Circles Ltd. - Privacy Policy

Last Updated Date: January 2025

Circles Workshops Ltd. (“Circles,” “we,” “us,” or “our”) provides a website at circlesup.com (the “Site”) and a mobile application (the “App”) on which  Members may join certain support Groups, each Group consisting of a small number of Members , in order to exchange and discuss certain life challenges Members are experiencing (as may be determined by Circles from time to time), with other Members who are experiencing similar life challenges. Each Group is moderated by a Professional Facilitator or a Guide provided by Circles (each a “Moderator“).

This privacy policy (“Privacy Policy”) explains how Circles collects, uses, stores and shares your User data through the Site and the App (including certain audio-based support Groups such as Circles Plus or Circles Plus Group) (together with the Site, the “Services”) and constitutes an integral part of the Terms of Use (“TOU”). This Privacy Policy is not, however, a contract and does not create any legal rights or obligations. 

Capitalized terms used but not defined herein shall have the meaning assigned to them in the TOU.

By making any attempt to use and/or by using the Services, or any part thereof, User agrees to be bound by the terms set forth herein. If User does not accept the TOU or the Privacy Policy, User must not access and use the Services, or any part thereof, and/or immediately stop any use of the Services.

CIRCLES PRIVACY PRINCIPLES

Circles Workshops Ltd. (“Circles”) takes your privacy seriously. The following principles guide our treatment of your personal information:

  1. We value the trust you place in Circles when sharing your personal information with us.
  2. We strive to be transparent with you about what personal information we collect, what we do with it and with whom we share it.
  3. We endeavor to work with you to address your concerns about how we use your personal information.
  4. We strive to take steps designed to secure your personal information and reduce the risk it will be misused.
CIRCLES PRIVACY POLICY – YOUR PRIVACY RIGHTS

Last Updated Date: December 12, 2024

When we use the term “personal information” in this Policy, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to you. It does not include aggregated, deidentified or anonymized information that is maintained in a form that is not reasonably capable of being associated with or linked to you.

If you are a resident of a state that has laws that govern our processing of your personal information and wish to learn more about our privacy practices, please refer to the California Notice at Collection  for California State Privacy Rights and learn more about your rights for other U.S. States in the U.S. State Privacy Rights section of this Privacy Policy.

TYPES OF PERSONAL INFORMATION WE COLLECT
  • Contact Information.For example, we may collect your name, mailing address, telephone number and email address. We may also collect your mobile phone number.
  • Payment Information.For example, we may collect your credit card number and billing address to share with our third-party payment processors.
  • Information You Post.We may collect personal information you post in a public space on our Site or App.
  • Social Media Information.We may collect personal information you post on our social media pages. We may also collect your social media profile information and personal information posted on your page.
  • Information You Submit.We may collect personal information when you send us a message through the “Contact Us” page or similar features on our Site or App. We may also collect personal information about the User, including:
  • Information User is required to provide in order to register for a Group;
  • Information User chooses to provide us with when submitting a query/comment via the Site or App;
  • Information User provides us with during a phone call, chat, or audio session with the Moderator or with another User via the App (which may be transcribed in real-time);
  • Log-in information (User ID & password);
  • Information User provides in certain Circles surveys, quizzes and exercises;
  • Information User is required to provide in order to open an account and create a user profile;
  • Information User posted to a moderated session in the  Group.
  • Information User provides in a Forum.
  • Sensory Information including Audio Visual Information.  We may collect call center or Group audio recordings, and voicemails.  For example, if you participate in our Group audio sessions, then we may record your voice and personal information that you share during the Group session.
  • Health-Related Information.If you are part of one of our Groups or participate in Circles’ exercises or quizzes, then we may obtain information about your general health, mental health and symptoms that are discussed during the sessions or provided in exercise questionnaires. 
  • Demographic Information and Protected Classes of Information.We may collect your birthdate, age, race, ethnicity or national origin, gender and zip code. We may also collect personal information relating to your hobbies, lifestyle, routines, and interests.
  • Device Information.We may collect the type of device you use to access our Services. For example, we may also collect your device identifier, IP address or mobile operating system.
  • Location Information.We may collect precise location information from your device. This may include information about your exact location when you use our Services or may include information that allows us to approximate your location. We may also collect this information in the background when our mobile applications are not in use. For more information about your options related to the collection of your location information, see the “Choices Regarding Your Information” section below.
  • Log and Analytics Data.If you use our website, we may collect information about the browser you are using. We may look at what site you came from, or what site you visit when you leave us. If you use our app, we may look at how often you use the app and where you downloaded it.
  • User Data.User is not under any legal obligation to submit any Personal Information to Circles. However, in case User chooses not to submit any information, or any part thereof, to Circles, User may not be able to become a Member and/or use the Services.
HOW WE COLLECT YOUR PERSONAL INFORMATION

