Circles Data Privacy Policy

 

The “Circles Platform” is a medium that allows “Circles’ Subscribers” to provide backing, support and engage by means of “Subscription” to their favourite “Circles’ Creators”, Causes, Art and Content. For the purpose of clarity, “Circles’ Creators” are users who use the Circles platform to create, distribute and monetize their content through pages/other avenues on the Circles Platform and “Circles’ Subscribers are users who use the Circles platform to subscribe to the pages of “Circles’ Creators”. To facilitate the safe use of this platform, we ensure to protect your data and have drafted the following Data Privacy Policy. This Policy is a part of the Circles Terms of Use. This Policy is applicable to all of the Circles’ Platform users from Circles’ Creator to Circles’ Subscribers. The entire policy is drafted so as to make the Circles’ user understand how and why Circles’ (also referred to as “Circles,” “we” or “us”) collects, uses, and shares information about you when you use our services via various platforms spanning from websites, mobile apps, widgets, and other online products and services (referred to as collectively, the "Services") or when you (referred to as “Circles’ User”“Circles’ Creator” and “Circles’ Subscribers”) otherwise interact with us or receive a communication from us. This Policy is made to ensure to let the Circles’ Users know the privacy and protection of their data is at the forefront of the Circles’ mind.

The Circles User’s (Circles’ Creators and Circles’ Subscribers) are bound by the following policies and as a user, you acknowledge to have read, understood and agree to these terms and policies. The Following Terms are effective from 1st June 2019.

Your Data

The Data are essentially of two types

  1. The Data/ Information that the Circles’ User Provides
  2. The Data/ Information we collect
  3. The Data that is collected from another source
A. The Data/ Information that the Circles’ User Provides

Information is provided by the Circles’ Users directly when they use the services. The following are the Scenarios and the data that is being provided by the Circles’ User themselves.

  • Account Creation
    • When a User signs up with Circles they provide the following information, First Name, Last Name, email address, password, Mobile Number, Photo. There are multiple options to sign in, the users can sign in via their Facebook and Google account. We will also store your user account preferences and settings. In case the user uses the Facebook and Google accounts, they can set the preferences in their accounts that control the use Circles’ in accessing their information on the other platforms. These details are usually collected via form fields that are filled in by the User. There are options where the users are provided with form fields to fill in additional data/ information such as location, social media links, etc.
    • Additional information about the Content Creator is collected to ensure they are in compliance with the governing laws, they need to provide information such as Legal name, Address, Social Security Number if any, Country of Citizenship, Tax details, Date of birth, etc.
    • Also, to facilitate the payment to the Circles’ creators, they share information of their bank accounts, credit/debit cards, other financial instruments or they sign up with their information relating to their accounts on the various payment gateways that are supported by Circles’.
  • The Content you submit.
    • We collect the content you submit to the Services. As the Circles’ Platform is for Circles’ Creators to share their Content with their Circles’ Subscribers, all the content that is created and shared on the platform, this includes your posts and comments including saved drafts, your messages with other users (e.g., private messages, chats), and your reports and other communications with moderators and with us. Your content may include text, links, images, gifs, and videos, podcasts, etc. This also includes the rewards if any that they are sharing with the Circles’ Subscribers, any revenue targets they have.
    • We also collect the information on the other Circles’ Creators that the Circles’ Subscribers, as well as Circles’ Creators endorse.
    • If the User is a Circles’ Subscriber to the Circles’ Creators pages, they need to provide their payment card details to facilitate the membership of the service through one of the Circles’ Platform’s chosen payment gateways.
  • Actions performed using Circles’
  • We collect information about the actions you take when using the Circles’ Platform. This includes your interactions with content, like voting, saving, hiding, and reporting. It also includes your interactions with other Circles’ Users and Circles’ Subscribers, such as following, subscribing, reporting, messaging, and blocking. Also, interaction with the Community as a whole is collected.

B. The Data/ Information we collect
  • The Circles’ Users Usage Data
  • We may log information when you access and use the Services. This may include your IP address, user-agent string, browser type, operating system, referral URLs, device information (e.g., device IDs), pages visited, links clicked, the requested URL, hardware settings, and search terms.

  • Cookies and similar technologies.
  • While you browse, there are pieces of data your browser stores and sends back to us when making requests, these are essentially called cookies. We use this information to improve the overall user experience, understand user activity, personalize content according to the interests of the User and advertisements, and improve the quality of our Services. Disabling the cookies is up to the User Discretion, the user can disable this via the browser settings.

  • Location information- We may get and process data about your area and Location. For instance, with your assent, we may gather data about the particular Location of your cell phone via GPS or Bluetooth. We may likewise get location data from you when you offer such data on our Services, including by partner your substance with an area, or we may get your surmised area from other data about you, including your IP address.
C. The Data that is collected from another source

Various other personally identifiable information about the user is collected.

