Thank you for choosing to be part of our community at circle("Company," "we," "us," or "our"). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about this privacy notice or our practices with regard to your personal information, please contact us at smcmblvme@gmail.com. This privacy notice describes how we might use your information if you: • Download and use our mobile application — circle • Engage with us in other related ways ― including any sales, marketing, or events In this privacy notice, if we refer to: "App," we are referring to any application of ours that references or links to this policy, including any listed above "Services," we are referring to our App, and other related services, including any sales, marketing, or events The purpose of this privacy notice is to explain to you in the clearest way possible what information we collect, how we use it, and what rights you have in relation to it. If there are any terms in this privacy notice that you do not agree with, please discontinue use of our Services immediately. Please read this privacy notice carefully, as it will help you understand what we do with the information that we collect. TABLE OF CONTENTS 1. WHAT INFORMATION DO WE COLLECT? 2. WILL YOUR INFORMATION BE SHARED WITH ANYONE? 3. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES? 4. HOW LONG DO WE KEEP YOUR INFORMATION? 5. WHAT ARE YOUR PRIVACY RIGHTS? 6. CONTROLS FOR DO-NOT-TRACK FEATURES 7. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS? 8. DO WE MAKE UPDATES TO THIS NOTICE? 9. HOW CAN YOU CONTACT US ABOUT THIS NOTICE? 10. HOW CAN YOU REVIEW, UPDATE OR DELETE THE DATA WE COLLECT FROM YOU? 1. WHAT INFORMATION DO WE COLLECT? Personal information you disclose to us In Short: We collect personal information that you provide to us. We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our products and Services, when you participate in activities on the App or otherwise when you contact us. The personal information that we collect depends on the context of your interactionswith us and the App , the choices you make and the products and features you use.The personal information we collect may include the following: All personal information that you provide to us must be true, complete and accurate,and you must notify us of any changes to such personal information. 2. WILL YOUR INFORMATION BE SHARED WITHANYONE? In Short: We only share information with your consent, to comply with laws, toprovide you with services, to protect your rights, or to fulfill business obligations. We may process or share your data that we hold based on the following legal basis: Consent: We may process your data if you have given us specific consent touse your personal information for a specific purpose. Legitimate Interests: We may process your data when it is reasonablynecessary to achieve our legitimate business interests. Performance of a Contract: Where we have entered into a contract with you,we may process your personal information to fulfill the terms of our contract. Legal Obligations: We may disclose your information where we are legallyrequired to do so in order to comply with applicable law, governmentalrequests, a judicial proceeding, court order, or legal process, such as inresponse to a court order or a subpoena (including in response to publicauthorities to meet national security or law enforcement requirements). Vital Interests: We may disclose your information where we believe it isnecessary to investigate, prevent, or take action regarding potential violationsof our policies, suspected fraud, situations involving potential threats to thesafety of any person and illegal activities, or as evidence in litigation in whichwe are involved. More specifically, we may need to process your data or share your personalinformation in the following situations: Business Transfers. We may share or transfer your information in connectionwith, or during negotiations of, any merger, sale of company assets, financing,or acquisition of all or a portion of our business to another company. 3. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES? In Short: We are not responsible for the safety of any information that you sharewith third-party providers who advertise, but are not affiliated with, our Website. The App may contain advertisements from third parties that are not affiliated with usand which may link to other websites, online services or mobile applications. Wecannot guarantee the safety and privacy of data you provide to any third parties. Anydata collected by third parties is not covered by this privacy notice. We are notresponsible for the content or privacy and security practices and policies of any thirdparties, including other websites, services or applications that may be linked to orfrom the App . You should review the policies of such third parties and contact themdirectly to respond to your questions. 4. HOW LONG DO WE KEEP YOUR INFORMATION? In Short: We keep your information for as long as necessary to fulfill the purposesoutlined in this privacy notice unless otherwise required by law. We will only keep your personal information for as long as it is necessary for thepurposes set out in this privacy notice, unless a longer retention period is required orpermitted by law (such as tax, accounting or other legal requirements). No purpose inthis notice will require us keeping your personal information for longer than 90 days . When we have no ongoing legitimate business need to process your personalinformation, we will either delete or anonymize such information, or, if this is notpossible (for example, because your personal information has been stored in backuparchives), then we will securely store your personal information and isolate it fromany further processing until deletion is possible. 5. WHAT ARE YOUR PRIVACY RIGHTS? In Short: You may review, change, or terminate your account at any time. If you are a resident in the EEA or UK and you believe we are unlawfully processingyour personal information, you also have the right to complain to your local dataprotection supervisory authority. You can find their contact details here: https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm . If you are a resident in Switzerland, the contact details for the data protectionauthorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html . 6. CONTROLS FOR DO-NOT-TRACK FEATURES Most web browsers and some mobile operating systems and mobile applicationsinclude a Do-Not-Track ("DNT") feature or setting you can activate to signal yourprivacy preference not to have data about your online browsing activities monitoredand collected. At this stage no uniform technology standard for recognizing andimplementing DNT signals has been finalized. As such, we do not currently respondto DNT browser signals or any other mechanism that automatically communicatesyour choice not to be tracked online. If a standard for online tracking is adopted thatwe must follow in the future, we will inform you about that practice in a revisedversion of this privacy notice. 7. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACYRIGHTS? In Short: Yes, if you are a resident of California, you are granted specific rightsregarding access to your personal information. California Civil Code Section 1798.83, also known as the "Shine The Light" law,permits our users who are California residents to request and obtain from us, once ayear and free of charge, information about categories of personal information (if any)we disclosed to third parties for direct marketing purposes and the names andaddresses of all third parties with which we shared personal information in theimmediately preceding calendar year. If you are a California resident and would liketo make such a request, please submit your request in writing to us using the contactinformation provided below. If you are under 18 years of age, reside in California, and have a registered accountwith the App , you have the right to request removal of unwanted data that youpublicly post on the App . To request removal of such data, please contact us usingthe contact information provided below, and include the email address associatedwith your account and a statement that you reside in California. We will make surethe data is not publicly displayed on the App , but please be aware that the data maynot be completely or comprehensively removed from all our systems (e.g. backups,etc.). 8. DO WE MAKE UPDATES TO THIS NOTICE? In Short: Yes, we will update this notice as necessary to stay compliant withrelevant laws. We may update this privacy notice from time to time. The updated version will beindicated by an updated "Revised" date and the updated version will be effective assoon as it is accessible. If we make material changes to this privacy notice, we maynotify you either by prominently posting a notice of such changes or by directlysending you a notification. We encourage you to review this privacy notice frequentlyto be informed of how we are protecting your information. 9. HOW CAN YOU CONTACT US ABOUT THIS NOTICE? If you have questions or comments about this notice, you may email us at smcmblvme@gmail.com or by post to:Cape Town , Western Cape 7441 South Africa 10. HOW CAN YOU REVIEW, UPDATE, OR DELETE THEDATA WE COLLECT FROM YOU? Based on the applicable laws of your country, you may have the right to requestaccess to the personal information we collect from you, change that information, or delete it in some circumstances.