Privacy

General Privacy Issues and Circle Privacy Policies

Circle Media Labs Inc. ("Circle") is committed to maintaining your privacy in all of its practices. This policy discusses measures that we take to protect your privacy and discloses information about certain data collection practices that help us ensure that your user experience is as seamless as possible.

The initial sections of this Privacy Notice cover the use of Circle Services (as defined in Section I of the Circle Services Terms of Use located at https://meetcircle.com/legal) as accessed through a Circle Device, the Circle application, the MyCircle application, the Circle Go application, or any other Circle product or feature from the United States or Canada. International customers, please refer to the region-specific privacy information located below this Privacy Notice. In addition, users who opt to use MyCircle’s family messaging features should review the specific privacy policies relating to that service.

I. Visiting the Circle Website.

Circle’s website (https://meetcircle.com) may use standard tracking technologies, such as "cookies", to collect information about how you use the site. A cookie is a small data file that certain Web sites write to your hard drive when you visit them. A cookie file can contain information such as a user ID that the site uses to track the pages you've visited, but the only personal information a cookie can contain is information you supply yourself. A cookie can't read data off your hard disk or read cookie files created by other sites.

Some parts of the Circle website may use cookies or other related technologies to understand user traffic patterns. We do this in order to determine the usefulness of our website information for our users and to see how effective our navigational structure is in helping users reach that information. Some of the features and functions of Circle’s web platforms, including a web dashboard for modifying the settings and configuration of a particular Circle Device, may require the use of cookies in order to work properly. If you prefer not to receive cookies while browsing our website, you can set your browser to reject all cookies, or to prompt you to accept or reject individual cookies. You do not need to have cookies turned on to use/navigate through many parts of the Circle website. However, some features of the Circle Services may not function in the absence of cookies.

Some visitors to the Circle website may also choose to contact Circle for marketing or support purposes directly through the tools provided on the website. You may choose to provide some Personal Information in order to communicate, and any disclosure of Personal Information is subject to the Privacy Considerations described in Section II below.

II. Privacy Considerations Related to the Circle Services.

What We Mean by "Personal Information." "Personal Information" means any information that may be used to identify an individual, including, but not limited to, a first and last name, email address, a home, postal or other physical address, other contact information (including information discoverable via access to your mobile device’s operating system), and other information, including information that you submit to or save within the Circle Services.

Privacy Defaults. When you use Circle Services, the primary identifier that we work with is the "Circle ID," which is an identifying string of characters that is associated with your Circle Device or any other Circle Account created via Circle applications, and the "Device ID," which is 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. This prevents unnecessary transfer of Personal Information whenever possible. Circle does not need to know "who" is using the Circle Services. Rather, we need to know "which" device(s) are requesting, posting, or otherwise interacting with the API, and what settings and configuration information apply to that device. The Circle Device and other Circle Accounts may carry preferences and filtering information both independent of and correlated with Personal Information, and that information may at times be mirrored on Circle’s servers. All information, including Personal Information, is encrypted while in transit. Finally, during registration of your Circle Device you are invited to submit information, including Personal Information, for the purposes of registering your Circle Device and creating a Circle Account for warranty protection and to deliver applicable services.

When you use, configure, or modify the Circle Services, whether via a mobile application, such as the Circle application, or through any other method, you may be providing Personal Information as you establish your account credentials, utilize the features of the Circle Services, transmit information to Circle’s API, and otherwise engage with the Circle Services. Circle has access to Personal Information for the limited purpose of providing functionality and features via the Circle Services.

Except as necessary to provide services, Personal Information stored on the Circle device, third-party hardware utilizing Circle software, or Circle systems of record is not shared with Circle or any third parties. Circle servers do not aggregate or retain this information beyond what is necessary for the Circle Services to function. We won’t sell your Personal Information. Although Circle takes reasonable steps to ensure the security of any Personal Information stored on the Circle device or any other Circle account, both while at rest and through normal modes of accessing that information, you should not expect that the information is entirely secure. You are primarily responsible for the security of information stored in any Circle services you use, including any Circle applications, services, and hardware.

From time to time, Circle may gather data collected through a user’s interaction with Circle Services in order to gain insight into the wider user base and improve Circle Services overall. In this case, Circle will only gather data in an anonymized fashion without any Personal Information.

Personal Information Sharing and Disclosure. Your Personal Information is never shared outside the Circle Services without your permission, except under conditions explained below. Bear in mind that Circle cannot be held responsible for your own disclosure of Personal Information, whether accidental or intentional.

Circle may send your personal information to other companies or people under any of the following circumstances:

  • When we have your consent to share the information;

  • When we need to share your information to provide the product or service you have requested;

  • When you have told us to send the information to other individuals on your behalf.

We will also disclose your personal information if required to do so by law, to enforce our Terms of Use, or in urgent circumstances, to protect personal safety, the public, or the Circle Services.

The Circle Services and the Children’s Online Privacy Protection Act (COPPA).

NOTE: MyCircle users should closely review the privacy policies and disclosures located in Section III of this Privacy Notice.

COPPA regulates the collection of data about children under the age of 13 who are accessing a website or other Internet application. Although the Circle Services are designed to support families with children of all ages, the administration, configuration, and management of the Circle Services is intended for use by adults over the age of 18. We do not require any information regarding minor children in order to provide the Circle Services. We offer the opportunity to create profiles for each user of the Circle Services, including minors. To the extent that a user submits Personal Information about minor children, such information is encrypted in transit.

To prevent inadvertent disclosure of Personal Information 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 18 to actively guide any interactions with Circle Services. In the event that a child under the age of 13 chooses to access the Circle Services, Circle believes that its privacy policy and procedures comply with the requirements of COPPA.

