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Legal
Legal
Privacy Policy
Privacy Policy
Privacy Policy
Privacy Policy
Last update:
Last update:
Last update:
June 1 ,2026
June 1 ,2026
June 1 ,2026
This Privacy Policy applies to Personal Information processed by us, including on our website located at Cirqul.com (the “Site”), our mobile device application (the “App”), and other online and offline products, tools, and offerings (collectively the “Services”). This Privacy Policy also includes information required under federal and state financial privacy laws regarding our collection of nonpublic personal information (“NPI”) collected in connection with providing our products and services. For purposes of this Privacy Policy, Personal Information includes NPI, except as noted in the section entitled Privacy Notice under Federal and State-Specific Privacy Laws.
By using, accessing or submitting information through the Services, you agree to the terms of Cirqul’s Privacy Policy. Cirqul’s Privacy Policy does not apply to any third-party websites, services or applications, even if they are accessible through our Services. Also, please note that, unless we define a term in this Privacy Policy, all capitalized terms used in this Privacy Policy have the same meanings ascribed to them in our Terms of Use. So, please make sure that you have read and understand our Terms of Use.
Our Site and App may contain links or direct you to websites and services that are owned or operated by third-parties. Any information that you provide to a third-party or that is collected by a third-party is subject to their privacy policy, not this Privacy Policy. We’re not responsible for the content, privacy or security practices and policies of any third-party. To protect your information, we recommend that you carefully review the privacy policies of all third-party websites and services that you access.
Information We Collect or Receive From You.
When you use the Services, we may collect Personal Information and other information from you as further described below.
Cirqul Account Information.
When you create a Cirqul Account, we’ll collect certain information that can be used to identify you, such as your name, email address, physical address and phone number. For compliance purposes related to some of our Services, and in order to provide those Services to you, we may request and collect your social security number, date of birth, and annual income.
External Bank Account.
If you want to link an external bank account that you hold with a U.S. financial institution (“Bank Account”) to your Cirqul Account, we will collect certain information from you about your Bank Account, such as your online login credentials, for the purposes of providing the Services to you. If you give us access to your Bank Account, you acknowledge and agree that we will have access to your transaction information, amount of funds, and other information about you and your Bank Account that may be available through the online settings for your Bank Account or otherwise through the relevant financial institution (“Financial Information”) that we require in order to provide the Services to you. Cirqul uses a third-party service provider, to retrieve information from your linked Bank Account. Our service provider offers a secure method of transmitting your banking information, and Cirqul does not see or store your bank credentials through this service. Banking information shared with us may include, among other things, ACH information (account and routing numbers), transaction data, identity verification information and account balance details. By utilizing these services, you acknowledge and agree that our service provider's privacy policy will govern their collection and use of such information, and you consent to their privacy policy. Further, you expressly grant our service provider the right, power, and authority to access and transmit your information as reasonably necessary to provide these services.
Purchases.
We may collect Personal Information and details associated with your purchases, including payment information. Any payments made to us are processed by third-party payment processors. We do not directly collect or store any payment card information you provide, but we may receive information associated with your payment card information (e.g., your billing details).
Verification Information.
For compliance purposes and in order to provide the Services to you, we may obtain information from you or a third party, including the financial institution providing your Bank Account, to help us to verify your identity or Bank Account details. For example, we may ask you to provide a copy of your government-issued photo ID, a copy of a utility bill or bank statement, or such other documentation that contains Personal Information.
In order to determine your eligibility to access certain Services, we’ll need to collect Bank Account information and other Personal Information as required by United States Federal law such as citizenship, employment and residence information, and social security number.
Your Communications with Cirqul.
We may collect Personal Information, such as email address, phone number, or mailing address when you request information about our Services, register for our newsletter or referral program, request customer or technical support, apply for a job, or otherwise communicate with us.
Surveys.
We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information which may include Personal Information.
Interactive Features.
We and others who use our Services may collect Personal Information that you submit or make available through our interactive features (e.g., messaging and chat features, commenting functionalities, forums, blogs, and social media pages). This includes questions, prompts, documents and other content that you input, upload or submit to the Services. This also includes any outputs that you generate using the Services, including any collections, pages, or responses that are produced using the Services, such as through Cirqul AI. Any information you provide using the public sharing features of the Services (referred to herein as “User Content”) will be considered “public,” unless otherwise required by applicable law, and is not subject to the privacy protections referenced herein.
Cirqul AI.
Our AI (known as “CARA”) is an artificial intelligence service that can help you on your financial journey, set up a budget and spending plan, and answer general financial questions. If you use the AI, we may collect Personal Information as part of the Service, including basic Cirqul Account information (name, email address, birthday), your social security number and other “KYC” information required by law, information from documents you provide, and other information associated with your financial planning and budgeting, such as your income, expenses, credit score, investments, insurance, taxes, debts, and liabilities. Your interactions will be recorded and analyzed together with any data that is submitted to provide, maintain and improve this Service, including to generate new content as part of this Service. The data collected by the AI may be used to provide you with offers for products or services. This data may be disclosed to our service providers as specified in the section entitled “Information that We Share with Third Parties”.
Job Applications.
We may post job openings and opportunities on our Site. If you reply by submitting your application, CV and/or cover letter to us, we will collect and use your information to assess your qualifications, as described in the relevant privacy notice posted with the job opening.
Information Collected Using Cookies and Other Web Technologies.
Like many website owners and operators, we use automated data collection tools such as Cookies and Web Beacons to collect certain information in order to help improve our Services and provide you with a more convenient and customized experience.
“Cookies” are small text files that are placed on your device by a Web server when you access our Services. We may use both session Cookies and persistent Cookies to identify that you’ve logged in to the Services and to tell us how and when you interact with our Services. We may also use Cookies to monitor aggregate usage and web traffic routing on our Services and to customize and improve our Services. Unlike persistent Cookies, session Cookies are deleted when you log off from the Services and close your browser. Although most browsers automatically accept Cookies, you can change your browser options to stop automatically accepting Cookies or to prompt you before accepting Cookies. Please note, however, that if you don’t accept Cookies, you may not be able to access all portions or features of the Services. Some third-party service providers that we engage may also place their own Cookies on your device for functional and analytics purposes.
“Beacons” (also known as Web bugs, pixel tags or clear GIFs) are tiny graphics with a unique identifier that may be included on our Services for several purposes, including to deliver or communicate with Cookies, to track and measure the performance of our Services, to monitor how many visitors view our Services, and to monitor the effectiveness of our advertising. Unlike Cookies, which are stored on the user’s hard drive, Web Beacons are typically embedded invisibly on web pages (or in an e-mail).
See “Your Choices” below to understand your choices regarding these Cookies and Web Beacons (collectively, “Technologies”).
Information From Using Our Services.
Our servers automatically record certain information about how our users (each, a “User”) use our Services (we refer to this information as “Log Data”). Log Data may include information such as a User’s Internet Protocol (IP) address, user settings, browser type, operating system, device identifiers, the web page that a User was visiting before accessing our Services, the pages or features of our Services to which a User browsed and the time spent on those pages or features, search terms, the links on our Services that a User clicked on and other statistics. We use Log Data to administer the Services and we analyze (and may engage third parties to analyze) Log Data to improve, customize and enhance our Services by expanding their features and functionality and tailoring them to our Users’ needs and preferences.
Analytics.
