Written by: Itiel Avraham

October 3, 2022

Circles Ltd. – Privacy Notice

    • Circles Workshops Ltd. (“Circles“) provides a digital platform (the “Support Platform“) on which certain Group Members may join certain support groups, each group consisting of a small number of Group Members (“Group“), in order to exchange and discuss certain life challenges each Group Member is experiencing (as may be determined by Circles from time to time), with other Group Members who are experiencing similar life challenges. Each Group is moderated by a group facilitator provided by Circles (the “Group Facilitator“).
    • This privacy notice (“Privacy Notice“) explains how Circles collects, uses, stores and shares your (“User“) data through Circles’ websites at circlesup.wpengine.com (the “Site“) and the Support Platform (together with the Site, the “Services”) and constitutes an integral part of the terms of use available at circlesup.wpengine.com (“TOU“).
    • 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 PP, User must not access and use the Services, or any part thereof, and/or immediately stop any use of the Services.
    • Circles may, from time to time modify this Privacy Notice. If User does not agree with the Privacy Notice, as amended, User must stop using the Services. Circles will notify User via the Services regarding material changes in the Privacy Notice. User is advised that if User does not terminate all use of the Services, User will be deemed to have accepted the Privacy Notice, as amended.
  1. Data collected by Circles.
    • In this Privacy Notice Circles uses the term “Personal Information” to mean any information about User that would allow a third party to determine User’s individual identity.
    • Circles receives a number of different types of information about User, including:
      • Information User is required to provide in order to register for a Group or Peer Group;
      • Information User chooses to provide us with when submitting a query/comment via the Site;
      • Information User provides us with (via the Group Facilitator) during a phone call, chat, video session with the Group Facilitator;
      • Log-in information (User ID & password);
      • Information User provides in certain Circles surveys;
      • Information User is required to providein order to open an account;
      • Information User posted to a moderated session in the Group or Peer Group.
    • 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 Group Member or Peer Group Member and/or use the Services.
    • Information Circles automatically collects when User uses the Services (e.g. User’s IP address, device identifier, User’s browser type, which pages of the Site User visited and how long user visited each page. Such information may include the following:

                    First Name

                    Last Name


                    Date of Birth

                    Mobile phone number


  • All Group Content (including Group threads, transcripts of the Group Meetings and/or Peer Group Meetings) and recordings of phone calls between Circles and/or Group Facilitator (or Peer Group Facilitator) and Group Member (or Peer Group Member) and/or User.


    1. Data collected by Third Parties.
      • This Privacy Notice does not apply to any content created, used, processed and/or stored by User when using the Services. Also, the Privacy Notice does not apply to any products, services, websites, links, icons or any other content that are offered by third parties. Circles does not have any control over such third parties’ privacy practices, or the technology used by such third parties in order to collect any information. Each User is advised to thoroughly review such third parties’ privacy policies and terms of use before making any use of such third party’s products and services.
      • Without derogating from the generality of the above, when clicking on certain social media links provided on the Site (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.
      • To facilitate and customize the User’s experience of the Services and to track User’s use of the Services Circles may utilize cookies and other industry standard technologies. A cookie is a small text file that is stored on a User’s computer for record-keeping purposes which contains information about that User. Most browsers automatically accept cookies, but User may be able to modify its browser settings to decline cookies. Please note that if User declines or deletes these cookies, some parts of the Services may not work properly.
      • 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 Notice does not cover the use of cookies by any third parties, and Circles is not responsible for such third parties’ privacy policies and practices.
      • Circles uses Google Analytics. Please click on google.com/policies/privacy/partners/ in order to find out how Google Analytics collects and processes data.
    1. Circles’ Use of the collected Personal Information.
      • Personal Information may be used by Circles and/or anyone on its behalf as follows:
        • Determine User’s eligibility for the Services; provide User with the Services; provide User with certain information regarding the Services (e.g. updates, changes, additional/new services); send User emails or text messages (e.g. reminders, educational information, etc.).
        • Administer Circles’ Services; for internal operations, including troubleshooting, data analysis, improving solution and better targeting offering, improving Group facilitation testing, research, statistical and survey purposes;
        • Circles might provide User with commercial emails and sms, if User indicates that User wishes to receive such notifications. User may opt-out from receiving such commercial emails and sms at any time via the unsubscribe link in each notification;
        • To investigate, prevent or take action regarding illegal activities; comply with applicable laws, regulations and legal process; enforce Circles’ TOU; and protect Circles’ rights, the rights of Circles’ customers, employees, affiliates, or related third parties, or to take appropriate legal action to enforce Circles’ rights.
    1. Consent to Use Personal Information.
      • By providing Circles with the information mentioned herein above on the Site and/or 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.
    2. Sharing of User’s 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.
      • In the following cases Circles may disclose, without prior notification, User’s Personal Information:
        • To obtain assistance in the administration of the Site or the Services;
        • If required to do so by law according to its understanding of such law (including, but not limited to, in cases of court orders or subpoenas);
        • 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;
        • In addition, Circles may be required to disclose Personal Information to relevant national, state and local law enforcement authorities, whom may further disclose such Personal Information;
        • Notwithstanding anything herein, in the event that Circles is sold, whether by merger, sale of assets or otherwise, Personal Information collected hereunder may be one of the assets sold in connection with such transaction. Personal Information collected hereunder may also be disclosed in connection with a commercial transaction where Circles is seeking financing, investment, or support.
      • 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.
    3. Data 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.

    1. 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.wpengine.com.