We collect your personal information in the following ways:

  • Directly From You.For example, when you:

o  Register for an account.

o  Use services through our Site or App.

o  Sign up to receive promotional communications.

o  Participate in one of our surveys or Groups.

o  Use of our  Services and features, such as Group sessions, quizzes, exercises, profiles, direct messaging, Forums, meeting feedback, etc.

o  Use the Ratings & Reviews or related services and features.

o  Submit a request to our Customer Service team.

o  Call or email or otherwise communicate with the Customer Service.

o  Interact with Circles social media pages.

  • Automatically. For example, when you:

o  Install and use Circles mobile apps.

o  Visit and navigate our Services  on any device.

o  Enable location-based features on our Site or App.

o  Click on sponsored links or third-party advertisements.

  • Use the Services (e.g. User’s IP address, device identifier, User’s browser type, which pages of the Site or App the User visited and how long user visited each page. Such information may include the following:

                    First Name

                    Last Name

                    Email

                    Date of Birth

                    Mobile phone number

                    Gender

  • Group Content. This includes Group threads, transcripts, and audio recordings of the Group Meetings and/or Forums, recordings of phone calls between Circles and/or Moderator ) and Group Member and/or User.  

We may also collect personal information about you over time and across different websites, apps and devices when you use our Services, using tracking technologies such as cookies, pixels, Flash objects, APIs and mobile software development kits (SDKs) and we may use third party services to collect this personal information when you use our Services.

For more information about our use of cookies and other tracking technologies to collect personal information about you automatically, please refer to the section called “Online Advertising and Third Party Tracking” below.

  • From Third Parties.We may receive personal information about you from other sources. For example, this may include receiving personal information from:

o  Our business partners, including online advertising networks, analytics vendors, and companies that co-sponsor our promotions.

o  Social media sites, including Facebook, Twitter, TikTok, Quora, Snapchat, LinkedIn and Instagram. The information we receive from these social media sites is dependent upon the social media site’s policies and your settings on that site.

o  Third party sites, including those that allow you to integrate your third-party account with your Circles account.

o  Companies that provide personal information to supplement what we already know about you, including data aggregators. Certain third parties might link your name or email address to other information they have collected. That might include online usage information.

  • By Combining Personal Information.For example, we may:

o  Combine personal information that we collect offline with personal information we collect through our Services.

o  Combine personal information we collect about you from the different devices you use to access our Services.

o  Combine personal information we get from third parties with personal information we already have about you.

HOW WE USE YOUR PERSONAL INFORMATION

We may use your personal information in the following ways:

  • To Provide Our Services.This could include fulfilling your requests for services.
  • To Improve Our Services.We may use your personal information to make our Services better. We may also use your personal information to customize your experience with us. For internal operations, this may include troubleshooting, data analysis, improving solution and better targeting offering, improving Group facilitation testing, research, statistical and survey purposes.
  • To Understand Your Interests.For example, we may use your personal information to better understand what services interest you.
  • To Respond to Your Requests or Questions.This may include responding to your feedback or request for information.
  • To Communicate With You.We may communicate with you about your account or our relationship. We may also contact you about this Policy, our Site or App terms and conditions.
  • To Determine Your Eligibility.We may use your personal information to verify your identity or determine your eligibility for some of our services and promotions. For example, this may include verifying your age, date of birth and state of residence. 
  • For Marketing Purposes.We may provide you with information about new services and special offers. We might use your personal information to serve you ads about services. We might tell you about new features or updates. These might be third-party offers we think you might find interesting. We may also use your personal information to send you electronic communications, including through email or text message. User may opt-out from receiving such commercial emails and sms at any time via the unsubscribe link in each notification.
  • For Interest-Based Advertising. We and our third party partners may engage in interest-based advertising using personal information gathered across multiple websites, devices, or other platforms to serve you relevant advertising on our Site, App or on other sites, services and mobile applications or on other devices you may use. For more information about your choices related to these communications, see the “Online Advertising and Third Party Tracking” section below.
  • For Security Purposes.This could include protecting our company and consumers who use our services. It may also include protecting our Site, App or enforcing our terms and complying with law.
  • To Send Push Notifications.If you use our mobile apps, we may send you push notifications about new services or special offers.
  • To Comply with Law.  For example, we may collect, evaluate, and monitor consumer complaints and adverse events during or after use of services to comply with our regulatory obligations.
  • For Internal Business Purposes.  For example, to provide and improve our Services, for quality control, training, and analysis, for risk management, audits, investigations, and reporting, to maintain records and audit interactions with you, for safety maintenance, for system administration and managing our technologies.  
  • As Otherwise Permitted By Law or As We May Notify You.