We may use third party data collection tools to provide us with analytics data regarding Users’ interactions with our Services, including:
Google Analytics. Please visit Google Analytics’ Privacy Policy to learn more about how to opt-out of Google Analytics’ use of your information.
Information Sent by or Collected From Your Mobile Device.
We collect certain information that your mobile device sends when you use our Services. For example, we may collect a device identifier, user settings and the operating system of your device, as well as information about your use of our Services. With your consent we may access, collect, and store the names, phone numbers, and email addresses associated with your phone contacts.
Location Information.
When you use our App, we may collect and store information about your location by converting your IP address into a rough geo-location or by accessing your mobile device’s GPS coordinates or coarse location if you enable location services on your device. We may use location information to improve and personalize our Services for you. If you do not want us to collect location information, you may disable that feature on your mobile device.
Social Media Platforms.
Our Site may contain social media buttons such as Facebook, Instagram, Snapchat, and Twitter (that might include widgets such as the “share this” button or other interactive mini programs). These features may collect your IP address, which page you are visiting on our Services, and may set a Cookie to enable the feature to function properly. Your interactions with these platforms are governed by the privacy policy of the company providing it.
Biometric Information.
To verify your identity, and if you consent, we may engage third-party vendors that collect facial geometry information from a selfie you submit to determine whether it matches your photo from a government-issued form of identification. If you allow the collection of that information, you consent to collection of your biometric information and biometric identifiers, including facial geometry, by our designated third-party vendor and that such provider can use such information and identifier for identity verification and compliance with applicable laws and as set forth in the third-party vendor’s privacy policy. We do not directly collect or store any biometric information entered through our Services, but we retain a record of your consent (which we share with our vendor) and may receive information associated with your identity verification from our vendor. We do not receive or store your facial geometry and only receive a verification from our vendor of whether the selfie and government identification photos match.
Information Collected from Other Sources.
We may obtain information about you from other sources, including through third-party services and organizations. For example, if you access our Services through a third-party application, such as an app store, a third-party login service, or a social networking site, we may collect information about you from that third-party application that you have made available via your privacy settings. When you give your consent to obtain your credit score we may also obtain your credit history from consumer reporting agencies.
How We Use Personal Information
We use Personal Information for a variety of business purposes, including to provide our Services, for administrative purposes, and to market our products and Services, as described below.
Providing Our Services.
We use your information to fulfill our contract with you and provide you with our Services, such as:
Managing your information and accounts;
Providing access to certain areas, functionalities, and features of our Services;
Answering requests for customer or technical support;
Communicating with you about your account, activities on our Services, and policy changes;
Processing your financial information and other payment methods for products or subscriptions purchased;
Processing applications if you apply for a job we post on our Services; and
Allowing you to register for events.
Administrative Purposes.
We use your information for various administrative purposes, such as:
Pursuing our legitimate interests such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;
Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;
Measuring interest and engagement in our Services;
Short-term, transient use, such as contextual customization of ads;
Improving, upgrading or enhancing our Services;
Developing new products and Services;
Ensuring internal quality control and safety;
Authenticating and verifying individual identities, including requests to exercise your rights under this policy or access our Services;
Debugging to identify and repair errors with our Services;
Administering and/or fulfilling any sweepstakes, contests, or giveaways we sponsor;
Auditing relating to interactions, transactions and other compliance activities;
Enforcing our agreements and policies; and
Complying with our legal obligations.
Marketing and Advertising our Products and Services.
In accordance with applicable law, we may use your Personal Information, including your credit history when you request your credit score or enroll in Identity Watcher, to tailor and provide you with content and advertisements, including offers for additional Services (collectively, the “Content”). We may provide you with such Content as permitted by applicable law.
Some of the ways we market to you include email campaigns, SMS, and in-app communications. If you have any questions about our marketing practices, you may email us at support@cirqul.com.
Other Purposes.
We also use your information for other purposes as requested by you or as permitted by applicable law.
Consent. We may use Personal Information for other purposes that are clearly disclosed to you at the time you provide Personal Information or with your consent.
Decision Making. Our Services may provide you with automated decision making, including profiling. Our processing of your personal information will not result in a decision based solely on automated processing that significantly affects you unless such a decision is necessary as part of a contract we have with you, we have your consent, or we are permitted by law to engage in such automated decision making. If you have questions about our automated decision making, you may contact us as described below.
Provide our services. We record and use the responses, information, and Personal Information you share with Cirqul to provide our Services.
Aggregated Information. We may use Personal Information and other information about you to create aggregated information, such as demographic information, information about the device from which you access our Site, or other analytics we create.
Share Content with Friends or Colleagues. Our Services may offer various tools and functionalities. For example, we may allow you to provide information to your friends about Cirqul. Please only provide us with contact information of people with whom you have a relationship (e.g., relative, friend, neighbor, or co-worker).
Information that We Share with Third Parties
We do not sell your Personal Information. We share Personal Information that we have collected from or regarding you as described below:
Opt In Data.
Subscriber text messaging originator opt-in data and consent details will not be shared with any third parties except when explicitly authorized by you.
Information Shared with Our Service Providers.
We may engage service providers to work with us to administer, market and provide the Services. These service providers have access to your Personal Information and Financial Information only for the purpose of performing services on our behalf.
We may also provide you with the ability to interact with and provide information to our service providers. When you leave our App or Site to interact with another service provider, you should also read their privacy policy to understand their privacy practices and how it relates to how they collect and share the information you provide.
Information Shared with our Business Partners and Affiliates.
We may share your Personal Information with business partners to provide you with a product or service you have requested or business partners with whom we jointly offer products or services. We may share your Personal Information with our company affiliates for our administrative purposes, including activities such as IT management, for them to provide services to you or support and supplement the Services we provide.
Information Shared with our Marketing Partners.
Some of the service providers we use provide us with analytics and performance reporting tools that help us understand how users interact with our Services and measure the effectiveness of our communications. These service providers access limited usage data solely to perform analytics services on our behalf, pursuant to written agreements that restrict further use or disclosure of that data.
Information Shared through APIs/SDKs.
We may use third-party Application Program Interfaces (“APIs”) and Software Development Kits (“SDKs”) as part of the functionality of our Services.
Information Shared with Large Language Model Providers.
We may share your Personal Information, including chat prompts, linked account information, and information from documents you upload, with large language model providers in a closed and secure environment in order to provide the Services, such as analyzing your inputs and providing responses. Your Personal Information will not be used to train those providers’ artificial intelligence models.
Aggregated Information Shared with Other Third Parties.
We may share aggregated information and non-identifying information with third parties for industry research and analysis, demographic and other similar purposes. For example, we may use aggregated and non-identifying information to derive statistics about the spending habits of our users, our users’ financial choices, and to publish blog posts, articles, or other communications on our Site and social media channels.
Information Disclosed in Connection with Company Transactions.
Information that we collect from our users, including Personal Information, is considered to be a business asset. Thus, if we are acquired by a third party as a result of a transaction such as a merger, acquisition or asset sale or if our assets are acquired by a third party in the event we go out of business or enter bankruptcy, some or all of our assets, including your Personal Information, may be disclosed or transferred to a third party acquirer in connection with the transaction.
Information Disclosed for Our Protection and the Protection of Others.
