Introduction‍

The purpose of this Privacy Policy is to explain how Circle App Srl, as the provider of cloud-based messaging services (the “Services”), collects and protects your personal data, which you provide to us or which is obtained or generated by us through your use of our Services. In this Privacy Policy, “Circle”, “we”, “us”, and “our” refer to Circle App Srl, while “you” refers to you, the user of our Services.
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Please also read our Terms of Service which describes the terms under which you can use and how we provide our Services.

Privacy principles

Circle has two fundamental principles when it comes to collecting and processing private data:

• We don't use your data to show you ads.
• We only store the data that Circle needs to function as a secure and feature-rich messaging service.

Information you provide

• Account Information. Circle requires users to register a phone number when creating an account in order to provide access to the Services. Additional information, such as a profile name and picture, may be added to the account. To make it easier for your contacts and other people to reach you and recognize who you are, the screen name you choose, your profile pictures, on Circle are always public.
• Your messages: Circle is a cloud service. We store messages, photos, videos, and documents from your chats on our servers so that you can access your data from any of your devices anytime without having to rely on third-party backups. All data is transmitted and stored on our servers using an encryption protocol for data transfer and data storage.
• Contacts. Circle uses phone numbers as unique identifiers so that it is easy for you to switch from SMS and other messaging apps and retain your social graph. We ask your permission before syncing your contacts. Circle provides an optional service that allows you to discover if any of your contacts on your address book are Circle users. This service is designed to protect the privacy of your contacts. The information from your contacts (we only use the phone number) is sent to the server, where it is used to determine which of your contacts are registered Circle users. You can always stop syncing contacts or delete them from our servers.
• Location Data. If you share a location in a chat, this location data is treated like any other messages in Circle. If you use the Live Location feature, Circle will display your location to those users you're sharing it with, even when the app is closed. This feature will continue to work as long as you keep it activated but will auto-disable after 60 min by default.
• Additional technical information. Circle stores additional technical information on our servers, including authentication tokens, keys, push tokens, and other materials that are necessary for the functioning of the Services. However, we only store the minimum amount of information required for the Services to operate. This information is also stored securely.

Automatically Collected Information

• Usage and Log Information. We gather this information to understand how you use our Services, diagnose any issues, and enhance our Services. This includes details of your activity on our platform, such as the settings you choose, your interactions with others (including businesses), and the frequency, duration, and time of your activities. Additionally, we collect information like diagnostic, crash, website, and performance logs and reports, as well as log files. We also collect information about your registration date, your use of features like messaging, calling, Status, groups (including group name, picture, and description), payments or business features, profile photo, "about" information, online status, "last seen" timestamp, and the last time you updated your "about" information.
• Device And Connection Information. We gather details about your device and connection when you use our Services. This covers information like your device's hardware model, operating system, battery level, signal strength, app version, browser details, mobile network, and connection specifics such as phone number, mobile operator, or internet service provider. We also collect information about your language and time zone, IP address, device operations, and identifier.
• Location Information. With your explicit consent, we gather and utilize exact location data from your device when you decide to utilize location-based features, such as sharing your location with contacts or viewing nearby locations or those shared with you. Your device settings or in-app settings provide certain options for managing location-related information, such as location sharing. If you don't use our location-related features, we still estimate your approximate location (such as city and country) using IP addresses and other data like area codes. We may also use your location information for diagnostic and troubleshooting purposes.
• Cookies. Cookies are used to facilitate the operation and provision of our Services, both web-based and desktop, as well as to enhance your experience, analyse how our Services are used, and personalise them. They allow us to understand which articles in our Help Center are popular and show you relevant content based on your usage of our Services. Cookies are also used to remember your preferences, such as language settings, to provide a safer experience and to customise our Services to suit your needs.

Third-Party Information

• Information Others Provide About You. Other users of our Services may provide us with information about you, such as your phone number, name, and other information from their mobile address book, when they use our Services. They may also send you messages, make calls to you, or add you to groups. We require these users to have lawful rights to collect, use, and share your information before providing it to us. However, please note that any user can take screenshots or make recordings of your chats or calls and share them with anyone, including WhatsApp, or post them on other platforms.
• User Reports. In addition to your ability to report other users for possible violations of our Terms or policies, other users or third parties may also choose to report to us your interactions and messages with them or others on our Services. When a report is made, we collect information on both the reporting user and the reported user.
• Businesses On Circle. Businesses you interact with using our Services may provide us with information about their interactions with you. We require each of these businesses to act in accordance with applicable law when providing any information to us. When you message with a business on Circle, it’s important to keep in mind that the content you share may be visible to several people in that business. In addition, some businesses might be working with third-party service providers to help manage their communications with their customers. For example, a business may give such third-party service provider access to its communications to send, store, read, manage or otherwise process them for the business.To understand how a business processes your information, including how it might share your information with third parties, you should review that business’ privacy policy or contact the business directly.
• Third-Party Service Providers. We collaborate with third-party service providers to assist us in the operation, provision, improvement, understanding, customization, support, and marketing of our Services. For instance, we work with them to disseminate our applications; offer our technical and physical infrastructure, delivery, and other systems; provide engineering, cybersecurity, and operational support; furnish location, map, and places information; process payments; aid us in comprehending how people use our Services; promote our Services; help you communicate with businesses using our Services; carry out surveys and research for us; ensure safety, security, and integrity; and help with customer service. In specific circumstances, these companies may provide us with information about you; for example, app stores may provide us with reports to assist us in diagnosing and resolving service issues.
• Third-Party Services. We give you the option to use our Services with third-party services. When you do so, we may receive information about you from those third-party services. For example, if you use the Circle share button on a news service to share an article with your groups, or if you access our Services through a promotion by your mobile carrier or device provider. However, it is important to note that the terms and privacy policies of those third-party services will apply to your use of those services or products, and not our own terms and privacy policy.

Legal Ground for Processing Your Personal Data

We process your personal data to further our legitimate interests in providing and improving our services, as well as detecting and preventing fraud or security issues. However, we will prioritize your interests and fundamental rights and freedoms that require the protection of personal data. This processing is in accordance with our Terms of Service.