When we use your personal information in the ways described above, we may employ various technologies such as artificial intelligence and machine learning to provide features and customize your experience with the Services.  We do not use artificial intelligence or machine learning to make any automated decisions that produce legal or similarly significant effects concerning a User.

CONSENT TO USE PERSONAL INFORMATION

By providing Circles with the information mentioned herein above on via the Services, User consents to Circles’ use of the information, as set forth above.

By providing Circles with User’s email address and phone number via the Services, User represents that it has the authority to use and provide consent for Circles to contact that email address and phone number for the purpose of providing the Services to User.

HOW WE SHARE YOUR PERSONAL INFORMATION

Circles will not sell, trade, or otherwise disclose Personal Information, except as set forth herein. It shall be clarified, that when Circles shares Personal Information with its service providers, Circles requires them to comply with its privacy practices.

We may share your personal information in the following ways:

  • Internally.We may share your personal information within Circles and its affiliates.
  • On our Site or App.For example, we may display personal information you post on our Site or App. 
  • With Our Service Providers.We may share your personal information with third parties who perform services on our behalf. For example, this may include payment processors. It may also include companies that send emails on our behalf or help us run our Services.
  • With Our Business Partners.For example, we may share personal information with data aggregators and advertising service providers.
  • With Third Parties for Marketing Purposes.This may include our affiliate companies or brands or third parties whose services we believe may be of interest to you. 
  • For Business Transactions or Reorganizations.We may take part in or be involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of all or a portion of our company assets. We may disclose personal information to a third party during negotiation of, in connection with or as an asset in such a corporate business transaction. Personal information may also be disclosed in the event of insolvency, bankruptcy, or receivership.
  • To Comply With the Law or To Protect Ourselves or Third Parties.For example, this could include responding to a court order or subpoena. It could also include sharing personal information as required with government agencies. We might share personal information with legal authorities or law enforcement when we are investigating potential fraud.
  • For Other Reasons We May Describe to You, including but not limited to:
  • To verify the information obtained by Circles.
  • To prevent or investigate suspected fraud, or any activity that Circles believes may be illegal or may expose Circles to legal liability.
  • If Circles believes that User’s conduct on or in connection with the Services is inappropriate and inconsistent with generally accepted norms of behavior.

It is clarified that Circles is under no obligation to exercise its rights hereunder and shall not incur any liability with such exercise or lack of exercise of its rights.

CHILDREN UNDER 13

Our Services are intended for adults. We do not knowingly collect or solicit any information from anyone under the age of 13 though our Site or App, who we positively know are under the age of 13, without the consent of a parent or legal guardian.  In the event that we learn that we have inadvertently collected personal information from a child under age 13, we will delete that information as quickly as possible.  If you believe that we might have collected personal information from a child under 13, please contact us at hello@circlesup.com, and Circles will take reasonable steps to ensure that such information is deleted from its files. 

CHOICES REGARDING YOUR PERSONAL INFORMATION

Promotional Emails and Text Message Communications:

At any time, you can opt out of receiving our promotional email or text message communications. If you opt-out you will still receive non-marketing or transactional messages from us, including messages about your account and responses to your inquiries. 

  • You can opt-out of our promotional emails or text messages by following the instructions included within each of those communications.