We cooperate with government and law enforcement officials or private parties to enforce and comply with the law. We may disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate: (i) to respond to claims, legal process (including subpoenas); (ii) to protect our property, rights and safety and the property, rights and safety of a third party or the public in general; and (iii) to stop any activity that we consider illegal, unethical or legally actionable activity.
Privacy Notice Under Federal And State Financial Privacy Laws
Certain Personal Information that we collect from you or otherwise obtain about you in connection with providing our Services, including information from any transaction involving a financial product or service we provide, is referred to in this Privacy Policy as NPI and is subject to federal financial privacy laws and, as described below, certain state financial privacy laws as well (collectively, “Financial Privacy Laws”). This section provides certain required disclosures and informs you of your rights under those Financial Privacy Laws, which may differ from your rights under other privacy laws.
Financial companies choose how they share your NPI. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your Personal Information that constitutes NPI.
The NPI we collect and share depends on the product or service you have with us. This information may include Personal Information described in the section entitled Information Collected or Received from You, such as the following:
Social Security number, date of birth, postal address, and email address
Annual income
Account and routing numbers
Account balances and transaction data
Credit history when you request your credit score or enroll in our product or service.
We collect this Personal Information directly from you, from your transactions with Cirqul, from your transactions with nonaffiliated third parties, and from consumer reporting agencies.
We share your NPI with certain Affiliates and third parties, such as our service providers, to run our everyday business and as required by law, and as generally described in the section entitled Information that We Share with Third Parties. We also share NPI with third party financial institutions for joint marketing. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons we choose to share; and whether you can limit this sharing. For purposes of this section of this Privacy Policy, the following definitions apply:
“Affiliates” means companies related by common ownership or control. They can be financial and nonfinancial companies.
“Nonaffiliates” means companies not related by common ownership or control with Cirqul. They can be financial and nonfinancial companies. We do not share with nonaffiliates so they can market to you.
“Joint marketing” means a formal agreement between nonaffiliated companies that together market products or services to you. Our joint marketers may include financial service providers, non-financial companies, and other businesses.
Reasons we can share your personal information | Do we share? | Can you limit this sharing? |
For our everyday business purposes— such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus | Yes | No |
For our marketing purposes— | Yes | No |
For joint marketing with other financial companies | Yes | No |
For our affiliates’ everyday business purposes— information about your transactions and experiences | Yes | No |
For our affiliates to market to you— including, based on information about your creditworthiness | Yes | Yes |
For nonaffiliates to market to you— about our products and services. | No | We don’t share |
To review your options for limiting the sharing of information, see Your Choices below. If you have any questions, you may email us at support@cirqul.com.
We protect your NPI from unauthorized access and use. In that regard, we use reasonable security measures that comply with applicable law. These measures include computer safeguards and secured files and buildings.
Certain state laws require additional disclosures as set forth below (these only apply to Personal Information subject to those laws):
For Nevada residents only. Nevada law requires that we provide you with the following contact information: Bureau of Consumer Protection, Office of the Nevada Attorney General, 555 E. Washington Ave., Suite 3900, Las Vegas, NV 89101; Phone number: 702-486-3132; Email: agInfo@ag.nv.gov
Under Vermont law, we will not share information we collect about Vermont residents with companies outside of our corporate family, unless the law allows it. For example, we may share information with your consent, to service your accounts or under joint marketing agreements with other financial institutions with which we have joint marketing agreements. We will not share information about your creditworthiness within our corporate family except with your consent, but we may share information about our transactions or experiences with you within our corporate family without your consent.
Under California law, we will not share information we collect about you with companies outside of Cirqul, unless the law allows it. For example, we may share information with your consent, to service your accounts, or to provide rewards or benefits you are entitled to. We will limit sharing among our companies to the extent required by California law.
California Privacy Rights
Collection and Use of Personal Information.
This Supplemental California Privacy Notice only applies to our processing of Personal Information that is subject to the California Consumer Privacy Act of 2018 (as amended) (“CCPA”). The CCPA provides California residents with the right to know what categories of personal information CIRQUL has collected about them, whether Cirqul disclosed that personal information for a business purpose (e.g., to a service provider), whether Cirqul “sold” that personal information, and whether Cirqul “shared” that personal information for “cross-context behavioral advertising” in the preceding twelve months. California residents can find this information below:
Category of Personal Information Collected by CIRQUL | Category of Third Parties Information is Disclosed to for a Business Purpose | Category of Personal Information That is Shared |
Identifiers
|
|
|
Protected classification characteristics under California or federal law
|
| Not Applicable |
Commercial information
|
| Not Applicable |
Internet or other electronic network activity Interaction with internet websites, mobile applications, or advertisements |
| Not Applicable |
Geolocation data Rough location of person or mobile device derived from Internet Protocol address |
| Not Applicable |
Professional or employment-related information Current or past job history |
| Not Applicable |
Inferences drawn from other Personal Information to create a profile about a consumer
|
| Not Applicable |
Category of Sensitive Personal Information Collected by CIRQUL | Category of Third Parties Information is Disclosed to for a Business Purpose | Category of Personal Information That is Shared |
Sensitive identifiers
|
| Not Applicable |
Financial Information
Personal Information does not include publicly available information that is lawfully made available to the general public from federal, state, or local government records. Note: Some Personal Information included in this category may overlap with other categories. |
| Not Applicable |
Biometric information
|
| Not Applicable |
“Sales” and “Sharing” Personal Information under the CCPA.
Cirqul does not sell your Personal Information for monetary consideration, as that term is defined in Cal. Civ. Code § 1798.140(t). Cirqul does not share your Personal Information for cross-context behavioral advertising, as that term is defined in Cal. Civ. Code § 1798.140(ah). We disclose Personal Information to service providers and contractors solely for the purpose of operating our platform and providing our Services, pursuant to written contracts that restrict further use.
Disclosure Regarding Individuals Under the Age of 16. Cirqul does not have actual knowledge of any “sale” of personal information of minors under 16 years of age. Cirqul does not have actual knowledge of any “sharing” of personal information of minors under 16 years of age for “cross-context behavioral advertising.”
Non-Discrimination.
California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA.
Authorized Agent.
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child. To designate an authorized agent, please contact us as at support@cirqul.com.
Verification.
To protect your privacy, we will take the following steps to verify your identity before fulfilling your requests submitted under the CCPA. When you make a request and as part of the verification process, we will ask you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative, which may include asking you to answer questions regarding your account and use of our Services.
If you are a California resident and would like to exercise any of your rights under the CCPA, please contact us as support@cirqul.com. We will process such requests in accordance with applicable laws.
California Opt-Out Rights.
Because Cirqul does not sell or share Personal Information for cross-context behavioral advertising, California residents are not required to opt out of any such activity. If our practices change in the future, we will update this Privacy Policy to reflect any applicable opt-out rights before those practices begin.
Disclosure Regarding Use of Sensitive Personal Information.
Cirqul only uses and discloses sensitive personal information for the following purposes:
To perform the Services reasonably expected by an average consumer who requests such Services.
To prevent, detect, and investigate security incidents that compromise the availability, authenticity, integrity, and or confidentiality of stored or transmitted personal information.
To resist malicious, deceptive, fraudulent, or illegal actions directed at Cirqul and to prosecute those responsible for those actions.
For short-term, transient use.
To verify or maintain the quality or safety of a product, service, or device that is owned, manufactured, manufactured for, or controlled by Cirqul, and to improve, upgrade, or enhance the service or device that is owned, manufactured by, manufactured for, or controlled by Cirqul.
