Privacy Policy

Circle Solutions Inc. ("Circle," "we," "us," or "our") is committed to processing personal data in accordance with applicable data protection and privacy laws. This Privacy Policy (the "Policy") describes our practices regarding the collection, use, disclosure, retention, and protection of information relating to an identified or identifiable natural person ("Personal Data") in connection with our websites, applications, products, and services (collectively, the "Platform").

By accessing or using the Platform, you acknowledge that you have read and understood this Policy. If you do not agree with this Policy, you must not access or use the Platform.

Scope.

This Policy applies to Personal Data that we collect through the Platform and through electronic communications related to the Platform.
This Policy does not apply to information collected offline or on websites or services not controlled by Circle, or to information collected by third parties, including through any application or content that may be linked to or accessible from the Platform. Such third parties are responsible for their own privacy practices.

Where we provide the Platform to a church or organization that administers end user accounts (a "Tenant"), that Tenant may be the controller of certain Personal Data, and Circle acts as a processor/service provider on the Tenant’s behalf. In such cases, your organization’s privacy notices and instructions will govern our processing in addition to this Policy.

Children’s Privacy

The Platform may be used by Tenants to process information about children for legitimate ministry or organizational purposes (e.g., check-in, household management, events, and forms). In such cases, the Tenant is responsible for obtaining any required verifiable parental consent and for complying with applicable laws, including the Children’s Online Privacy Protection Act ("COPPA") where applicable.

Circle does not knowingly permit children to create accounts or use the Platform independent of a Tenant’s supervision. If we learn that we have collected Personal Data from a child without appropriate consent, we will take reasonable steps to delete such information.

Parents or legal guardians who believe their child’s information has been collected contrary to this Policy may contact us at privacy@getcircle.us.

California residents under 16 years of age may have additional rights. See Your California Privacy Rights below.

Information We Collect and How We Collect It

We collect Personal Data from and about users of the Platform:

Directly from you when you provide it (e.g., forms, registrations, communications).
Automatically through your use of the Platform (see Tracking Technologies below).
From your organization or church (a Tenant) that manages your account and permissions within the Platform.

Information You Provide to Us

When you access, register with, or use the Platform, we may collect:

Identifiers and contact information (e.g., name, postal address, email address, telephone number, date of birth).
Information about your role, campus, or ministry involvement provided by you or your Tenant.
Information that relates to you but may not, on its own, identify you.

This includes, without limitation:

Information you provide in forms, registrations, and interactive features (e.g., check-ins, volunteer shifts, learning modules, AI-assisted features).
Records and copies of communications with us (including email addresses and phone numbers).
Survey responses and form submissions used for internal processing, reporting, or ministry engagement.
Transaction details related to donations, event payments, or other contributions. Payment card data is processed by third-party processors and not stored by Circle.
Search queries and usage preferences within the Platform.
Content you provide for publication or display on public areas of the Platform ("User Contributions"). User Contributions are made at your own risk, and we cannot control the actions of third parties who may view or use such content.

Tracking Technologies and Automatic Collection

When you access or use the Platform, we and our service providers may automatically collect certain information using cookies, local storage, web beacons, and similar technologies:

Usage Data: Information about how you use the Platform (e.g., access times, pages or modules viewed, interaction logs, and diagnostics).
Device and Network Data: Technical information about the device and connection you use to access the Platform (e.g., device type, browser, operating system, IP address, and mobile network).
Stored Files and Metadata: Metadata associated with files uploaded or generated in the Platform (e.g., document versioning, media content, and form submissions).
Location Data: Real-time location information if enabled by your organization. You may disable location permissions through your device settings, which may affect functionality.

Technologies used include:

Cookies: Small data files placed on your device to authenticate sessions, remember preferences, and improve user experience.
Local Storage: Data stored in your browser or app for performance and offline capabilities.
Web Beacons/Pixels: Tiny electronic files used to count users, track usage, or verify email deliverability.

These technologies help deliver a secure, reliable, and personalized experience and to maintain the integrity and performance of the Platform.

