Privacy Policy

Effective Date

18 November 2024

Circl (“we,” “us,” or “our”) values your privacy and is committed to protecting your personal data. This Privacy Policy outlines how we collect, use, and share information about you when you interact with our platform, whether as a content creator (“Creator”) or as a subscriber/fan (“Fan”).

1. Information We Collect

We collect various types of information to provide and improve our services, including:

  • Personal Identification Information: Name, email address, date of birth, and contact details when you register or update your profile.
  • Payment Information: Payment details (e.g., credit card information), processed securely by our third-party payment providers.
  • Usage Data: Interaction data, including page views, clicks, and subscription history.
  • Technical Information: IP address, browser type, device information, and cookies to improve website functionality and experience.

2. How We Use Your Information

We use your personal data for purposes including, but not limited to:

  • Providing Services: To process transactions, such as subscriptions, one-time content purchases, or tips given to Creators.
  • Improving Circl: To monitor usage patterns, enhance features, and optimize the user experience.
  • Customer Support: To resolve inquiries, process complaints, and assist with account management.
  • Marketing and Notifications: To send you updates about Circl’s services, content suggestions, and promotions, with an option to opt-out.
  • Legal Compliance and Security: To comply with legal requirements, respond to requests from law enforcement, and protect against misuse.

3. Legal Basis for Processing (GDPR Compliance)

For users in the European Union (EU), Circl processes your personal data based on:

  • Contractual Necessity: Processing is necessary to provide our services, including subscription management and content access.
  • Legitimate Interests: For purposes like improving services, ensuring security, and handling customer inquiries.
  • Consent: For optional communications, where your explicit consent is obtained (e.g., newsletters or non-essential cookies).
  • Legal Obligation: To comply with applicable laws and requests from authorities.

4. Cookies and Tracking Technologies

Circl uses cookies to enhance your experience. Cookies are small data files stored on your device. We use:

  • Essential Cookies: Required for core functionality, such as user authentication and security.
  • Performance Cookies: To monitor website performance and user engagement.
  • Advertising Cookies: For personalized content recommendations and targeted advertising.

You can manage your cookie preferences through your browser settings. For more information, please refer to our Cookie Policy.

5. Data Sharing and Third-Party Providers

We may share your information with:

  • Payment Processors: To securely process payments and transactions on Circl. Circl itself does not store full payment card details.
  • Service Providers: For purposes such as hosting, analytics, and customer support.
  • Law Enforcement: When required by law or for the protection of Circl’s rights, safety, and integrity.

6. Data Retention

We retain your personal data as long as necessary to provide services and meet legal obligations. User information will be retained:

  • For active accounts, until you request deletion or deactivate your account.
  • For deactivated accounts, data will be retained as needed for compliance, legal claims, and fraud prevention.

7. Your Rights Under GDPR

If you are an EU resident, you have rights under the GDPR, including:

  • Access: Request a copy of your personal data.
  • Rectification: Correct inaccurate or incomplete data.
  • Deletion: Request deletion of your data, subject to legal limitations.
  • Restriction: Limit how we process your data in certain circumstances.
  • Portability: Request your data in a structured format for transfer to another service.
  • Objection: Object to processing for specific purposes, such as direct marketing.

To exercise any of these rights, please contact us at privacy@circl.my.

8. Data Security

We implement measures to protect your data, including encryption, secure servers, and access restrictions. While we strive to secure your data, please note that no online service is completely secure, and we cannot guarantee absolute security.

9. Changes to This Privacy Policy

Circl may update this Privacy Policy periodically. We will notify you of any significant changes via email or through our platform. Your continued use of Circl following any changes constitutes acceptance of the revised Privacy Policy.

10. Contact Us

For questions or concerns about this Privacy Policy, please contact:

Email: privacy@circl.my

Mail: KODIGI SAS, 229 rue Saint Honoré, 75001 Paris, France