Circle European Privacy Policy

This Privacy Policy was updated on, and its effective date is: December 21, 2023.

This European Privacy policy contains information on how we collect, store, process, transfer, share use data that identifies or is associated with residents of the European Economic Area (“EEA”), Switzerland, and the United Kingdom (“UK”) (“personal data”) and information regarding our use of cookies and similar technologies. This European Privacy Policy applies solely to residents of the EEA, Switzerland, and the UK (“you”). Please ensure that you have read and understood this European Privacy Policy before accessing or using the Website, App, or Services. Unless otherwise expressly stated, all terms in this section have the same meaning as defined in our Privacy Policy or as otherwise defined in the General Data Protection Regulation (“GDPR”).

Who is responsible for your personal data

We process most of the personal data that customers and their users upload to the Services as a processor on behalf of the relevant customer. This means that the relevant customer determines and is responsible for how we process that personal data. If a customer has uploaded your personal data to our Services, you should consult that customer's privacy notice (either on their website or as otherwise provided to you) for information about how that personal data is used.

We do, however, process some personal data as a controller as described in our Privacy Policy and this European Privacy Policy. This means that, with respect to the processing of personal data described in our Privacy Policy and this European Privacy Policy, CircleCo, Inc determines and is responsible for how your personal data is used.

How to contact us

Please contact if you have any questions, comments and requests regarding this European Privacy Policy.

Personal Data We Collect From You When You Use the Services and How We Use It


Prospective Customers

When you contact us to express an interest in our Services or with a query about becoming a customer of our Services, we will collect the following personal data:

When you sign up for a free trial, we will collect your contact information, such as your name and email address and the date on which you signed up for a free trial.

Customer Admins

When you sign up to our Services as a customer, or if a customer designates you as an admin user on their account, we will collect the following personal data:

If you are the customer (i.e. if you sign up to the Services or a free trial as a customer in your personal capacity rather than as an admin on behalf of a customer), we will also collect the following information:

All customer users

Prospective customers and all customer users

Information We Collect About You Automatically

We also automatically collect personal data indirectly about how you access and use the Website, App, or Services, and information about the device you use to access the Website, App, or Services, or otherwise engage with us. We collect the following information in this way:

We may link or combine the personal data you provide and the information we collect automatically. This allows us to provide you with a personalised experience regardless of how you interact with us.

We may anonymise and aggregate any of the personal data we collect (so that it does not directly identify you), and may use the anonymised and aggregated information or disclose it as set out in our Privacy Policy.

Cookies and Similar Technologies Used on Our Website, App and Services

Our Website, App and Services use cookies and similar technologies such as pixels and Local Storage Objects (LSOs) like HTML5 (together “cookies”) to distinguish you from other users of our Website, App, and Services. This helps us to provide you with a good experience when you browse our Website, App, or Services and also allows us to monitor and analyse how you use and interact with our Website, App, or Services so that we can continue to improve our Website, App, and Services. It also helps us determine products and services that may be of interest to you. Please see our Cookie Policy for more information about these practices and your choices regarding cookies.

How Long Will We Store Your Personal Data

We will usually store the personal data we collect about you for no longer than the following:

Recipients of Personal Data

We may share your personal data as follows:

Marketing and Advertising

Promotional emails

From time to time we may contact you with information about our products and services, including sending you marketing messages and asking for your feedback on our products and services.

For some marketing messages, we may use personal data we collect about you to help us determine the most relevant marketing information to share with you.

We will only send you marketing messages if you have given us your consent to do so. You can withdraw your consent at a later date by clicking on the “unsubscribe” link at the bottom of our marketing emails or by updating your preferences via the App settings.

Online advertising

We work with online advertising networks and advertising partners to tailor the ads played or displayed to you on our Website, App and Services and on other websites, apps, or services. The ads you see online are tailored to your interests based on information collected about you, including information about your age, demographic, location, as well information about your internet usage over time, such as the websites you visit, the products and pages you view and the links you click on (including links in ads played or displayed to you).