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. Except as described elsewhere in this Privacy 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 Circle or its duly authorized support representatives have to your Circle Device or Account, you must state what limitations you wish to place on Circle’s use of remote access 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 access upon resolution of the support request.

III. MyCircle Privacy Considerations and Policies.

MyCircle Messaging Features. The MyCircle application provides a secure platform for family members to send messages to one another via the Circle Services. These messages may include Personal Information, including the Personal Information of children under the age of 13. The MyCircle messaging features therefore require prior consent of the parent or legal guardian of any such children under the age of 13 in a specific household. When MyCircle messaging features are activated by a user, the user is required to verify the existence of MyCircle users under the age of 13 and provide consent for Circle’s information collection practices for children under the age of 13.

Circle’s Treatment of MyCircle Messages. MyCircle is designed to provide a safe and family-friendly messaging system. Circle maintains reasonable security measures to ensure that messages are securely transmitted and stored. Circle will not share, release, or distribute MyCircle messages to anyone other than the intended recipients except under extraordinary circumstances, such as: a valid subpoena or search warrant from a law enforcement agency or police department; a legitimate concern for public safety or the personal safety of a user; or in response to a signed written request of a parent or legal guardian.

IV. Privacy Complaints, Consent Modifications, and Concerns.

If you have a complaint about privacy matters, questions, or concerns regarding this Privacy Policy, or if you wish to modify or revoke your consent to Circle’s information collection practices under COPPA but are unable to do so through the Circle applications directly, please contact Circle’s Privacy team:

Circle Media Inc.
Attn: Privacy
1201 NE Lloyd Blvd Ste 100
Portland, OR 97232

privacy@meetcircle.com

XVI. Privacy Notice for Canadian Purchasers: Protection of Personal Information & Mandatory Disclosures

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 device (the "Circle Device") or services ("Services"), you may return your Circle Device for a full refund.

Circle believes that its Privacy Policy, as described in more detail in its Terms of Use and 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.

  1. Circle's Servers are in the 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 continental United States. The Act recommends that notice be given that data, which may include Personal Information, will travel between Canada and the United States, and that the data will rest on our servers.

  2. Circle's Treatment of Personal Information. When you use the 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 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 Information. 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 unless you have logged in to our website. 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.

  3. Your Consent to our Privacy Policies. Your use of the Services, or applications designed to access the Services, whether stand-alone applications for computers or mobile devices, or the software incorporated into a Circle Device means that you consent to Circle's Terms of Use and Privacy Policy. We may revise these Terms at any time; if we do so we will post an updated version with the date of the update posted below the effective date. It is your responsibility to visit this page periodically to review any updates. Your continued use of Circle Services after any changes to the Terms constitutes your acceptance of, and consent to abide by, the revised Terms. IF YOU DO NOT AGREE WITH THE PRIVACY POLICY, OR OBJECT TO CIRCLE'S TREATMENT OF PERSONAL INFORMATION, DO NOT USE THE CIRCLE DEVICE OR SERVICES.

XVII. Privacy Notice for Norwegian Purchasers: Protection of Personal Information & Mandatory Disclosures

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

Circle believes that its Privacy Policy, as described in more detail in its Terms of Use and 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.

  1. 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.

  2. Circle's Treatment of Personal Information. When you use the 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 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 Information. 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 unless you have logged in to our website. 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.

  3. Your Consent to our Privacy Policies. Your use of the Services, or applications designed to access the Services, whether stand-alone applications for computers or mobile devices, or the software incorporated into a Circle Device means that you consent to Circle's Terms of Use and Privacy Policy. We may revise these Terms at any time; if we do so we will post an updated version with the date of the update posted below the effective date. We will also notify you by email. Your continued use of Circle Services after any changes to the Terms constitutes your acceptance of, and consent to abide by, the revised Terms. IF YOU DO NOT AGREE WITH THE PRIVACY POLICY, OR OBJECT TO CIRCLE'S TREATMENT OF PERSONAL INFORMATION, DO NOT USE THE CIRCLE DEVICE OR SERVICES.

XVIII. Privacy Notice for Purchasers in the Netherlands, Belgium, and Luxembourg Protection of Personal Information & Mandatory Disclosures

Pursuant to the EU Privacy Directive (the “Directive”) and the national privacy laws of the Netherlands, Belgium, and Luxembourg, Circle Media, Inc., a Nevada Corporation ("Circle") provides this Privacy Notice ("Notice") to its customers in these countries.

Circle believes that its Privacy Policy, as described in more detail in its Terms of Use and Privacy Policy, meets or exceeds the requirements of the Act. Additionally, Circle does not collect "Personal Data" as defined in the Directive unless it is encrypted in transit and at rest. Nonetheless, using the Services carries certain privacy risks for customers in EU member nations. Please review this Notice carefully.

  1. Circle's Servers are in the 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 continental United States. The Directive requires Circle to notify and obtain consent from users regarding data, which may include Personal Information, traveling outside the EU to the United States. Data transmitted outside the country of origin will rest on our servers.

  2. Circle's Treatment of Personal Information. When you use the 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 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 Information. 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 unless you have logged in to our website. 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.

  3. Your Consent to our Privacy Policies. Your use of the Services, or applications designed to access the Services, whether stand-alone applications for computers or mobile devices, or the software incorporated into a Circle Device means that you consent to Circle's Terms of Use and Privacy Policy. We may revise these Terms at any time; if we do so we will post an updated version with the date of the update posted below the effective date. We will also notify you by email. Your continued use of Circle Services after any changes to the Terms constitutes your acceptance of, and consent to abide by, the revised Terms. IF YOU DO NOT AGREE WITH THE PRIVACY POLICY, OR OBJECT TO CIRCLE'S TREATMENT OF PERSONAL INFORMATION, DO NOT USE THE CIRCLE DEVICE OR SERVICES.