For purposes that do not infer characteristics about individuals.
Right for Minors to Remove Posted Content.
Where required by law, California residents under the age of 18 may request to have their posted content or information removed from the publicly-viewable portions of the Services by logging into their Cirqul Account and removing the content or information using our self-service tools.
Nevada Privacy Rights.
If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Information to third parties who intend to license or sell that Personal Information. Please note that we do not currently sell your Personal Information as sales are defined in Nevada Revised Statutes Chapter 603A. If you would like to request that we do not sell your Personal Information going forward, please email support@cirqul.com with the subject line “Nevada Do Not Sell Request” and provide us with your name and the email address associated with your account.
Your Choices.
We offer you choices regarding the collection, use and sharing of your Personal Information. Please note that if you decide not to provide us with the Personal Information that we request, you may not be able to access all of the features of the Services.
Communications and Opt-Out.
Our main form of communication with you will be via SMS / text message, but we may also send you push notifications and/or emails from time to time. Communications from us may include notifying you about account related information or updates on a technical or customer support request that you submitted. We may periodically send you free newsletters, e-mails and notifications on your mobile device that promote our Services. When you receive such promotional communications from us, you will have the opportunity to “opt-out” (either through your CIRQUL Account or by following the unsubscribe instructions provided in the e-mail you receive). To opt out of receiving communications sent by Cirqul through text messages, you can text “Stop” to the message you have received from Cirqul. However, we need to send you certain communications regarding the Services and you will not be able to opt out of those communications – e.g., verifying updates or changes to your account information, updates to our Terms of Use or Cirqul’s Privacy Policy.
Cookies and Interest-Based Advertising.
You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, our Services may not work properly. Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt-out of personalized advertisements on some mobile applications by following the instructions for Android, iOS and others.
Your Privacy Rights.
In accordance with applicable law, you may have the right to:
Access Personal Information about you, including: (i) confirming whether we are processing your Personal Information; (ii) obtaining access to or a copy of your Personal Information in a structured, commonly used, and machine readable format; and (iii) receiving an electronic copy of Personal Information that you have provided to us, or asking us to send that information to another company in a structured, commonly used, and machine readable format (the “right of data portability”);
Request Correction of your Personal Information where it is inaccurate or incomplete. In some cases, we may provide self-service tools that enable you to update your Personal Information;
Request Deletion of your Personal Information;
Request Restriction of or Object to our processing of your Personal Information;
Request to Opt-Out of certain processing activities including, as applicable, if we process your personal information for “targeted advertising” (as “targeted advertising” is defined by applicable privacy laws), if we “sell” your personal information (as “sell” is defined by applicable privacy laws), or if we engage in profiling in furtherance of certain decisions that produce legal or similarly significant effects concerning you;
Withdraw your Consent to our processing of your Personal Information; and
Object to our processing of your personal data in Automated Individual Decision-Making;
Appeal our decision to decline to process your request.
To exercise the rights described above, please email us at privacy@cirqul.com.
Data Transfers.
Your Personal Information may be transferred to and maintained on computers located outside of your state or the United States, where the privacy laws may not be as protective as those in your jurisdiction. Please note our Services are currently designed for individuals based in the United States. If you’re located outside the United States while accessing the Services and choose to provide your Personal Information to us, we may transfer your Personal Information to the United States and process it there.
Retention of Your Information.
We store the personal information we collect as described in this Privacy Policy for as long as you use our Services, or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.
Deleting Personal Information.
Subject to the exceptions and conditions described in this section, you have the right to request that Cirqul delete personal information we have collected from you and, where applicable, to direct our service providers and contractors to delete your personal information.
This right applies to residents of California, Virginia, Colorado, Connecticut, Texas, Nevada, and other states that have enacted comprehensive consumer privacy legislation. Cirqul extends these rights to all users located in the United States on a voluntary basis, regardless of state residency.
To delete your personal information, you may submit a verified request to delete your personal information through one of the following methods:
Mail In Request: Submit your written request via mail to Cirqul, Attn. Deletion Request, 40 S. Stephanie Street #101, Henderson, NV 89012. Your written request must include your full name, email address associated with your account, and a description of the information you wish to have deleted.
Email: Send a written request to privacy@cirqul.com with “Deletion Request” in the subject line. Include your full name, email address associated with your account, and a description of the information you wish to have deleted.
Cirqul does not require you to create an account in order to submit a deletion request. If you do not have an account, please use the email method described above.
To protect your personal information and prevent unauthorized deletion, Cirqul is required to verify your identity before processing a deletion request.
For registered account holders: We will verify your identity by matching the information provided in your request against the information associated with your account. We may send a verification link or one-time passcode to the email address or phone number on file.
For individuals without an account: We will verify your identity by requesting at least two pieces of personal information that we can match against our records (such as your name, email address, phone number, or ZIP code).
If we are unable to verify your identity with a reasonable degree of certainty, we will inform you that we cannot process your request and explain the basis for this determination.
We will acknowledge receipt of your deletion request within ten (10) business days of receiving it. We will confirm the deletion or, if an exception applies, provide you with an explanation within forty-five (45) calendar days of receiving your verified request. If we require additional time, we will notify you of the extension and the reason for it within the initial 45-day period. Under California law, we may extend our response period by an additional 45 days (for a total of 90 days) where reasonably necessary, provided we give you prior notice.
Upon verification and absent an applicable exception, Cirqul will delete your personal information from our active systems. Please note that deletion of your personal information will result in the deactivation of your Cirqul account and may prevent you from using certain features or services that depend on that information.
When We May Retain Your Information.
Cirqul is not required to delete your personal information if retaining it is necessary for us to:
Complete a transaction for which the personal information was collected, provide a good or service requested by you, collect on a debt, or otherwise perform a contract between you and Cirqul;
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activity;
Debug and repair errors that impair existing intended functionality;
Exercise free speech, ensure the right of another consumer to exercise free speech, or exercise another right provided for by law;
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et seq.) or other applicable law;
Comply with a legal obligation, including but not limited to applicable financial record keeping requirements, tax law, and regulatory obligations; or
Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.
Where an exception applies, we will inform you that we cannot fulfill your deletion request in full or in part and will identify the specific exception(s) that prevent us from doing so.
Cirqul will not discriminate against you for exercising any of your privacy rights, including your right to delete. Note that some features or services may no longer be available to you after deletion of your account data, as those features are dependent on the information you have provided. This is a consequence of the deletion itself and does not constitute discrimination.
Nothing in this section requires Cirqul to delete information that has been de-identified or aggregated in a manner that can no longer reasonably identify, relate to, describe, be capable of being associated with, or reasonably linked to you or your household. Cirqul may retain de-identified or aggregated information derived from your data after deletion.
Our Policy Toward Children.
Our Services are not directed to children under 13 and we do not knowingly collect Personal Information from children under 13. If we learn that we have collected Personal Information of a child under 13 we will take steps to delete such information from our files as soon as possible.
Revisions to This Privacy Policy.
Any information that is collected via our Services is covered by the Privacy Policy in effect at the time such information is collected. We may revise this Privacy Policy from time to time. If we make any material changes to this Privacy Policy, we’ll notify you of those changes by posting them on the Services or by sending you an email or other notification and we’ll update the “Last Updated” date above to indicate when those changes will become effective.
