his or her personal data for one or more specific purposes;

  2. processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract;

  3. processing is necessary for compliance with a legal obligation to which the controller is subject;

  4. processing is necessary in order to protect the vital interests of the data subject or of another natural person;

  5. processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;

  6. processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.

YOUR CHOICES AND RIGHTS

Fair play and transparency are important to Us. We are open about the Personal Data We collect and have implemented mechanisms to enable You to exercise any rights You might have with respect to Your Personal Data, such as:

a. Contacting Us to update or correct Your information if it changes or if You believe that any information that We have collected about You is inaccurate or out-of-date;

b. Asking Us to see what Personal Data We hold about You;

c. Asking Us to rectify or erase Your Personal Data, or to port Your Personal Data;

d. Telling Us if You object to or want to restrict Our use of Your Personal Data; and

e. Complaining to a data protection authority about Our collection and use of Your User Information and/or Personal Data.

Where We process Your Personal Data on the basis of Your consent (e.g. Your consent to receiving direct marketing messages or Your consent to the placement of cookies on Your device), You may withdraw Your consent at any time by contacting Us at the address below. Withdrawing Your consent will not affect the lawfulness of any processing We conducted prior to Your withdrawal, nor will it affect processing of Your User Information and/or Personal Data conducted in reliance on lawful processing grounds other than consent.

If You would like to opt out of or unsubscribe from receiving direct marketing communications, You can also use the unsubscribe link contained in the message You have received. However, You cannot opt out of receiving transactional emails related to Your Account with Us or Services, unless You delete Your Account. Where We process Your Personal Data on the basis of Our or a third party's legitimate interest, You may object to such processing at any time by contacting Us at the address below.

Our affiliates and partners are solely responsible for their own marketing emails and other communications directed to You. We cannot unsubscribe You from Our partners’ communications. You may, however, unsubscribe from Our communications regarding Our partners’ by clicking on the "unsubscribe" link located on the bottom of their emails, or by contacting them directly.

If You would like to discuss or exercise Your rights, please contact Us via privacy@meetcircle.com. You can also use this address to lodge a complaint. If You are not satisfied about the manner in which Circle handles Your complaint, You may also lodge a complaint with Your local data protection authority. For information about the choices You may have in regard to Our use of cookies or other tracking mechanisms, please click here.

USE OF COOKIES AND TRACKING TECHNOLOGIES

Circle collects certain information by automated means when You visit Our Site or use Circle Applications. By collecting this information, Circle learns how to best tailor Our Site and App experiences to Our Users. Circle collects this information through various means such as “cookies,” “web beacons”, and “IP addresses” as explained below.

Like many companies, Circle uses “cookies” and related trackers on Our Site and Apps. Cookies are bits of text that are placed on Your computer's hard drive when You visit certain websites. Web beacons allow Us to obtain information such as the IP address of the computer that downloaded the page on which the beacon appears, the URL of the page on which the beacon appears, the time the page containing the beacon was viewed, the type of browser used to view the page, and the information in cookies set by the third party. Circle uses the information collected from these technologies to compile reports and help Us improve the Site and Apps.

For example, a cookie might tell Us whether You have visited Us before, the number of visitors to the Site, which site a visitor has come from, the pages they visited, and to help Us identify site features in which You may have the greatest interest. Cookies may enhance Your online experience by saving Your preferences while You are visiting a particular site.

Circle also collects IP addresses. An IP address is a unique identifier that certain electronic devices use to identify and communicate with each other on the internet. When You visit Our Site, Circle may view and/or store the IP address of the device You use to connect to the internet. Circle uses this information to determine the general physical location of the device and understand from what regions of the world Our websites visitors come from. Circle also may use this information to enhance Circle's websites.

More information about the tracking services We use on Our Site and Circle Applications is set out here.