  • Additional Information about you the Circles’ User may be collected from various other sources, with the permission of the User, these permissions are obtained when the Circle’s User signs up to the Circles’ Platform. These permissions can be disabled by the User at any point of time by accessing the platform settings. Certain Demographical, as well as Statistical information may be ascertained from the Third-Party sources such as advertisers and social media networks, as mentioned earlier, these data are collected from these sources with the permission of the Circles’ User. All the data that are collected are in accordance with the Privacy Policy. We use this data that is collected to understand the user needs and tailor make the suggestions and contents that are suitable to the targeted user / Circles’ follower to personalize the usage of the Circles’ Subscription Platform.
In what ways the User Data is being utilized by Circles’

The various ways the data is being used are as follows.

  • Helps Circles’ Users access the Circles’ Platform with ease and help use the services effectively.
  • Automatically update the Application for you.
  • Help send technical assistance messages like updates, Security alerts, invoices, and other support functions to the user.
  • Remember the information to enable the Circles’ users to log in to the account with ease and not re-enter the information every single time.
  • Allow the Circles’ Subscribers to support the Circles’ Creators content effectively.
  • Allow the Circles’ Creators to benefit from the Subscription Fees collected from the Circles’ Subscribers.
  • Respond to specific queries that are specifically related to the Circles’ User.
  • Allow Circles’ to ensure the advertisements and emails are tailored to the Users’ needs. This includes the best content for the User to access based on their preferences and Interests.
  • Preventing Misuse and Fraud and to take a prompt corrective course of action and enforcing the Terms of Use and other Policies. This could include blocking suspected spammers, addressing abuse, etc.
  • To aid in research and development to improve the overall user experience as well as the improve the Circles’ Platform. Also, the research data is used to introduce new services.
  • In certain cases, we have a legal obligation to collect and process the Circles’ Users personal information (such as our obligation to share data with tax authorities).
  • Circles’ will depend on lawful grounds to process your own data to the degree allowed by pertinent law, which may incorporate, without constraint: to respect authoritative duties, to make strides fully expecting going into contract, to satisfy lawful commitments and your consent.
Scenarios where Circles’ discloses the User Information
  1. Data Disclosure to Third- party- Circles’ has a strict policy on Data protection and we do not sell/share the User’s data unless the following scenarios apply.
    • To comply with the law- We may share data in light of a solicitation for data in the event that we trust divulgence is as per or required by, any pertinent law, guideline, legitimate procedure or administrative solicitation, including, however not constrained to, meeting national security or law authorization prerequisites. To the degree the law permits it, we will endeavour to give you earlier notice before uncovering your data because of such a solicitation.
    • In an emergency – If we believe sharing the data can prevent physical/mental harm to a person.
    • To our affiliates/ partner’s and Vendors – We source out certain work relating to the platform, such as, to: provide website hosting, maintenance, and security services; fulfil orders; conduct data analysis and create reports; offer certain functionality; or assist Circles’ in improving the Circles’ Services and creating new services and features only data that is required for the proper functioning of the platform will be shared with the third parties.
    • Circles’ additionally maintains all authority to unveil data that we accept, in compliance with common decency, is fitting or important to shield Circles’ from potential risk or false, fraudulent, abusive, or unlawful utilizations; explore and guard ourselves against third-party cases and claims, or charges; ensure the security or trustworthiness of the Circles’ Services; or ensure the rights, property, or wellbeing of Circles’, our Subscribers, our Creators, our Users, or others.
  2. Data Disclosure to Circles’ Content Creators- Some of the User’s personal identifier data is shared with the Circles’ creators as below.
    • We share the Circles’ User’s data to facilitate the distribution of rewards if any.
    • Messages and actions that are sent to the Circles’ Creators.
    • All the details of the Circles’ Subscribers Subscription data including the Subscription Fees paid, the Subscription time limit, the Subscription tier that is paid for, etc. We do not provide the Circles’ Subscribers payment detail data such as Credit card information to the Circles’ Creators.
  3. Data Disclosure to the Public
    • The following data can be publicly accessible with the Circles’ User’s permission.

    • Circles’ Users’ public profile data including the Social Media Links if added by the user.
    • The Circles’ Creators that the Circles’ Subscribers Support unless the Circles’ Subscribers choose to subscribe to the membership in private mode.
    • Any post’s or comments that the Circles’ Subscriber’s writes on the Circles’ Creator’s Public page.

You as a Circles’ User will receive notice when personal information about you might be shared with third parties and you will have an opportunity to choose not to share the information.