Contact Us.
Please contact us via the “Connect” link on the Site, or via email at support@cirqul.com.
This Privacy Policy applies to Personal Information processed by us, including on our website located at Cirqul.com (the “Site”), our mobile device application (the “App”), and other online and offline products, tools, and offerings (collectively the “Services”). This Privacy Policy also includes information required under federal and state financial privacy laws regarding our collection of nonpublic personal information (“NPI”) collected in connection with providing our products and services. For purposes of this Privacy Policy, Personal Information includes NPI, except as noted in the section entitled Privacy Notice under Federal and State-Specific Privacy Laws.
By using, accessing or submitting information through the Services, you agree to the terms of Cirqul’s Privacy Policy. Cirqul’s Privacy Policy does not apply to any third-party websites, services or applications, even if they are accessible through our Services. Also, please note that, unless we define a term in this Privacy Policy, all capitalized terms used in this Privacy Policy have the same meanings ascribed to them in our Terms of Use. So, please make sure that you have read and understand our Terms of Use.
Our Site and App may contain links or direct you to websites and services that are owned or operated by third-parties. Any information that you provide to a third-party or that is collected by a third-party is subject to their privacy policy, not this Privacy Policy. We’re not responsible for the content, privacy or security practices and policies of any third-party. To protect your information, we recommend that you carefully review the privacy policies of all third-party websites and services that you access.
Information We Collect or Receive From You.
When you use the Services, we may collect Personal Information and other information from you as further described below.
Cirqul Account Information.
When you create a Cirqul Account, we’ll collect certain information that can be used to identify you, such as your name, email address, physical address and phone number. For compliance purposes related to some of our Services, and in order to provide those Services to you, we may request and collect your social security number, date of birth, and annual income.
External Bank Account.
If you want to link an external bank account that you hold with a U.S. financial institution (“Bank Account”) to your Cirqul Account, we will collect certain information from you about your Bank Account, such as your online login credentials, for the purposes of providing the Services to you. If you give us access to your Bank Account, you acknowledge and agree that we will have access to your transaction information, amount of funds, and other information about you and your Bank Account that may be available through the online settings for your Bank Account or otherwise through the relevant financial institution (“Financial Information”) that we require in order to provide the Services to you. Cirqul uses a third-party service provider, to retrieve information from your linked Bank Account. Our service provider offers a secure method of transmitting your banking information, and Cirqul does not see or store your bank credentials through this service. Banking information shared with us may include, among other things, ACH information (account and routing numbers), transaction data, identity verification information and account balance details. By utilizing these services, you acknowledge and agree that our service provider's privacy policy will govern their collection and use of such information, and you consent to their privacy policy. Further, you expressly grant our service provider the right, power, and authority to access and transmit your information as reasonably necessary to provide these services.
Purchases.
We may collect Personal Information and details associated with your purchases, including payment information. Any payments made to us are processed by third-party payment processors. We do not directly collect or store any payment card information you provide, but we may receive information associated with your payment card information (e.g., your billing details).
Verification Information.
For compliance purposes and in order to provide the Services to you, we may obtain information from you or a third party, including the financial institution providing your Bank Account, to help us to verify your identity or Bank Account details. For example, we may ask you to provide a copy of your government-issued photo ID, a copy of a utility bill or bank statement, or such other documentation that contains Personal Information.
In order to determine your eligibility to access certain Services, we’ll need to collect Bank Account information and other Personal Information as required by United States Federal law such as citizenship, employment and residence information, and social security number.
Your Communications with Cirqul.
We may collect Personal Information, such as email address, phone number, or mailing address when you request information about our Services, register for our newsletter or referral program, request customer or technical support, apply for a job, or otherwise communicate with us.
Surveys.
We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information which may include Personal Information.
Interactive Features.
We and others who use our Services may collect Personal Information that you submit or make available through our interactive features (e.g., messaging and chat features, commenting functionalities, forums, blogs, and social media pages). This includes questions, prompts, documents and other content that you input, upload or submit to the Services. This also includes any outputs that you generate using the Services, including any collections, pages, or responses that are produced using the Services, such as through Cirqul AI. Any information you provide using the public sharing features of the Services (referred to herein as “User Content”) will be considered “public,” unless otherwise required by applicable law, and is not subject to the privacy protections referenced herein.
Cirqul AI.
Our AI (known as “CARA”) is an artificial intelligence service that can help you on your financial journey, set up a budget and spending plan, and answer general financial questions. If you use the AI, we may collect Personal Information as part of the Service, including basic Cirqul Account information (name, email address, birthday), your social security number and other “KYC” information required by law, information from documents you provide, and other information associated with your financial planning and budgeting, such as your income, expenses, credit score, investments, insurance, taxes, debts, and liabilities. Your interactions will be recorded and analyzed together with any data that is submitted to provide, maintain and improve this Service, including to generate new content as part of this Service. The data collected by the AI may be used to provide you with offers for products or services. This data may be disclosed to our service providers as specified in the section entitled “Information that We Share with Third Parties”.
Job Applications.
We may post job openings and opportunities on our Site. If you reply by submitting your application, CV and/or cover letter to us, we will collect and use your information to assess your qualifications, as described in the relevant privacy notice posted with the job opening.
Information Collected Using Cookies and Other Web Technologies.
Like many website owners and operators, we use automated data collection tools such as Cookies and Web Beacons to collect certain information in order to help improve our Services and provide you with a more convenient and customized experience.
“Cookies” are small text files that are placed on your device by a Web server when you access our Services. We may use both session Cookies and persistent Cookies to identify that you’ve logged in to the Services and to tell us how and when you interact with our Services. We may also use Cookies to monitor aggregate usage and web traffic routing on our Services and to customize and improve our Services. Unlike persistent Cookies, session Cookies are deleted when you log off from the Services and close your browser. Although most browsers automatically accept Cookies, you can change your browser options to stop automatically accepting Cookies or to prompt you before accepting Cookies. Please note, however, that if you don’t accept Cookies, you may not be able to access all portions or features of the Services. Some third-party service providers that we engage may also place their own Cookies on your device for functional and analytics purposes.
“Beacons” (also known as Web bugs, pixel tags or clear GIFs) are tiny graphics with a unique identifier that may be included on our Services for several purposes, including to deliver or communicate with Cookies, to track and measure the performance of our Services, to monitor how many visitors view our Services, and to monitor the effectiveness of our advertising. Unlike Cookies, which are stored on the user’s hard drive, Web Beacons are typically embedded invisibly on web pages (or in an e-mail).
See “Your Choices” below to understand your choices regarding these Cookies and Web Beacons (collectively, “Technologies”).
Information From Using Our Services.
Our servers automatically record certain information about how our users (each, a “User”) use our Services (we refer to this information as “Log Data”). Log Data may include information such as a User’s Internet Protocol (IP) address, user settings, browser type, operating system, device identifiers, the web page that a User was visiting before accessing our Services, the pages or features of our Services to which a User browsed and the time spent on those pages or features, search terms, the links on our Services that a User clicked on and other statistics. We use Log Data to administer the Services and we analyze (and may engage third parties to analyze) Log Data to improve, customize and enhance our Services by expanding their features and functionality and tailoring them to our Users’ needs and preferences.
Analytics.
We may use third party data collection tools to provide us with analytics data regarding Users’ interactions with our Services, including:
Google Analytics. Please visit Google Analytics’ Privacy Policy to learn more about how to opt-out of Google Analytics’ use of your information.
