Privacy Policy

This privacy notice for CRCL ("we," "us," or "our") describes how and why we might collect, store, use, and/or share ("process") your information when you use our services ("Services"), such as when you:

• Download and use the CRCL mobile application
• Engage with us in other related ways, including any marketing or events

Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at hello@crcl.events.

Summary of Key Points

• What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the features you use.
• Do we process any sensitive personal information? We do not process sensitive personal information.
• Do we collect any information from third parties? We do not collect any information from third parties.
• How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law.
• In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties.
• How do we keep your information safe? We have organizational and technical measures in place to protect your personal information; however, no system can be guaranteed 100% secure.
• What are your rights? Depending on your location, you may have certain rights regarding your personal information.
• How do you exercise your rights? Contact us at hello@crcl.events.

1. What Information Do We Collect?

Personal information you disclose to us

We collect personal information that you voluntarily provide to us when you register on the Services, participate in activities on the Services, or otherwise contact us.

Personal Information Provided by You may include:

• Names — provided when you create your account or join via invitation.
• Phone numbers — used solely for account verification via SMS. We do not store your actual phone number; only a hashed version is retained to ensure your number cannot be accessed.
• Event data — events you create (name, time, location, description) and your attendance status.
• Circle membership — which circles you belong to and who invited you.

Sensitive Information: We do not process sensitive information.

All personal information you provide must be true, complete, and accurate, and you must notify us of any changes.

Information automatically collected

We automatically collect certain information when you visit, use, or navigate the Services, including IP address, browser and device characteristics, operating system, language preferences, referring URLs, country, location, usage data, and other technical information. This information is primarily needed to maintain security and operations, and for analytics and reporting.

• Log and Usage Data: Service-related diagnostic and performance information collected in log files.
• Device Data: Information about your device, including IP address, hardware model, operating system, and system configuration.
• Location Data: Information about your device's location, used to display and pin events on the map. We only access location when the App is in use and you have granted permission. You can opt out via device settings, though this may limit functionality.

2. How Do We Process Your Information?

We process your information to provide, improve, and administer our Services, communicate with you, prevent fraud, and comply with law. Specifically, we process personal information to:

• Facilitate account creation and authentication.
• Deliver and facilitate delivery of services, including creating events, notifying circle members, and showing event pins on the map.
• Verify your identity via SMS during sign-up.
• Send push notifications about events in your circles (only when enabled).
• Send administrative information.
• Enable user-to-user communications within circles.
• Protect an individual's vital interests.
• Improve the App — aggregated, anonymized usage data may inform product decisions.

3. What Legal Bases Do We Rely On to Process Your Personal Information?

We only process personal information when we have a valid legal basis to do so.

If you are located in the EU or UK, we may rely on:

• Consent (withdrawable at any time)
• Performance of a Contract
• Legitimate Interests
• Legal Obligations
• Vital Interests

If you are located in Canada, we may rely on express or implied consent, or other lawful bases permitted by applicable law.

4. When and With Whom Do We Share Your Personal Information?

We do not sell your personal data. Your information is shared only as follows:

• Within your circles — your name and event activity are visible to other members of circles you belong to. This is core to how the App works.
• Service providers — we use third-party services (e.g., SMS delivery, push notifications) strictly to operate the App. They do not use your data for their own purposes.
• Business Transfers — we may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business.
• Legal requirements — we may disclose data if required by law or to protect the safety of users.

5. Do We Use Cookies and Other Tracking Technologies?

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. As CRCL is primarily a mobile application, tracking is minimal and limited to what is necessary for security, functionality, and analytics.

6. Is Your Information Transferred Internationally?

Our servers are located in the United States. If you access the Services from outside the United States, your information may be transferred and processed in the United States or other countries. We take steps to protect your data in accordance with applicable law.

7. How Long Do We Keep Your Information?

We retain personal information while users have an account with us, unless a longer period is required by law. When no longer needed, we delete or anonymize data, or securely store it until deletion is possible. If you request account deletion, we will delete your personal data within a reasonable timeframe, except where retention is required by law.

8. How Do We Keep Your Information Safe?

We use industry-standard measures to protect your data, including encrypted transmission (HTTPS) and secure token storage. We implement technical and organizational safeguards, but no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure. Please access the Services within a secure environment.

9. Do We Collect Information From Minors?

We do not knowingly collect data from or market to children under 13. By using the Services, you represent that you are at least 13 years of age, or that you are the parent or guardian of such a minor and consent to such minor dependent's use of the Services. If we learn that personal information from users less than 13 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data. If you become aware of any data we may have collected from children under age 13, please contact us at hello@crcl.events.

10. What Are Your Privacy Rights?

Depending on your location, you may have rights regarding your personal information. These may include rights to:

• Access your personal data
• Correct inaccurate personal data
• Request deletion of your personal data
• Restrict processing of your personal data
• Data portability
• Object to processing of your personal data
• Withdraw consent

You may request to exercise these rights by contacting us at hello@crcl.events. We will respond within 30 days.

Account Information: If you would at any time like to review or change the information in your account or terminate your account, you can contact us using the contact information provided. Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms, and/or comply with applicable legal requirements.

11. Controls for Do-Not-Track Features

Most web browsers and some mobile operating systems include a Do-Not-Track ("DNT") feature or setting. We do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

12. Do United States Residents Have Specific Privacy Rights?

Residents of certain U.S. states (including California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Montana, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, and Virginia) may have additional rights regarding their personal data, including the right to access, correct, delete, obtain copies of, or opt out of the processing of personal data, subject to legal limitations.

To exercise these rights, please contact us at hello@crcl.events.

13. Do We Make Updates to This Notice?

We may update this privacy notice from time to time. The updated version will be indicated by an updated "Last updated" date and the updated version will be effective as soon as it is accessible. We may notify you of material changes by posting a notice or communicating directly with you. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

14. How Can You Contact Us About This Notice?

If you have questions or comments about this notice, you may email us at hello@crcl.events.

15. How Can You Review, Update, or Delete the Data We Collect From You?

You have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. To submit a request, please contact us at hello@crcl.events.