Privacy Notice (California)

Last Updated: August 12, 2024

This California Resident Privacy Notice supplements the information and disclosures contained in our Privacy Policy. It applies to individuals residing in California from whom we collect Personal Information as a business under the CCPA.

Personal Information Collection, Disclosure, and Sale

For the purposes of this California Resident Privacy Notice, “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, or as otherwise defined by the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (California Civil Code §§ 1798.100 to 1798.199) and its implementing regulations, as amended or superseded from time to time (“CCPA”).

Personal Information does not include information that is:

  • Lawfully made available from government records.
  • Deidentified or aggregated.
  • Otherwise excluded from the scope of the CCPA.

The chart below provides the categories of Personal Information and Sensitive Personal Information (as defined by the CCPA) we have collected, disclosed for a business purpose, or sold or “shared” (for cross-context behavioral advertising purposes) in the preceding twelve months since this notice was last updated. The examples of Personal Information and Sensitive Personal Information provided for each category reflect each category’s statutory definition and may not reflect all of the specific types of Personal Information and Sensitive Personal Information associated with each category.

Category We Collected We Disclosed We Sold/Shared

A. Identifiers

Examples: Name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.

Yes Yes No

B. Categories of Personal Information in Cal. Civ. Code Section 1798.80(e)

Examples: Name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

Yes Yes No

C. Characteristics of Protected Classifications under California or Federal Law

Examples: Race or color, ancestry or national origin, religion or creed, age (over 40), mental or physical disability, sex (including gender and pregnancy, childbirth, breastfeeding or related medical conditions), sexual orientation, gender identity or expression, medical condition, genetic information, marital status, military and veteran status.

No N/A N/A

D. Commercial Information

Examples: Records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

Yes Yes No

E. Biometric Information

Examples: Physiological, biological, or behavioral characteristics, including DNA, that can be used, singly or in combination with each other or with other identifying data, to establish individual identity, such as imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information.

No N/A
 N/A

F. Internet or Other Electronic Network Activity Information

Examples: Browsing history, search history, and information regarding a consumer’s interaction with an internet website, application or advertisement.

Yes Yes No

G. Geolocation Data

Example: General geographic information based on IP address.

 Yes Yes No

H. Sensory Information

Examples: Audio, electronic, visual, thermal, olfactory, or similar information.

Yes Yes No

I. Professional or Employment-Related Information

Examples: Job application or resume information, past and current job history, and job performance information.

Yes Yes No

J. Non-Public Education Information (as defined in 20 U.S.C. 1232g; 34 C.F.R. Part 99)

Examples: Records that are directly related to a student maintained by an educational agency or institution or by a party acting for the agency or institution.

No N/A N/A

K. Inferences Drawn from Personal Information

Examples: Consumer profiles reflecting a consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Yes Yes No

L. Sensitive Personal Information (Identifiers)

Examples: A consumer’s social security, driver’s license, state identification card, or passport number.

No N/A N/A

M. Sensitive Personal Information (Log-In)

Examples: Account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account.

Yes Yes No

N. Sensitive Personal Information (Precise Geolocation)

Geolocation data used to locate a consumer within a geographic area that is equal to or less than the area of a circle with a radius of 1,850 feet.

Yes Yes No

O. Sensitive Personal Information (Group Membership)

Examples: Racial or ethnic origin, religious or philosophical beliefs, or union membership.

No N/A N/A

P. Sensitive Personal Information (Contents of Communications)

Examples: The contents of a consumer’s mail, email, and text messages unless the business is the intended recipient of the communication.