Information Sent by or Collected From Your Mobile Device.
We collect certain information that your mobile device sends when you use our Services. For example, we may collect a device identifier, user settings and the operating system of your device, as well as information about your use of our Services. With your consent we may access, collect, and store the names, phone numbers, and email addresses associated with your phone contacts.
Location Information.
When you use our App, we may collect and store information about your location by converting your IP address into a rough geo-location or by accessing your mobile device’s GPS coordinates or coarse location if you enable location services on your device. We may use location information to improve and personalize our Services for you. If you do not want us to collect location information, you may disable that feature on your mobile device.
Social Media Platforms.
Our Site may contain social media buttons such as Facebook, Instagram, Snapchat, and Twitter (that might include widgets such as the “share this” button or other interactive mini programs). These features may collect your IP address, which page you are visiting on our Services, and may set a Cookie to enable the feature to function properly. Your interactions with these platforms are governed by the privacy policy of the company providing it.
Biometric Information.
To verify your identity, and if you consent, we may engage third-party vendors that collect facial geometry information from a selfie you submit to determine whether it matches your photo from a government-issued form of identification. If you allow the collection of that information, you consent to collection of your biometric information and biometric identifiers, including facial geometry, by our designated third-party vendor and that such provider can use such information and identifier for identity verification and compliance with applicable laws and as set forth in the third-party vendor’s privacy policy. We do not directly collect or store any biometric information entered through our Services, but we retain a record of your consent (which we share with our vendor) and may receive information associated with your identity verification from our vendor. We do not receive or store your facial geometry and only receive a verification from our vendor of whether the selfie and government identification photos match.
Information Collected from Other Sources.
We may obtain information about you from other sources, including through third-party services and organizations. For example, if you access our Services through a third-party application, such as an app store, a third-party login service, or a social networking site, we may collect information about you from that third-party application that you have made available via your privacy settings. When you give your consent to obtain your credit score we may also obtain your credit history from consumer reporting agencies.
How We Use Personal Information
We use Personal Information for a variety of business purposes, including to provide our Services, for administrative purposes, and to market our products and Services, as described below.
Providing Our Services.
We use your information to fulfill our contract with you and provide you with our Services, such as:
Managing your information and accounts;
Providing access to certain areas, functionalities, and features of our Services;
Answering requests for customer or technical support;
Communicating with you about your account, activities on our Services, and policy changes;
Processing your financial information and other payment methods for products or subscriptions purchased;
Processing applications if you apply for a job we post on our Services; and
Allowing you to register for events.
Administrative Purposes.
We use your information for various administrative purposes, such as:
Pursuing our legitimate interests such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;
Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;
Measuring interest and engagement in our Services;
Short-term, transient use, such as contextual customization of ads;
Improving, upgrading or enhancing our Services;
Developing new products and Services;
Ensuring internal quality control and safety;
Authenticating and verifying individual identities, including requests to exercise your rights under this policy or access our Services;
Debugging to identify and repair errors with our Services;
Administering and/or fulfilling any sweepstakes, contests, or giveaways we sponsor;
Auditing relating to interactions, transactions and other compliance activities;
Enforcing our agreements and policies; and
Complying with our legal obligations.
Marketing and Advertising our Products and Services.
In accordance with applicable law, we may use your Personal Information, including your credit history when you request your credit score or enroll in Identity Watcher, to tailor and provide you with content and advertisements, including offers for additional Services (collectively, the “Content”). We may provide you with such Content as permitted by applicable law.
Some of the ways we market to you include email campaigns, SMS, and in-app communications. If you have any questions about our marketing practices, you may email us at support@cirqul.com.
Other Purposes.
We also use your information for other purposes as requested by you or as permitted by applicable law.
Consent. We may use Personal Information for other purposes that are clearly disclosed to you at the time you provide Personal Information or with your consent.
Decision Making. Our Services may provide you with automated decision making, including profiling. Our processing of your personal information will not result in a decision based solely on automated processing that significantly affects you unless such a decision is necessary as part of a contract we have with you, we have your consent, or we are permitted by law to engage in such automated decision making. If you have questions about our automated decision making, you may contact us as described below.
Provide our services. We record and use the responses, information, and Personal Information you share with Cirqul to provide our Services.
Aggregated Information. We may use Personal Information and other information about you to create aggregated information, such as demographic information, information about the device from which you access our Site, or other analytics we create.
Share Content with Friends or Colleagues. Our Services may offer various tools and functionalities. For example, we may allow you to provide information to your friends about Cirqul. Please only provide us with contact information of people with whom you have a relationship (e.g., relative, friend, neighbor, or co-worker).
Information that We Share with Third Parties
We do not sell your Personal Information. We share Personal Information that we have collected from or regarding you as described below:
Opt In Data.
Subscriber text messaging originator opt-in data and consent details will not be shared with any third parties except when explicitly authorized by you.
Information Shared with Our Service Providers.
We may engage service providers to work with us to administer, market and provide the Services. These service providers have access to your Personal Information and Financial Information only for the purpose of performing services on our behalf.
We may also provide you with the ability to interact with and provide information to our service providers. When you leave our App or Site to interact with another service provider, you should also read their privacy policy to understand their privacy practices and how it relates to how they collect and share the information you provide.
Information Shared with our Business Partners and Affiliates.
We may share your Personal Information with business partners to provide you with a product or service you have requested or business partners with whom we jointly offer products or services. We may share your Personal Information with our company affiliates for our administrative purposes, including activities such as IT management, for them to provide services to you or support and supplement the Services we provide.
Information Shared with our Marketing Partners.
Some of the service providers we use provide us with analytics and performance reporting tools that help us understand how users interact with our Services and measure the effectiveness of our communications. These service providers access limited usage data solely to perform analytics services on our behalf, pursuant to written agreements that restrict further use or disclosure of that data.
Information Shared through APIs/SDKs.
We may use third-party Application Program Interfaces (“APIs”) and Software Development Kits (“SDKs”) as part of the functionality of our Services.
Information Shared with Large Language Model Providers.
We may share your Personal Information, including chat prompts, linked account information, and information from documents you upload, with large language model providers in a closed and secure environment in order to provide the Services, such as analyzing your inputs and providing responses. Your Personal Information will not be used to train those providers’ artificial intelligence models.
Aggregated Information Shared with Other Third Parties.
We may share aggregated information and non-identifying information with third parties for industry research and analysis, demographic and other similar purposes. For example, we may use aggregated and non-identifying information to derive statistics about the spending habits of our users, our users’ financial choices, and to publish blog posts, articles, or other communications on our Site and social media channels.
Information Disclosed in Connection with Company Transactions.
Information that we collect from our users, including Personal Information, is considered to be a business asset. Thus, if we are acquired by a third party as a result of a transaction such as a merger, acquisition or asset sale or if our assets are acquired by a third party in the event we go out of business or enter bankruptcy, some or all of our assets, including your Personal Information, may be disclosed or transferred to a third party acquirer in connection with the transaction.
Information Disclosed for Our Protection and the Protection of Others.
We cooperate with government and law enforcement officials or private parties to enforce and comply with the law. We may disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate: (i) to respond to claims, legal process (including subpoenas); (ii) to protect our property, rights and safety and the property, rights and safety of a third party or the public in general; and (iii) to stop any activity that we consider illegal, unethical or legally actionable activity.