Use of tracking in Our Circle Applications is required for the proper functioning and ongoing improvement of the Circle Service and Product. Specifically, the data collected in the Apps allows Circle to diagnose bugs and service-level issues, send on-boarding information via email and in-app messages about important updates and issues, and track feature usage at an aggregate level to inform product enhancements. The tracking described only occurs when the Circle Services are in use.

Most browsers will tell You how to stop accepting new cookies, how to be notified when You receive a new cookie, and how to disable existing cookies. Please note, however, that without cookies You may not be able to take full advantage of all Our Services and Circle Applications. Some browsers offer a “Do Not Track” (“DNT”) signal whereby You may indicate Your preference regarding tracking and cross-site tracking. Although Circle does not currently employ technology that recognizes DNT signals, Circle will only process Your Personal Data in accordance with this Policy.

Our Services also use web analysis services such as Google Analytics, in order to better understand Your use of Our websites and how We can improve the Site. The information generated by these services is anonymous and does not include data that can personally identify You. The anonymous information collected through the use of these services is not combined with any Personal Data You may have explicitly chosen to share with Us. The providers’ ability to use and share information collected by these services about Your visits of Our Services is restricted by terms of use and the providers’ privacy statements. To get a better understanding of how these providers may use the anonymous data collected on Our websites, You may review, as an example, Google’s policy on this matter here. You can also opt-out of Google advertising features through Your ad settings.

REMOTE ACCESS OF YOUR CIRCLE ACCOUNT CONFIGURATION

The End User License Agreement for any Circle Device or Circle Account authorizes Circle or its duly authorized support representatives to access Circle Devices or Circle Account information remotely. Circle requires such access in order to troubleshoot, debug, and otherwise offer support and solutions to Circle Services users. Remote access is enabled by the User via the Circle App.

Except as described elsewhere in this Policy, Circle does not access a given Circle Device or Account unless a support request has been received, and it becomes apparent to the support representative that there is a problem that can be solved via remote access. If You wish to limit the level of access to Your Circle Device or Account, You must state those limitations at the time of Your support request.

Circle or its duly authorized support representatives will only access Your Circle Device or Account under the conditions that You set. Whether or not You set any limitations on remote access, Circle will discontinue remote access upon resolution of the support request or deletion of Your account.

PRIVACY NOTICE FOR CANADIAN USERS

Pursuant to Section 4.2 of Schedule 1 of Canada's Personal Information Protection and Electronic Documents Act (the "Act"), Circle Media, Inc., a Nevada Corporation ("Circle") provides this Privacy Notice ("Notice") to its Canadian customers. The Act provides that the protection of Canadian citizens requires certain disclosures to be made before the acceptance of any offer of services. If after reading these disclosures You do not wish to use Circle's Services or Products, You may return Your Circle Device for a full refund.

Circle believes that its Privacy Policy meets or exceeds the requirements of the Act. It is Circle's interpretation of Section 7.2(2) of Division One of Part One of the Act that Circle's data collection activities fall within the Completed Business Transaction exemption to some requirements of the Act. Additionally, Circle does not collect "Personal Information" as defined in the Act unless it is encrypted in transit and at rest. Nonetheless, using the Services carries certain privacy risks unique to Canadians. Please review this Notice carefully.

Circle's Servers are in the United States of America. In order to provide the Circle Services, the Circle Device uses the Internet to connect to Circle's servers. Those servers are located within the continental United States. The Act recommends that notice be given that data, which may include Personal Data, will travel between Canada and the United States, and that the data will rest on Our servers.

Circle's Treatment of Personal Information. When You use Circle Services, Circle uses the ID Number of Your Circle Device or the Circle Go software application, in whatever form (the "Circle Go Software"), as its primary identifier. This prevents unnecessary transfer of Personal Data between the Circle Go Software and the servers, or between various portions of the Circle Go Software. Circle does not need to know “who” is using the Circle Services to provide the personalization You expect of the Circle Services. Rather, We need to know “which” device is requesting, posting, or otherwise interacting with Circle's servers. The Circle Device and Circle Go Software carry preferences and filtering information independent of Personal Data. We do log Your IP address (the Internet address of Your computer or network) to give Us an idea of which parts of Our website You visit and how long You spend there. Circle does not link Your IP address to any Personal Information or Data unless You have logged in to Our Services. Even then, the related Personal Data is encrypted while in transit and at rest. Finally, during registration of Your Circle Device You are invited to submit information, including Personal Data, for the purposes of registering Your Circle Device for warranty protection. Once collected, this information is stored in a separate database, and is not readily accessible via the Circle Services.