No N/A N/A

Q. Sensitive Personal Information (Genetic Data)

 No N/A N/A

R. Sensitive Personal Information (Identifying Biometric Information)

 No N/A N/A

S. Sensitive Personal Information (Personal Information Collected and Analyzed Concerning a Consumer’s Health)

 No N/A N/A

T. Sensitive Personal Information (Personal Information Collected and Analyzed Concerning a Consumer’s Sex Life or Sexual Orientation)

 No N/A N/A

Personal Information Usage

We collect your Personal Information for the following specific business and commercial purposes:

  • to provide, maintain, and improve the Services and to enhance and personalize your experience;
  • to process, complete, and maintain records on transactions;
  • to provide our Members, Creators, and online communities with the Services. Other Creators may use your Personal Information for their own purposes, such as to provide you with content, discussions, events, and memberships;
  • to send you technical notices, updates, security alerts, and support and administrative messages;
  • to respond to your comments, questions, and requests, and to provide customer service;
  • to communicate with you about products, services, offers, promotions, rewards, and events offered by Circle and others, and provide news and information we think will be of interest to you;
  • to monitor and analyze trends, usage, effectiveness and activities in connection with the Services, including our offers, advertising, communications features, and customer service;
  • to generate deidentified or aggregated data for any lawful purpose;
  • to detect, investigate and prevent fraudulent transactions and other illegal activities and protect the rights and property of Circle;
  • to facilitate contests, sweepstakes and promotions and process and deliver entries and rewards;
  • to link or combine with information we get from the Services and from others to help understand your needs and provide you with better service;
  • to maintain appropriate records for internal administrative purposes; and
  • to carry out any other purpose described to you at the time the information was collected or permitted by law.

Collection of Personal Information

We collect Personal Information from the following categories of sources:

  • You/Your Devices: You or your devices directly.
  • Members and Creators: Other Members and Creators of the Services.
  • Analytics Providers.
  • OS/Platform Provider: Operating systems and platforms.
  • Social Networks.
  • Partners: Business partners.
  • Public: Publicly accessible sources.

Personal Information Disclosure

In the preceding twelve months since this notice was last updated, we disclosed Personal Information to the following categories of third parties for the purposes outlined under the “Personal Information Usage” section above:

  • Analytics Providers.
    1. Personal Information we disclosed: Identifiers, Categories of Personal Information in Cal. Civ. Code Section 1798.80(e), Commercial Information, and Internet or Other Electronic Network Activity Information.
  • OS/Platform Providers: Operating systems and platforms.
    1. Personal Information we disclosed: Identifiers, Categories of Personal Information in Cal. Civ. Code Section 1798.80(e), Commercial Information, Internet or Other Electronic Network Activity Information, Geolocation Data, Sensory Information, Professional or Employment-Related Information, Inferences Drawn from Personal Information, Sensitive Personal Information (Log-In), and Sensitive Personal Information (Precise Geolocation).
  • Social Networks.
    1. Personal Information we disclosed: Identifiers, Categories of Personal Information in Cal. Civ. Code Section 1798.80(e), Commercial Information, Internet or Other Electronic Network Activity Information, and Sensory Information.
  • Vendors: Vendors and service providers.
    1. Personal Information we disclosed: Identifiers, Categories of Personal Information in Cal. Civ. Code Section 1798.80(e), Commercial Information, Internet or Other Electronic Network Activity Information, Geolocation Data, Sensory Information, Professional or Employment-Related Information, Inferences Drawn from Personal Information, Sensitive Personal Information (Log-In), and Sensitive Personal Information (Precise Geolocation).

Minors

We do not sell the Personal Information of any of our consumers or share the Personal Information of consumers we know to be less than 16 years of age.

Your Privacy Choices

If you are a California resident, subject to certain legal limitations and exceptions, you may be able to exercise some or all of the following rights:

The Right to Know and Access

The right to confirm whether we are processing Personal Information about you and, under California law only, to obtain certain personalized details about the Personal Information we have collected about you, including:

  • Categories of Personal Information collected, sold, or disclosed by us;
  • Purposes for which categories of Personal Information are collected or sold by us;
  • Categories of sources from which we collect Personal Information;
  • Categories of third parties to whom we disclosed or sold Personal Information; and
  • Specific pieces of Personal Information we have collected about you during the past twelve months.
The Right to Correction

The right to correct inaccuracies in your Personal Information, taking into account the nature of the Personal Information and the purposes of the processing of the Personal Information.