Typically, this information is collected through cookies or similar tracking technologies. When you visit the Website, App or Services we will, if you give us your consent to do so, place cookies and similar tracking technologies on your device to:

We may use certain forms of display advertising and other advanced features through third party service providers like Google Universal Analytics, such as Remarketing with Google Analytics, Google Display Network Impression Reporting, the DoubleClick Campaign Manager Integration, and Google Analytics Demographics and Interest Reporting. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick advertising cookie) or other third-party cookies together to inform, optimize, and display ads based on your past visits to the Site. You can opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at

You may learn more about Google’s practices with Google Analytics by visiting Google’s privacy policy at You can also view Google’s currently available opt-out options at

Controlling the ads you see online

Please see our Cookie Policy for details of the third parties that collect information about your use of the Website, App and Services for advertising purposes.

We will only collect and share information about your use of the Website, App and Services for advertising purposes to the extent you have given us your consent to do so.

Withholding or withdrawing consent, or opting out of the use of advertising cookies, will mean that information about your use of the Website, App and Services will not be shared with advertising networks to allow us to target advertising on other websites.

If you opt-out of advertising by opting out of the use of, or withholding or withdrawing your consent to advertising cookies, you will still get ads when you browse the internet, and those ads may still be relevant to your interests. However, this advertising may be based on the content of the site you visit or, for advertising on social media, your approximate location or demographic information associated with your social media profile, rather than your recent browsing activity. As a result, you may still see advertising relevant to your location, demographic or other information on the websites you visit even if you reject cookies on the Website, App or Services.

Storing and Transferring Your Personal Data

Security. We implement appropriate technical and organisational measures to protect your personal data against accidental or unlawful destruction, loss, change or damage. We will never send you unsolicited emails or contact you by phone requesting your account ID, password, credit or debit card information or national identification numbers.

International Transfers of Your Personal Data. The personal data we collect may be transferred to and stored in countries outside of the jurisdiction you are in where we and our third-party service providers have operations, including in the United States.

In the event of such a transfer, we ensure that: (i) the personal data is transferred to countries recognised as offering an equivalent level of protection (“Adequacy”); or (ii) the transfer is made pursuant to appropriate safeguards, such as standard data protection clauses adopted by the European Commission or approved under the UK Data Protection Act 2018 (“Standard Contractual Clauses”). When we transfer your personal data to recipients in the United States, we ensure that such transfers are:

If you wish to enquire further about these safeguards used, please contact us using the details set out in the “How to Contact Us” section above.

Your Rights in Respect of Your Personal Data

In accordance with applicable privacy law, you have the following rights in respect of your personal data that we hold:

Right of access. You have the right to obtain.

Right of portability. You have the right, in certain circumstances, to receive a copy of the personal data you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your personal data to another person.

Right to rectification. You have the right to obtain rectification of any inaccurate or incomplete personal data we hold about you without undue delay.

Right to erasure. You have the right, in some circumstances, to require us to erase your personal data without undue delay if the continued processing of that personal data is not justified.

Right to restriction. You have the right, in some circumstances, to require us to limit the purposes for which we process your personal data if the continued processing of the personal data in this way is not justified, such as where the accuracy of the personal data is contested by you.

Right to withdraw consent. If you have provided consent for the processing of your personal data, you have the right to withdraw your consent. If you withdraw your consent, this will not affect the lawfulness of our use of your personal data before your withdrawal.

You also have the right to object to any processing based on our legitimate interests where there are grounds relating to your particular situation. There may be compelling reasons for continuing to process your personal data, and we will assess and inform you if that is the case. You can object to marketing activities for any reason.

You also have the right to lodge a complaint to your local data protection authority. Information about how to contact your local data protection authority is available here.

If you wish to exercise one of these rights, please contact us using the contact details at the end of this European Privacy Policy.

Due to the confidential nature of data processing, we may ask you to confirm your identity when exercising the above rights.

Changes to This European Privacy Policy

We may update this European Privacy Policy from time to time and so you should review this page periodically. When we change this European Privacy Policy in a material way, we will update the “Effective Date“ above. Changes to this European Privacy Policy are effective when they are posted on this page.