PRIVACY NOTICE FOR NORWEGIAN USERS

Pursuant to Norway’s Personal Data Act (the "Act"), Circle provides this Privacy Notice ("Notice") to its Nordic customers.

Circle believes that its Privacy Policy meets or exceeds the requirements of the Act. Additionally, Circle does not collect "Personal Data" as defined in the Act unless it is encrypted in transit and at rest. Nonetheless, using the Services carries certain privacy risks unique to Nordic customers. Please review this Notice carefully. Circle's Servers are in the European Economic Area and United States of America. In order to provide the Services, the Circle Device uses the Internet to connect to

Circle's servers. Those servers are located within the EU/EEA and USA. The Act recommends that notice be given that data, which may include Personal Information, may travel between the Nordic region and other EU/EEA states or the USA, and that the data will rest on Our servers.

Circle's Treatment of Personal Information. When You use the Circle Services , Circle uses the ID Number of Your Circle Device or the Circle Go software application, in whatever form (the "Circle Go Software"), as its primary identifier. This prevents unnecessary transfer of Personal Information between the Circle Go Software and the servers, or between various portions of the Circle Go Software. Circle does not need to know “who” is using the Circle Services to provide the personalization You expect of the Services. Rather, we need to know “which” device is requesting, posting, or otherwise interacting with Circle's servers. The Circle Device and Circle Go Software carry preferences and filtering information independent of Personal Data. We do log Your IP address (the Internet address of Your computer or network) to give Us an idea of which parts of Our Site You visit and how long You spend there. Circle does not link Your IP address to any Personal Data unless You have logged in to Our Services. Even then, the related Personal Information is encrypted while in transit and at rest. Finally, during registration of Your Circle Device You are invited to submit information, including Personal Information, for the purposes of registering Your Circle Device for warranty protection. Once collected, this information is stored in a separate database, and is not readily accessible via the Circle Services. We will delete or anonymize Personal Information when it is not required for our provision of Circle Services to You.

YOUR RESPONSIBILITIES AND CONSENTS

By visiting or using the Services, You agree to this Privacy Policy. This is the entire and exclusive Privacy Policy and it supersedes any earlier version.

By using any of Circle Services, You expressly consent to the following:

  1. You consent to the collection, use, disclosure and processing of Your User Information and/or Personal Data in the manner described in this Privacy Policy, including Our procedures relating to cookies, IP addresses, log files and the like;

  2. Our servers are based in the United States or the European Economic Area, so Your User Information and/or Personal Data will be primarily processed by Us in the United States or EEA/EU. You consent to the transfer and processing of Your User Information and/or Personal Data in the United States or the EEA/EU by Us and by Our partners and affiliates;

  3. You consent and agree that We may transfer Your User Information and/or Personal Data to data processors located in countries, including the United States, which do not have data protection laws that provide the same level of protection that exists in countries in the European Economic Area. Your consent is voluntary, and You may revoke Your consent by opting out at any time, as described above. Please note that if You opt-out, We may no longer be able to provide You with Our Services;

  4. You consent to Us sharing Your User Information and/or Personal Data with relevant persons working for service providers and third party affiliates who assist Us to provide Our Service; and

  5. If You have enabled cookies on Your web browser, You consent to Our use of cookies as described in this Privacy Policy.


Contact
Circle Media Labs, Inc.
1104 NW 15th Ave, Portland, OR 97209
503-206-5346
privacy@meetcircle.com

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