    1. Compliance with Children’s Online Privacy Protection Act.
      • The Services are not intended for use by minors. Circles will not knowingly collect PII and Non-PII from or market to children, who it positively knows are under the age of 13, without the consent of a parent or legal guardian.
      • In the event that Circles becomes aware that Circles has collected Personal Information from any child, Circles will dispose of that information.  A parent or guardian who believes that his/her child under the age of 13 has provided Circles with information without parent’s/guardian’s consent, is hereby asked to contact Circles at circlesup.wpengine.com, and Circles will take reasonable steps to ensure that such information is deleted from its files.
    2. Access to 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.wpengine.com.

      • Definition

    Personal Data” means data that may be used, either alone or together with other information, to identify an individual user, including, without limitation, a user’s name, address, telephone number, username, email address, city and country, geolocation, unique identifiers, picture, or other similar information and includes personal data as defined in the General Data Protection Regulation 2016 /679 of the European Parliament and of the Council of 27 April 2016 (“GDPR“).

    • Legal Basis for Processing of Personal Data

    Circles will only process User’s Personal Data if it has one or more of the following legal bases for doing so:

    • Contractual Necessity: processing of Personal Data is necessary to enter into a contract with User, to perform Circles’ contractual obligations to User under the TOU, to respond to requests from User, or to provide User with customer support;
    • Legitimate Interest: Circles has a legitimate interest to process User’s Personal Data;
    • Legal Obligation: processing of User’s Personal Data is necessary to comply with relevant law and legal obligations, including to respond to lawful requests and orders; or
    • Consent: processing of User’s Personal Data with User’s consent.
    • User’s Rights regarding Personal Data
      • Subject to applicable law, User has certain rights with respect to User’s Personal Data, including the following:
        • User may ask whether Circles holds Personal Data about User and request copies of such Personal Data and information about how it is processed;
        • User may request that inaccurate Personal Data is corrected;
        • User may request the deletion of certain Personal Data;
        • User may request Circles to cease or restrict the processing of Personal Data where the processing is inappropriate;
        • When User consents to processing User’s Personal Data for a specified purpose by Circles, User may withdraw User’s consent at any time, and Circles will stop any further processing of User’s data for that purpose.
      • In certain circumstances, Circles may not be able to fully comply with User’s request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, however, in those circumstances, Circles will still respond to notify User of such a decision. 
      • User can exercise User’s rights of access, rectification, erasure, restriction, objection, and data portability by contacting Circles at hello@circlesup.wpengine.com. In some cases, Circles may need User to provide Circles with additional information, which may include Personal Data, if necessary to verify User’s identity and the nature of User’s request.
    • Transfer of User’s Personal Data outside of the EEA
      • The data that Circles processes in relation to Users may be transferred to, and stored at a destination outside the European Economic Area (“EEA“), e.g. the USA, that may not be subject to equivalent data protection law.
      • Where Personal Data is transferred by Circles or Circles ‘ affiliates in relation to providing the services Circles will take all steps reasonably necessary to ensure that it is subject to appropriate safeguards, such as relying on a recognized legal adequacy mechanism, which may include by entering into European Commission approved standard contractual clauses relevant to transfers of Personal Data and that it is treated securely and in accordance with this Privacy Policy.
    1. California Consumer Privacy Act (CCPA).
      • Circles recognizes that California has articulated specific privacy rights of California residents. California Users of the Support Platform should understand that Circles does not sell User data to third parties.
      • The CCPA does not generally apply to medical information governed by the California Confidentiality of Medical Information Act (CMIA) or protected health information collected by a covered entity or business associate governed by the privacy, security, and breach notification rules of the Health Insurance Portability and Accountability Act (HIPAA) and Health Information Technology for Economic and Clinical Health (HITECH) Act of 2009.
      • Pursuant to Section 1798.83 of the California Civil Code, residents of California have the right to request, once a year, if Circles have shared their personal information (non-medical record data only) with other companies for direct marketing purposes during the preceding calendar year. This is California’s “Shine-the-Light Law.”  To request a copy of the information disclosure provided by Circles, please contact at hello@circlesup.wpengine.com. Please allow reasonable time for a response.
      • California Right to Know: You may request access to the specific pieces of personal data we have collected about you in the last 12 months. You may also request additional details about our information practices, including the categories of personal data we have collected about you, the sources of such collection, the categories of personal data we share for a business or commercial purpose, and the categories of third parties with whom we share your personal data. You may make these requests by contacting us at hello@circlesup.wpengine.com. Please allow reasonable time for a response.
      • California Designated Agent. You may designate an agent to make a request on your behalf. That agent must have access to your Account in order for us to verify the request. 
      • California Non-Discrimination. Circles will never discriminate against you, including by denying or providing a different level of service should you choose to exercise your rights under the CCPA.
    2. International Storage. Each User is advised to be aware that Personal Information that Circles collects will be transferred to, processed and stored outside User’s jurisdiction, and that data protection laws in such jurisdiction where the information is collected stored and/or processed may differ from User’s jurisdiction. Each User hereby gives User’s consent to this transfer, processing and storage of User’s information outside its jurisdiction (e.g. outside the EU and/or the United States of America).
    3. Law and Jurisdiction. This Privacy Notice and any dispute or claim arising out of it is governed by Israeli law. Any dispute or claim arising out of or in connection with the Privacy Notice will be subject to the jurisdiction of the courts of Tel Aviv, Israel.
    4. Contact Us. For any question with respect to this Privacy Notice, Circles’ privacy practices, or in connection with the Services, User is invited to contact Circles at hello@circlesup.wpengine.com.



    Dated: March 2021