Third-Party Information Collection

When you use the Platform or its content, certain third parties may use automatic information collection technologies to gather information about you or your device. These third parties may include:

Analytics providers
Payment processors
Email and messaging vendors
Background check services (if initiated by your organization)
Embedded content platforms (such as video players or maps)

These third parties may collect information about your activity over time and across different online services. Such information may be associated with your Personal Data or used to infer preferences, characteristics, or behavior.

We do not control third-party technologies and are not responsible for their privacy practices. We encourage you to review the privacy notices of any third-party services before use. For integrations enabled by your organization, please consult your administrator.

Purposes of Processing

We use Personal Data that we collect about you or that you provide to us for the following purposes:

Provide, operate, maintain, and secure the Platform and its modules.
Fulfill requests, process transactions, and respond to inquiries and support needs.
Personalize experiences based on role, campus, or ministry involvement.
Notify you about changes to the Platform or any services we offer or provide.
Support ministry workflows, including check-ins, communications, event participation, and volunteer scheduling.
Generate insights, recommendations, or task assignments using AI-powered features (where enabled by your organization).
Comply with applicable laws, regulations, and legal processes, and enforce our terms and policies.

We may use aggregated or de-identified information for analytics, performance evaluation, research, and feature development. Such information does not identify you.

You may receive communications from your organization via the Platform (e.g., reminders, announcements). Where available, communication preferences may be managed in profile settings or through Tenant administrators.

Disclosures of Personal Data

We may disclose aggregated or de-identified information without restriction. We may disclose Personal Data that we collect or that you provide as follows:

To your Tenant and its administrators in connection with your account and activities.
To contractors, service providers, and other recipients who support our operations under appropriate confidentiality and data protection obligations.
To a buyer or successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of assets.
To comply with legal obligations, court orders, or governmental requests, or to establish, exercise, or defend legal claims.
To enforce our terms and policies and to protect the rights, property, or safety of Circle, our users, or others.
With your consent or at your direction.

Your Rights and Choices

Depending on your location, your organization’s configuration, and applicable law, you may have the following rights or choices:

Communication Preferences: Manage email, SMS, or push notifications in your profile settings, where available.
Cookies and Tracking: Most browsers allow you to refuse or manage cookies. Disabling cookies may impact Platform functionality.
Location Services: Disable location access via device settings. Certain features may be affected.
Access, Correction, and Deletion: Request access to, correction of, or deletion of Personal Data by contacting your Tenant administrator or contacting us. We will assist the Tenant as appropriate.
EEA/UK Users: Where applicable, you may have additional rights such as data portability and restriction or objection to processing, and the right to lodge a complaint with a supervisory authority.
California Residents: See Your California Privacy Rights below for rights under the CCPA/CPRA, including the right to know, delete, correct, and opt-out of certain sharing.

Data Security

We implement technical, organizational, and physical safeguards designed to protect Personal Data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access.

All data is encrypted in transit and at rest using industry-standard protocols.
Access to user data is limited by role-based permissions and enforced by secure authentication.
Our systems are hosted on secure infrastructure with regular vulnerability assessments.
User sessions are protected with timeouts and activity monitoring to prevent unauthorized access.
Audit logs and system alerts help detect and respond to suspicious behavior.

No security measure is infallible. You are responsible for maintaining the confidentiality of your credentials. If you believe your account has been compromised, contact your organization or our support team promptly.

Changes to This Privacy Policy

We may update this Policy from time to time. When we make material changes, we will notify you by:

Posting the revised policy within the Circle Platform;
Updating the "Last Updated" date at the top of this Policy; and
Optionally, sending a notification via email or in-app message if required.

Your continued use of the Platform after the effective date of any changes signifies your acceptance of the revised Policy. We encourage you to review this Policy periodically.

Contact Information

If you have any questions or concerns about this Policy or our privacy practices, please contact us at: privacy@getcircle.us

Your California Privacy Rights (if applicable)

If you are a California resident, California law may provide you with additional rights regarding our collection, use, disclosure, and sharing of your Personal Data. To learn more about your rights under the California Consumer Privacy Act ("CCPA"), as amended by the California Privacy Rights Act ("CPRA"), including how to submit a request, please visit:

https://oag.ca.gov/privacy/ccpa

You may also contact us at privacy@getcircle.us to submit such a request. We will not discriminate against you for exercising your rights.