Privacy Policy

Last updated: March 26, 2026

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.

We use Your Personal Data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

Interpretation and Definitions

Interpretation

The words whose initial letters are capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

• Account means a unique account created for You to access our Service or parts of our Service.
• Affiliate means an entity that controls, is controlled by, or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
• Application refers to Circles, the software program provided by the Company.
• Company (referred to as either "the Company", "We", "Us" or "Our" in this Privacy Policy) refers to Circles.
• Country refers to: Denmark
• Device means any device that can access the Service such as a computer, a cell phone or a digital tablet.
• Personal Data (or "Personal Information") is any information that relates to an identified or identifiable individual.
• Service refers to the Application.
• Service Provider means any natural or legal person who processes the data on behalf of the Company.
• Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself.
• You means the individual accessing or using the Service.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

While using Our Service, We may ask You to provide Us with certain personally identifiable information, including but not limited to:

• Email address
• First name and last name
• Address, State, Province, ZIP/Postal code, City

Usage Data

Usage Data is collected automatically when using the Service. It may include information such as Your Device's Internet Protocol address, browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, time spent on those pages, unique device identifiers and other diagnostic data.

Information Collected while Using the Application

While using Our Application, in order to provide features of Our Application, We may collect, with Your prior permission:

• Pictures and other information from your Device's camera and photo library

You can enable or disable access to this information at any time through Your Device settings.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

• To provide and maintain our Service, including to monitor the usage of our Service.
• To manage Your Account and Your registration as a user of the Service.
• To contact You by email or push notifications regarding updates or informative communications related to the Service.
• To manage Your requests to Us.
• For business transfers: We may use Your Personal Data in connection with a merger, acquisition or sale of assets.
• For other purposes such as data analysis, identifying usage trends, and improving our Service.

Sharing Your Personal Data

We may share Your Personal Data in the following situations:

• With Service Providers to monitor and analyze the use of our Service.
• For business transfers in connection with a merger, sale of Company assets or acquisition.
• With other users when You share information or interact in public areas of the Service.
• With Your consent for any other purpose.

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. Retention periods by category:

• User Accounts: retained for the duration of your account relationship plus up to 24 months after account closure.
• Support tickets and correspondence: up to 24 months from ticket closure.
• Application usage statistics: up to 24 months.
• Server logs: up to 24 months for security monitoring and troubleshooting.

When retention periods expire, We securely delete or anonymize Personal Data. Residual copies may remain in encrypted backups for a limited period and are not restored except where necessary for security, disaster recovery, or legal compliance.

Transfer of Your Personal Data

Your information may be transferred to and maintained on computers located outside of Your state, province, country or other governmental jurisdiction where data protection laws may differ. The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy.

Delete Your Personal Data

You have the right to delete or request that We assist in deleting the Personal Data that We have collected about You. You can delete your account directly from within the app or by contacting Us. Please note that We may need to retain certain information when we have a legal obligation to do so.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data becomes subject to a different Privacy Policy.

Law Enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities.

Other Legal Requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

• Comply with a legal obligation
• Protect and defend the rights or property of the Company
• Prevent or investigate possible wrongdoing in connection with the Service
• Protect the personal safety of Users of the Service or the public
• Protect against legal liability

Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While We strive to use commercially reasonable means to protect Your Personal Data, We cannot guarantee its absolute security.

Children's Privacy

Our Service does not address anyone under the age of 16. We do not knowingly collect personally identifiable information from anyone under the age of 16. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us so We can take steps to remove that information from Our servers.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. We strongly advise You to review the Privacy Policy of every site You visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page and updating the "Last updated" date. You are advised to review this Privacy Policy periodically for any changes.

Contact Us

If you have any questions about this Privacy Policy, You can contact us:

• By email: info@circlessocialapp.com