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 Workshops Ltd. (“Circles”) takes your privacy seriously. The following principles guide our treatment of your personal information:
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.
We collect your personal information in the following ways:
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.
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.
First Name
Last Name
Date of Birth
Mobile phone number
Gender
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.
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.
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.
We may use your personal information in the following ways:
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.
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.
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:
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.
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.
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 also opt-out of these promotional messages by contacting us:
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.
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.
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.
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.
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.
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:
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.
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.
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.
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.
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.
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
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.