The Right to Deletion

The right to have us delete the Personal Information we maintain about you.

The Right to Opt-Out of Sales or Sharing of Personal Information

The right to direct us not to “sell” your Personal Information to third parties for monetary or other valuable consideration, or “share” your Personal Information to third parties for cross-context behavioral advertising and targeted advertising purposes. We do not sell any of your information, and we do not process or otherwise share sensitive information for the purpose of targeted advertising.

The Right to Limit Use and Disclosure of Sensitive Personal Information

The right to limit our use and disclosure of your Sensitive Personal Information. We do not use or disclose your Sensitive Personal Information for purposes other than the limited purposes permitted by the CCPA.

The Right of No Retaliation

The right not to receive discriminatory treatment for the exercise of your CCPA privacy rights, subject to certain limitations.

How to Exercise Your Privacy Rights. To exercise these privacy rights and choices, please follow the instructions below:

  • How to Request That We Identify or Provide You Access to Personal Information: You may request that we identify or provide you access to your Personal Information twice in a 12-month period. To do so, please email us at legal@circle.so or write to us at 228 Park Ave S, PMB 52933, New York, NY 10003. In response to a request to access your Personal Information, we will produce an “Access Report” detailing the Personal Information we have collected and disclosed about you. This Access Report will be delivered electronically at your request.
  • How to Request Deletion of Personal Information: You may request that Circle delete the Personal Information it has collected and/or maintained about you. To do so, please email legal@circle.so or write to us at 228 Park Ave S, PMB 52933, New York, NY 10003. Note, we may need to retain certain Personal Information as permitted by law, such as to complete the transaction for which the Personal Information was collected, provide a requested good or service, detect security incidents, protect against malicious, deceptive, fraudulent or illegal activities, comply with legal obligations or to enable solely internal uses that are reasonably aligned with your expectations or lawful within the context in which you provided the information.
  • How to Opt-Out of the Sale or Sharing of Personal Information:
    • For Cookie-Based Sales & Targeted Advertising Opt-Outs: To exercise your right to opt-out as it relates to the use of cookies and other third-party tracking technologies and targeted ads, please reference our Cookie Policy.
    • For Non-Cookie-Based Opt-Outs: You may submit a request by emailing us at legal@circle.so.
  • For App-Based Opt-Outs: You may download the DAA’s CCPA App-Based Opt-Out Tool, which opts out of data processing by third parties enrolled in the DAA’s program. Please note that this opt-out is device-specific and will not be effective on your visits to the services from other devices or through the website.

Verification. Please note, we will take steps to verify your identity before fulfilling any of the above requests. If you maintain an Account with us, we will verify your identity through existing authentication practices for the Account (e.g., login and password). If you are not a registered Creator or Member, we will verify your identity by matching two or three data points that you provide with data points that we maintain and have determined to be reliable for the purposes of verification.

Authorized Agents. In certain circumstances, you may permit an authorized agent to submit requests on your behalf. The authorized agent must provide a letter signed by you confirming the agent has permission to submit a request on your behalf, or must provide sufficient evidence to show that the authorized agent has been lawfully vested with power of attorney.

Retention of Personal Information. We retain Personal Information only for as long as is reasonably necessary to fulfill the purpose for which it was collected. However, if necessary, we may retain Personal Information for longer periods of time, until set retention periods and deadlines expire, for instance where we are required to do so in accordance with legal, tax and accounting requirements set by a legislature, regulator or other government authority.

To determine the appropriate duration of the retention of Personal Information, we consider the amount, nature and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of Personal Information and if we can attain our objectives by other means, as well as our legal, regulatory, tax, accounting and other applicable obligations.

Contact Us

If you have any questions, comments or concerns about our California Resident Privacy Notice, you may email us at legal@circle.so. Additionally, if you have any questions, comments or concerns about our California Resident Privacy Notice, feel free to send correspondence to the following address:

CircleCo, Inc.
228 Park Ave S
PMB 52933
New York, NY 10003