You can also opt-out of these promotional messages by contacting us:

  • Send us an email at hello@circlesup.com
  • Call us at (+1)4075641770 (Monday through Friday, 8:30 AM – 9:00 PM Eastern)
  • Send us a letter at:
    Circles LTD.
    Attn:  Customer Service
    Street Address: 34th Page St.
    City, State Zip: San Francisco CA, 94102
    Re:  Circles Privacy Policy
Access to Your Information:

In case User wishes to remove User’s Personal Information from Circles’ database and not to receive further communications or Services, or if User wants to change or update User’s Personal Information, User is invited to contact Circles at hello@circlesup.com.

ONLINE ADVERTISING AND THIRD-PARTY TRACKING

General

This Privacy Policy does not apply to any content created, used, processed and/or stored by User when using the Services. 

Without derogating from the generality of the above, when clicking on certain social media links provided on the Site or App (e.g. Twitter, Facebook, and Pinterest) User will be transferred to Circles’ sites on such social media (“Social Media Sites“). It shall hereby be clarified that such Social Media Sites are governed by the terms of use and privacy notice of the respective social media and not by Circles.

By clicking on a link and/or icon to a third-party website or service, a third party may transmit cookies to User. This Privacy Policy does not cover the use of cookies by any third parties, and Circles is not responsible for such third parties’ privacy policies and practices.

Cookies & Other Tracking Technologies:

We automatically collect certain types of usage and device information when you visit our Site or App, read our emails or otherwise engage with us. We typically collect this information through use cookies (a small text file sent from a website and stored on your device), web beacons or pixels and similar tracking technologies, and we may utilize third party services to collect this information. For example, these tracking technologies, such as Facebook Pixels, may collect information about your device and its software, such as your IP address, browser type, device type, date and time stamp, unique device ID., and about the way you engage with our Services, for example, the site from which you came and the site to which you are going when you leave our website, the pages you visit, how frequently you access our Services, whether you open emails or click the links contained in emails, whether you access the Services from multiple devices, the products or services you view and click on, and similar actions you take. 

  • We use this information collected through tracking technologies to provide custom, personalized content and information, including targeted content and advertising, recognize you across multiple devices, monitor aggregate usage metrics such as total number of visitors, traffic, usage, and demographic patterns of our visitors, and otherwise enhance our Services and your user experience.
  • Most browsers automatically accept cookies, but User may be able to modify its browser settings to decline cookies. Your browser may give you the ability to control cookies or other tracking technologies, or to reject browser cookies. To control flash cookies, which we may use on certain websites from time to time, you can go here. Why? Because flash cookies cannot be controlled through your browser settings.
  • If you block cookies, certain features on our Site or App may not work. Depending on your mobile device and operating system, you may not be able to delete or block all cookies and you may not be able to block non-cookie technologies (such as flash cookies) and these browser settings that block cookies may have no effect on such techniques.  In addition, options you select relating to cookies and other tracking technologies are browser and device specific. You must exercise these choices on each browser and device you use.

Interest-Based Advertising:

We engage in interest-based advertising to deliver online advertising that may be more relevant to your interests. We permit third party online advertising networks, social media companies, and other third party services to collect information about your use of our websites and Services over time so that they may play or display ads on our Site or App, on other websites, apps, or services you may use, and on other devices you may use. Typically, though not always, the information used for interest-based advertising is collected through cookies or similar tracking technologies. We may share a common account identifier (such as an email address or user ID) or hashed data with our third party advertising partners to help identify you across devices or serve you ads on social media sites you may use. We and our third party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics, and market research.

  • To opt-out of or learn more about interest-based advertising and how you may be able to control the use of your personal information for interest-based advertising purposes, contact us at: hello@circlesup.com
Google Analytics and Advertising:

We use Google Analytics to better understand how our users interact with our Services. For information on how Google Analytics collects and processes data, as well as how you can control information sent to Google, review Google’s site “How Google uses data when you use our partners’ sites or apps” located at www.google.com/policies/privacy/partners/.  You can learn about Google Analytics’ currently available opt-outs, including the Google Analytics Browser Ad-On here https://tools.google.com/dlpage/gaoptout/.

We may also utilize certain forms of display advertising and other advanced features through Google Analytics, such as Remarketing with Google Analytics, Google Display Network Impression Reporting, the DoubleClick Campaign Manager Integration, and Google Analytics Demographics and Interest Reporting. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the Doubleclick advertising cookie) or other third party cookies together to inform, optimize, and display ads based on your past visits to the Service. You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences or by vising NAI’s online resources at http://www.networkadvertising.org/choices.