Privacy Notice Under Federal And State Financial Privacy Laws
Certain Personal Information that we collect from you or otherwise obtain about you in connection with providing our Services, including information from any transaction involving a financial product or service we provide, is referred to in this Privacy Policy as NPI and is subject to federal financial privacy laws and, as described below, certain state financial privacy laws as well (collectively, “Financial Privacy Laws”). This section provides certain required disclosures and informs you of your rights under those Financial Privacy Laws, which may differ from your rights under other privacy laws.
Financial companies choose how they share your NPI. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your Personal Information that constitutes NPI.
The NPI we collect and share depends on the product or service you have with us. This information may include Personal Information described in the section entitled Information Collected or Received from You, such as the following:
Social Security number, date of birth, postal address, and email address
Annual income
Account and routing numbers
Account balances and transaction data
Credit history when you request your credit score or enroll in our product or service.
We collect this Personal Information directly from you, from your transactions with Cirqul, from your transactions with nonaffiliated third parties, and from consumer reporting agencies.
We share your NPI with certain Affiliates and third parties, such as our service providers, to run our everyday business and as required by law, and as generally described in the section entitled Information that We Share with Third Parties. We also share NPI with third party financial institutions for joint marketing. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons we choose to share; and whether you can limit this sharing. For purposes of this section of this Privacy Policy, the following definitions apply:
“Affiliates” means companies related by common ownership or control. They can be financial and nonfinancial companies.
“Nonaffiliates” means companies not related by common ownership or control with Cirqul. They can be financial and nonfinancial companies. We do not share with nonaffiliates so they can market to you.
“Joint marketing” means a formal agreement between nonaffiliated companies that together market products or services to you. Our joint marketers may include financial service providers, non-financial companies, and other businesses.
Reasons we can share your personal information | Do we share? | Can you limit this sharing? |
For our everyday business purposes— such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus | Yes | No |
For our marketing purposes— | Yes | No |
For joint marketing with other financial companies | Yes | No |
For our affiliates’ everyday business purposes— information about your transactions and experiences | Yes | No |
For our affiliates to market to you— including, based on information about your creditworthiness | Yes | Yes |
For nonaffiliates to market to you— about our products and services. | No | We don’t share |
To review your options for limiting the sharing of information, see Your Choices below. If you have any questions, you may email us at support@cirqul.com.
We protect your NPI from unauthorized access and use. In that regard, we use reasonable security measures that comply with applicable law. These measures include computer safeguards and secured files and buildings.
Certain state laws require additional disclosures as set forth below (these only apply to Personal Information subject to those laws):
For Nevada residents only. Nevada law requires that we provide you with the following contact information: Bureau of Consumer Protection, Office of the Nevada Attorney General, 555 E. Washington Ave., Suite 3900, Las Vegas, NV 89101; Phone number: 702-486-3132; Email: agInfo@ag.nv.gov
Under Vermont law, we will not share information we collect about Vermont residents with companies outside of our corporate family, unless the law allows it. For example, we may share information with your consent, to service your accounts or under joint marketing agreements with other financial institutions with which we have joint marketing agreements. We will not share information about your creditworthiness within our corporate family except with your consent, but we may share information about our transactions or experiences with you within our corporate family without your consent.
Under California law, we will not share information we collect about you with companies outside of Cirqul, unless the law allows it. For example, we may share information with your consent, to service your accounts, or to provide rewards or benefits you are entitled to. We will limit sharing among our companies to the extent required by California law.
California Privacy Rights
Collection and Use of Personal Information.
This Supplemental California Privacy Notice only applies to our processing of Personal Information that is subject to the California Consumer Privacy Act of 2018 (as amended) (“CCPA”). The CCPA provides California residents with the right to know what categories of personal information CIRQUL has collected about them, whether Cirqul disclosed that personal information for a business purpose (e.g., to a service provider), whether Cirqul “sold” that personal information, and whether Cirqul “shared” that personal information for “cross-context behavioral advertising” in the preceding twelve months. California residents can find this information below:
Category of Personal Information Collected by CIRQUL | Category of Third Parties Information is Disclosed to for a Business Purpose | Category of Personal Information That is Shared |
Identifiers
|
|
|
Protected classification characteristics under California or federal law
|
| Not Applicable |
Commercial information
|
| Not Applicable |
Internet or other electronic network activity Interaction with internet websites, mobile applications, or advertisements |
| Not Applicable |
Geolocation data Rough location of person or mobile device derived from Internet Protocol address |
| Not Applicable |
Professional or employment-related information Current or past job history |
| Not Applicable |
Inferences drawn from other Personal Information to create a profile about a consumer
|
| Not Applicable |
Category of Sensitive Personal Information Collected by CIRQUL | Category of Third Parties Information is Disclosed to for a Business Purpose | Category of Personal Information That is Shared |
Sensitive identifiers
|
| Not Applicable |
Financial Information
Personal Information does not include publicly available information that is lawfully made available to the general public from federal, state, or local government records. Note: Some Personal Information included in this category may overlap with other categories. |
| Not Applicable |
Biometric information
|
| Not Applicable |
“Sales” and “Sharing” Personal Information under the CCPA.
Cirqul does not sell your Personal Information for monetary consideration, as that term is defined in Cal. Civ. Code § 1798.140(t). Cirqul does not share your Personal Information for cross-context behavioral advertising, as that term is defined in Cal. Civ. Code § 1798.140(ah). We disclose Personal Information to service providers and contractors solely for the purpose of operating our platform and providing our Services, pursuant to written contracts that restrict further use.
Disclosure Regarding Individuals Under the Age of 16. Cirqul does not have actual knowledge of any “sale” of personal information of minors under 16 years of age. Cirqul does not have actual knowledge of any “sharing” of personal information of minors under 16 years of age for “cross-context behavioral advertising.”
Non-Discrimination.
California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA.
Authorized Agent.
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child. To designate an authorized agent, please contact us as at support@cirqul.com.
Verification.
To protect your privacy, we will take the following steps to verify your identity before fulfilling your requests submitted under the CCPA. When you make a request and as part of the verification process, we will ask you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative, which may include asking you to answer questions regarding your account and use of our Services.
If you are a California resident and would like to exercise any of your rights under the CCPA, please contact us as support@cirqul.com. We will process such requests in accordance with applicable laws.
California Opt-Out Rights.
Because Cirqul does not sell or share Personal Information for cross-context behavioral advertising, California residents are not required to opt out of any such activity. If our practices change in the future, we will update this Privacy Policy to reflect any applicable opt-out rights before those practices begin.
Disclosure Regarding Use of Sensitive Personal Information.
Cirqul only uses and discloses sensitive personal information for the following purposes:
To perform the Services reasonably expected by an average consumer who requests such Services.
To prevent, detect, and investigate security incidents that compromise the availability, authenticity, integrity, and or confidentiality of stored or transmitted personal information.
To resist malicious, deceptive, fraudulent, or illegal actions directed at Cirqul and to prosecute those responsible for those actions.
For short-term, transient use.
To verify or maintain the quality or safety of a product, service, or device that is owned, manufactured, manufactured for, or controlled by Cirqul, and to improve, upgrade, or enhance the service or device that is owned, manufactured by, manufactured for, or controlled by Cirqul.