Data is in Circles’ User’s Control and Discretion

As a Circles’ User, you may decline to give permission to provide certain personal data, however, this would restrict the user from using certain functionalities of the Circles’ Platform. This is based on the sole discretion of the Circles’ User and most of the permissions can be controlled and enabled in the setting on the Circles’ Platform under the My Account tab. To protect the Circle’s User privacy and security, we may take additional steps to verify the user’s identity before granting you access or making corrections to your information. You are responsible for maintaining the secrecy of your unique OTP/password and account information at all times.

  • Accessing and Changing Your Information
  • You can access and change certain account information through the Circles’ Platform via the Settings available. You can also reach out to the Live support agents to provide you with any kind of help related to your account services anytime.

  • Deleting Your Account
  • You may delete your Circles’ account whenever required from the Account Settings Page. The Deletion of the Circles account will happen in a phased manner and will be accessible to the Circles’ Subscribers till the next billing date of Subscription of the Tier/ page. The content/page will be deleted and inaccessible to all the Circles’ Users from the new billing cycle. When you delete your account, your profile is not active and the details and pages/content will not be shared with the different Circles’ Users and you are disassociated from content you have posted under that Circles’ account. We may likewise hold certain data about you as required by law or for authentic business purposes after you delete your account.

  • Controlling Linked Services’ Access to Your Account
  • You can review the services you have linked to your account and revoke access to individual services here.

  • Controlling the Use of Cookies
  • Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject first- and third-party cookies when the Cookies notification pops up. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of the Circles’ Services.

  • Advertising and Analytics
  • Circles’ Platform has partnered with certain analytics providers to enhance the user experience. These providers may provide specific opt-out mechanisms and we may provide, as needed and as available, additional tools and third-party services that allow you to better understand cookies and how you can opt-out.

    We also give a Circles’ User the option to receive personalized advertisements based on their preference. The User can edit or opt out of receiving these personalized advertisements by accessing these in the account settings. Your Online Choices.

  • Do Not Track
  • Most of the web browsers today give the users a privacy preference option to send a Do Not Track signal to the websites you visit, indicating that you do not wish to be tracked. We at Circles’ do not take any action in response to this signal. At Circles’ we offer you the choices described in this policy to manage the collection and use of information about you.

  • Mobile Notifications
  • With the Users consent, we would send promotional and non-promotional push notifications or alerts to the Users mobile device. Deactivation of these notices can be done at any time by the User from the Users Mobile Settings.

  • Location Information
  • During the installation of the app, with the consent of the User, we take details of the user Location to send personalized Content to the User. This can be disabled by the User via their device settings.

Circles’ User Data/ Information Security

We at Circles’ respect our Circles’ User Data privacy and understand the importance of the same. We ensure we protect the interests of our user’s by providing multiple avenues like technical, administrative and physical measures and controls to ensure data Security and the Privacy is protected against loss, theft, misuse, unauthorized access, disclosure, alteration, and destruction. The measures vary according to the sensitivity of the Data that has been provided by the Users’. In spite of our constant care and measures are taken, we cannot provide a warranty and guarantee of the data that is being provided to us, as the data could be susceptible through factors that are out of our control. The data that the User transmits to us is based on the User’s Risk.

Data Retention of Circle’ User Data

We Retain the User’s Data and Personal Information as long as it is required to enable the use of the Circles’ Platform and to implement the various functions of the various policies at Circles’. We would also retain the information based on the requirements as per law for purposes such as tax, accounting, and reporting, or other scenarios that will be communicated to the Circles’ User.

Children

The Circles’ Platform prohibits children below the age of 13 from creating an account or using the Circles’ platform. Protection of Children’s privacy is of utmost importance at Circles’. In the case there are cases where data of Children has been used, we would take prompt steps to delete the information at the earliest and the account will be deleted. In case of Children above the age of 13, we need to have obtained verifiable consent from your parent or legal guardian for the children to use the Circles’ Platform.

International Data Transfer

We are situated in India and we process and store data on servers situated in India. We may store data on servers and hardware in different nations relying upon an assortment of variables, including the areas of our clients and specialist co-ops. By getting to or utilizing the Services or generally giving data to us, you agree to the handling, exchange, and storage of data in India. and other countries, where you may not have the same rights as you do under local law.

The Following terms can be subject to change, and if the changes affect the rights of the users, they will be intimated via an announcement on the platform or Circles will send a notice to the Users notifying the change. We encourage Circles’ Users to review the Privacy Policy whenever they access or use our Services or otherwise interact with us to stay informed about our information practices and the ways you can help protect your privacy. By continuing to use our Services after Privacy Policy changes go into effect, you agree to be bound by the revised policy. In case the Circles Users continue to use the platform after the terms are changed, it is deemed that the user has read, understood and agree to the new terms and Policies.

Privacy Policy is effective as on 1st June 2019.