Our Do Not Track Policy:
  • Some browsers used to access the Site or App have “do not track” features that allow you to tell a website or App not to track you. These features are not all uniform. While we continue to evaluate this evolving technology, we do not currently respond to those signals. However, you can opt-out of such tracking by contacting us via one of the methods listed in the “How to Contact Us” section at the end of this Policy.
  •   If you block or reject cookies, not all of the tracking described here will stop and some features of our Site or App may not be available.
  • Options you select are browser and device specific.
STATE AND COUNTRY SPECIFIC DISCLOSURES

We may choose or be required by law to provide different or additional disclosures relating to the processing of personal information about residents of certain states and countries. Please refer below for disclosures that may be applicable to you:

  • California.If you are a California resident, please click here for additional California-specific privacy disclosures. 
  •     Nevada.Chapter 603A of the Nevada Revised Statutes permits a Nevada resident to opt out of future sales of certain covered information that a website operator has collected or will collect about the resident. To submit such a request, please contact us at hello@circlesup.com with the subject line “Nevada opt-out”.
  • European Union – European Economic Area (“EEA”).If you are a EEA resident, please click here for additional EEA-specific privacy disclosures. 
SECURITY

Circles has taken appropriate technical and organizational measures to protect any information Circles collects about User from loss, misuse, unauthorized access, disclosure, alteration, destruction, and any other form of unauthorized processing. User should be aware, however, that no data security measures can guarantee 100% security. We encourage you to use caution when using the Internet. A user id and a password are needed to access certain areas of the Site or App. It is your responsibility to protect your username and password. The Internet is not 100% secure. Like all businesses, we cannot guarantee the security of the personal information you provide to us via the Site or App. We have, however, taken certain steps designed to reduce the risk that the personal information you provide us will be subject to loss, misuse, unauthorized access, disclosure, alteration or destruction.  These physical measures (e.g., restricting access to offices and files), up-to-date technological tools (e.g., passwords, encryption, firewalls, and security patches), and organizational controls (e.g., limiting access, staff training, and agreements).  We apply these measures, tools, and controls based on the sensitivity of the information we collect, use, and store.  

PREVENTING IDENTITY THEFT

Each User is requested to pay attention and not to be misled by emails that appear to be from Circles and ask for Personal Information. If User receives a suspicious email requesting User’s Personal Information, User is requested to forward such email immediately to hello@circlesup.com.

STORAGE OF INFORMATION

Our Site and App are directed only to U.S. consumers for services of Circles United States. Personal Information we maintain may be stored in or outside of the United States. If you live outside of the United States, you understand and agree that we may transfer your personal information to the United States. The Services are intended for use in the United States and are subject to the laws of the United States, which may not provide the same level of protections as those in your own country.

RETENTION OF PERSONAL INFORMATION

The period for which we retain your personal information varies, depending on the type of personal information and the purpose for which it was collected.  The duration is limited to time necessary to fulfill the purposes for which the information was collected, in light of any restrictions or deletions you might request, as well as our need to address our legal obligations or rights.

LINKS TO THIRD-PARTY SERVICES

Our Services may contain links to other third-party sites, plug-ins, applications or other online services. If you click on a link to a third-party site or other online service, you will be taken to a site or other online service we do not control and that is not governed by this Policy. We are not responsible for the privacy practices used by third-party sites and other online services. We suggest that you read the privacy policies of those sites and other online services carefully.        

HOW TO CONTACT US

If you have any questions, comments or concerns with respect to our privacy practices or this Policy, or wish to update your information, please feel free to contact us at hello@circlesup.com or by telephone at (+1)4075641770 (Monday through Friday, 8:30 AM – 9:00 PM Eastern). You may also write to us at the following address:

Circles LTD.
Attn:  Customer Service
Street Address: 34th Page St.
City, State Zip: San Francisco CA, 94102
Re:  Circles Privacy Policy

CHANGES IN POLICY

Circles may, from time to time, change our Policy. We will notify you of any material changes to our Policy as required by law. We will also post an updated copy of this Policy on our Site and App. Please check our Site and App periodically for updates. If User does not agree with the Privacy Policy, as amended, User must stop using the Services. User is advised that if User does not terminate all use of the Services, User will be deemed to have accepted the Privacy Policy, as amended.