For purposes that do not infer characteristics about individuals.
Right for Minors to Remove Posted Content.
Where required by law, California residents under the age of 18 may request to have their posted content or information removed from the publicly-viewable portions of the Services by logging into their Cirqul Account and removing the content or information using our self-service tools.
Nevada Privacy Rights.
If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Information to third parties who intend to license or sell that Personal Information. Please note that we do not currently sell your Personal Information as sales are defined in Nevada Revised Statutes Chapter 603A. If you would like to request that we do not sell your Personal Information going forward, please email support@cirqul.com with the subject line “Nevada Do Not Sell Request” and provide us with your name and the email address associated with your account.
Your Choices.
We offer you choices regarding the collection, use and sharing of your Personal Information. Please note that if you decide not to provide us with the Personal Information that we request, you may not be able to access all of the features of the Services.
Communications and Opt-Out.
Our main form of communication with you will be via SMS / text message, but we may also send you push notifications and/or emails from time to time. Communications from us may include notifying you about account related information or updates on a technical or customer support request that you submitted. We may periodically send you free newsletters, e-mails and notifications on your mobile device that promote our Services. When you receive such promotional communications from us, you will have the opportunity to “opt-out” (either through your CIRQUL Account or by following the unsubscribe instructions provided in the e-mail you receive). To opt out of receiving communications sent by Cirqul through text messages, you can text “Stop” to the message you have received from Cirqul. However, we need to send you certain communications regarding the Services and you will not be able to opt out of those communications – e.g., verifying updates or changes to your account information, updates to our Terms of Use or Cirqul’s Privacy Policy.
Cookies and Interest-Based Advertising.
You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, our Services may not work properly. Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt-out of personalized advertisements on some mobile applications by following the instructions for Android, iOS and others.
Your Privacy Rights.
In accordance with applicable law, you may have the right to:
Access Personal Information about you, including: (i) confirming whether we are processing your Personal Information; (ii) obtaining access to or a copy of your Personal Information in a structured, commonly used, and machine readable format; and (iii) receiving an electronic copy of Personal Information that you have provided to us, or asking us to send that information to another company in a structured, commonly used, and machine readable format (the “right of data portability”);
Request Correction of your Personal Information where it is inaccurate or incomplete. In some cases, we may provide self-service tools that enable you to update your Personal Information;
Request Deletion of your Personal Information;
Request Restriction of or Object to our processing of your Personal Information;
Request to Opt-Out of certain processing activities including, as applicable, if we process your personal information for “targeted advertising” (as “targeted advertising” is defined by applicable privacy laws), if we “sell” your personal information (as “sell” is defined by applicable privacy laws), or if we engage in profiling in furtherance of certain decisions that produce legal or similarly significant effects concerning you;
Withdraw your Consent to our processing of your Personal Information; and
Object to our processing of your personal data in Automated Individual Decision-Making;
Appeal our decision to decline to process your request.
To exercise the rights described above, please email us at privacy@cirqul.com.
Data Transfers.
Your Personal Information may be transferred to and maintained on computers located outside of your state or the United States, where the privacy laws may not be as protective as those in your jurisdiction. Please note our Services are currently designed for individuals based in the United States. If you’re located outside the United States while accessing the Services and choose to provide your Personal Information to us, we may transfer your Personal Information to the United States and process it there.
Retention of Your Information.
We store the personal information we collect as described in this Privacy Policy for as long as you use our Services, or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.
Deleting Personal Information.
Subject to the exceptions and conditions described in this section, you have the right to request that Cirqul delete personal information we have collected from you and, where applicable, to direct our service providers and contractors to delete your personal information.
This right applies to residents of California, Virginia, Colorado, Connecticut, Texas, Nevada, and other states that have enacted comprehensive consumer privacy legislation. Cirqul extends these rights to all users located in the United States on a voluntary basis, regardless of state residency.
To delete your personal information, you may submit a verified request to delete your personal information through one of the following methods:
Mail In Request: Submit your written request via mail to Cirqul, Attn. Deletion Request, 40 S. Stephanie Street #101, Henderson, NV 89012. Your written request must include your full name, email address associated with your account, and a description of the information you wish to have deleted.
Email: Send a written request to privacy@cirqul.com with “Deletion Request” in the subject line. Include your full name, email address associated with your account, and a description of the information you wish to have deleted.
Cirqul does not require you to create an account in order to submit a deletion request. If you do not have an account, please use the email method described above.
To protect your personal information and prevent unauthorized deletion, Cirqul is required to verify your identity before processing a deletion request.
For registered account holders: We will verify your identity by matching the information provided in your request against the information associated with your account. We may send a verification link or one-time passcode to the email address or phone number on file.
For individuals without an account: We will verify your identity by requesting at least two pieces of personal information that we can match against our records (such as your name, email address, phone number, or ZIP code).
If we are unable to verify your identity with a reasonable degree of certainty, we will inform you that we cannot process your request and explain the basis for this determination.
We will acknowledge receipt of your deletion request within ten (10) business days of receiving it. We will confirm the deletion or, if an exception applies, provide you with an explanation within forty-five (45) calendar days of receiving your verified request. If we require additional time, we will notify you of the extension and the reason for it within the initial 45-day period. Under California law, we may extend our response period by an additional 45 days (for a total of 90 days) where reasonably necessary, provided we give you prior notice.
Upon verification and absent an applicable exception, Cirqul will delete your personal information from our active systems. Please note that deletion of your personal information will result in the deactivation of your Cirqul account and may prevent you from using certain features or services that depend on that information.
When We May Retain Your Information.
Cirqul is not required to delete your personal information if retaining it is necessary for us to:
Complete a transaction for which the personal information was collected, provide a good or service requested by you, collect on a debt, or otherwise perform a contract between you and Cirqul;
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activity;
Debug and repair errors that impair existing intended functionality;
Exercise free speech, ensure the right of another consumer to exercise free speech, or exercise another right provided for by law;
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et seq.) or other applicable law;
Comply with a legal obligation, including but not limited to applicable financial record keeping requirements, tax law, and regulatory obligations; or
Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.
Where an exception applies, we will inform you that we cannot fulfill your deletion request in full or in part and will identify the specific exception(s) that prevent us from doing so.
Cirqul will not discriminate against you for exercising any of your privacy rights, including your right to delete. Note that some features or services may no longer be available to you after deletion of your account data, as those features are dependent on the information you have provided. This is a consequence of the deletion itself and does not constitute discrimination.
Nothing in this section requires Cirqul to delete information that has been de-identified or aggregated in a manner that can no longer reasonably identify, relate to, describe, be capable of being associated with, or reasonably linked to you or your household. Cirqul may retain de-identified or aggregated information derived from your data after deletion.
Our Policy Toward Children.
Our Services are not directed to children under 13 and we do not knowingly collect Personal Information from children under 13. If we learn that we have collected Personal Information of a child under 13 we will take steps to delete such information from our files as soon as possible.
Revisions to This Privacy Policy.
Any information that is collected via our Services is covered by the Privacy Policy in effect at the time such information is collected. We may revise this Privacy Policy from time to time. If we make any material changes to this Privacy Policy, we’ll notify you of those changes by posting them on the Services or by sending you an email or other notification and we’ll update the “Last Updated” date above to indicate when those changes will become effective.
Contact Us.
Please contact us via the “Connect” link on the Site, or via email at support@cirqul.com.