Last updated: 18 September 2017
For the purpose of the UK Data Protection Act, the Data Controller is Circle UK Trading Limited registered office at White Collar Factory, 1 Old Street, London, EC1Y 8AF, UK.
What You Directly Provide Us
When you create a Circle account, we’ll collect some important details about you such as your name, address, phone number, email, birth date, password, tax ID or equivalent (if applicable) and any other information you provide directly via our website or mobile application.
If you want to link a debit card, credit card or current account, we’ll need to collect the card number or IBAN/BIC numbers and related account information. As Circle adds additional features, you may also be prompted to provide additional information.
Sometimes we need to request more information to verify your identity or to meet legal and regulatory obligations. When that is necessary, you will be prompted to provide such information.
In the event that Circle integrates with other platforms, you may be prompted from time to time to grant Circle access to additional information from such platform (or grant such partner platform access to information you have provided to Circle). For example, if Circle implements an integration with a social media platform, you would have the option of linking your account on that platform to Circle in order to streamline the signup process, populate your contact list or other purposes.
In providing personal data of any individual (other than yourself) to us during the use of our Services, you agree that you have obtained consent from such individual to disclose their personal data to use for collection and use.
What is Automatically Collected
There is some information that is automatically collected as you use Circle. This information allows us to deliver cool new features, more easily handle your customer support issues and better protect your account. This information includes:
Throughout this policy, we use the term “personal information” to describe information that is associated with you or can be used to identify you. We do not consider personal information to include information that has been anonymised.
We collect all of this information so that we can provide you with a safe and seamless way to make and receive payments. The information we collect allows us to:
We will never sell or rent your personal information to third parties. We may combine your information with information we collect from other companies and use it to improve and personalise the Services, as well as our content and advertising.
Sharing With Third Parties
In order to provide you with the Circle product and meet our legal and regulatory obligations, we may share the information we collect as detailed below:
Sharing With Other Circle Users
In order to make Circle payments about more than just sending money from A to B, we will share additional information with other Circle users, but only to the extent that you give us permission to do so. Note that any information you provide to someone (through a payment, payment request or otherwise) can always be shared by them with others - so use discretion. This information includes:
Circle works to ensure that customers located in the EEA receive notice of the purposes for which we collect and use your personal information, the types and identities of third parties to which we disclose this information, certain privacy rights of customers (such as the right to access your personal information and your choices for limiting the use and disclosure of your personal information), and how to contact Circle about our practices concerning your personal information.
For more on these topics, please refer to Sections 3 and 4, above (“How We Use Your Information” and “How We Share Your Information”), as well as Sections 6 and 7, below (“How to Change or Delete Your Information” and “Complaints”).
Circle will take steps to remediate any unauthorized use by third-parties and, if found responsible, we have potential liability for any damage caused. We will also make reasonable efforts to accommodate employee privacy preferences, including restricting third-party access to personal information and limiting use for a purpose that is incompatible with the purpose(s) for which it was originally collected or subsequently authorized by the employees.
If you need to add or change any information, you can just log in to your Circle account and make the change in your settings. If it doesn’t look like you can make the change on your own, just reach out to Support and we’ll take care of it.
If you want to close your Circle account, know that as a regulated financial institution we are required to retain certain information you have provided for a number of years.
If you want to know what information we’re keeping on you, check out the categories listed above. Subject to applicable laws, you have the right to access the personal data we hold on you, this can be done by submitting a request to [email protected]. We may ask you to verify your identity and for more information about your request.
You have the right to ask us not to process your personal data for marketing purposes by contacting us at [email protected]. Our Services may contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility for them. Please check these policies before you submit any personal data to these websites.
In compliance with the EU-US Privacy Shield Principles, Circle commits to resolve complaints about our collection or use of your personal information. Individuals in the European Union with inquiries or complaints regarding our Privacy Shield policy should first contact Circle at [email protected].
Circle has further committed to refer unresolved Privacy Shield complaints to the Information Commissioner's Office (“ICO”), an alternative dispute resolution provider located in the United Kingdom. Circle is registered with the ICO with the Registration reference number ZA176325. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact or visit the ICO at https://ico.org.uk/ for more information or to file a complaint. The services of the ICO are provided at no cost to you.
Unfortunately, if you’re under 13, you can’t use Circle. So we don’t knowingly solicit or collect information from anyone under 13. If we become aware that a child under the age of 13 has provided us with personal information, we’ll delete it immediately.