For the purpose of data protection legislation, the data controller is Circle Internet Financial Trading Company Limited of 8 Clanwilliam Square, Grand Canal Quay, Dublin 2, Republic of Ireland. When we refer to “Circle” in this policy, we refer to this entity. Circle is registered with the Irish Data Protection Commissioner.
1. Information We Collect
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, etc.
If you want to link a debit card, credit card or bank account, we’ll need to collect the card number or IBAN/BIC or account/routing 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.
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:
- Device Information. We collect information about your device, including the type of device (Computer vs. iPhone vs. Android), operating system, mobile phone number, browser type and language, and device identifiers (such as IMEI and MAC address).
- Location Information. With your permission, we collect your device location so that we can offer you location-based features such as the ability to send funds to nearby Circle users.
- Contacts. To make it easier to send money to your contacts, we will - with your permission - collect information from your phone’s address book.
- Photos, Videos & Other Media. If you want to attach photos, videos or other media to your payments, payment requests or other communication using Circle, we require access to the photos on your phone. Any photos, videos or other media you attached will be stored and accessible to Circle, but we will never download or store any photos, videos or other media from your phone that aren’t attached to payments, payment requests or other communications using Circle.
- Message Content. If you include a message with your payments, the content of that message is stored and accessible to Circle.
- Transactions. We collect information about your payment activity such as the amount, date, time, recipient for each transaction.
2. Protecting Your Information
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 anonymized.
We protect your information using physical, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure and alteration. Some of the safeguards we use are firewalls and data encryption, physical access controls to our data centers, and information access authorization controls. All of our physical, electronic and procedural safeguards are designed to comply with applicable laws and regulations.
3. How We Use Your Information
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:
- Deliver the full range of payments and functionality of the Circle product;
- Keep in touch with you - whether it be for providing customer service, notifying you of cool new features that have been added to the mobile apps, or providing security notices or information;
- Verify your identity so that we can prevent fraud or unauthorized activity;
- Improve Circle or add new product features by analyzing usage trends;
- Personalize the Circle experience by matching product features to things that we think you specifically might be interested in; and
- Fulfill any other purpose for which the information was collected.
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 personalize the Services, as well as our content and advertising.
4. How We Share Your Information
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:
- In order to prevent fraud, we will sometimes need to share your information with third party identity verification services. This lets us make sure you are who you say you are, by comparing the information you provide us to public records and other third party databases.
- In order to improve Circle’s functionality, we will sometimes share information with service providers that help us analyse how people are using the app. This allows us to refine popular features and improve or eliminate features people don’t use.
- As a regulated financial institution, we may need to share your information with law enforcement or government officials. We will only do this when we are compelled to do so by a specific regulation, subpoena, court order or formal request, or we otherwise believe in good faith that we need to share such information to prevent physical harm, financial loss, or are obligated to report illegal activity.
- In order to complete third party financial, technical and legal audits of Circle’s operations, we may need to share information about your account as part of such review.
- Circle will share your information with Circle Internet Financial, Inc. (a U.S. entity), Circle Internet Financial Trading Company Limited (an Irish entity) and other Circle affiliated entities as necessary in order to provide you with the best possible product and customer support.
- We will share your information with other third parties if you specifically authorise us to do so.
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. This information includes:
- Transaction Details. At the risk of stating the obvious, when you send someone a payment or payment request, they will be provided with the details of that transaction, including the payment amount, currency, date, time and a unique transaction ID number.
- Messages & Photos. If you attach a message or photo, video or other media to a payment, payment request or other communication using Circle, that information will be visible to the person(s) receiving the payment. You should know that the recipient of a message or photo (or other media) can always save them - so don’t send anything you wouldn’t want shared publicly.
- Your Identity & Photo. When another Circle user receives a payment or payment request from you, they will receive some information about your identity. Exactly what “persona” we provide to others is up to you. This can be your email address or simply your first name and last initial and can be customized in your account settings. If you add a photo or avatar to your Circle account, they’ll see that too.
- Location. If you have your location enabled in your settings, the location from which a payment was initiated may be visible to the recipient. This also lets other users take advantage of the “nearby users” function, which makes it easier for them to send you a payment if you’re nearby and not otherwise in their contacts.
- Status as a Circle User. Other Circle users may be able to see that you have a Circle account. This lets them know they can send you a payment and you will receive it instantly without having to first set up a Circle account. Other Circle users may also be able to tell which currency you have chosen as your default currency. This makes it easier for them to send you the right amount and to know the currency in which their payment will be delivered.
- Public Sharing of Transactions. In the future, Circle may give users the ability to share certain payment information through a public feed or social media integration. The information may include sender, recipient, date and time of transaction, avatars, location, media or other information regarding the transaction. If this feature is enabled, you will be able to determine how much information is shared in your account settings.
- Other Information. As we add new product features, there may be additional information that is shared with other Circle users. If those new features require sharing any personal information, we’ll always get your permission first and will do our best to allow you to disable such features in your account settings. We’ll also provide information to other Circle users if you specifically request that we share such information.
5. How To Change or Delete Your Information
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 know what information we’re keeping on you, check out the categories listed above. We can also provide you with a copy of this information, but we won’t include any sensitive financial information.
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.
6. Children’s Privacy
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.