CIRCLE  PRIVACY  POLICY

Effective Date: January 1, 2022

Updated: August 24, 2022

This Privacy Policy applies to Personal Information received, collected and processed by Circle The People Inc. (“Circle”, “us”, “we” or “our” herein) in the course of our business, including any of our subsidiaries and affiliated entities, as well as additional sites/applications operated by us and our affiliates and subsidiaries (each a “Site”) and the services provided through the Sites (collectively with the Sites, the “Services”). The terms “you” and “your” refer to users of the Sites and Services.

Please note that unless we define a term in this Privacy Policy, capitalized terms used in this Privacy Policy have the same meanings as in our Terms of Use.

This Privacy Policy contains the following sections:

1.  Personal Information Collection and Use

2.  Personal Information Sharing

3.  Your Choices

4.  Individual Rights in Personal Information

5.  Personal Information Retention

6.  Personal Information Storage and Security

7.  Other Important Information

1.  Personal Information Collection and Use

This Privacy Policy covers our use of your Personal Information. “Personal Information,” means any information that relates to you and can — either on its own or in combination with other information — identify you as an individual. Personal Information does not include information that has been de-identified or aggregated such that you can no longer be identified.

The types of information we collect depends on your level of engagement with the Services. The more you interact with the Services, the more information we need to provide the Services. This Section explains how we collect and use Personal Information based on your level of engagement with the Services.

A.  All Users of the Sites and Applications

From registered and unregistered users of the Sites and Services, we automatically receive and record information whenever you interact with the Sites and Services. This includes IP address data from our server logs, cookie information, browser information, information about your activity while on the Sites (such as the pages you request, properties that you view or save, and property that you claim), and the URL of the site you came to the Sites from. We also may collect the mobile device ID (such as the ID for Advertising on iOS and Android ID on Android) from users of our Services and Apps. If permitted by the settings on your device and/or with your consent, we will also collect your geo-location information. We use this to provide you with location-specific information, such as homes for sale near your current location as determined by your geolocation, and information about listing your home for sale based on your geolocation. We may also approximate your location based off your IP address, to customize your experience on our Sites.

We may also use the information listed above to help diagnose problems and performance with the Services, analyze trends, customize your experience, and administer the Services. We may provide IP addresses to third parties to help us analyze website user survey data. We may also use the information described in this section to better target information about our Sites and Services, for example, by displaying more accurate or relevant information on our Sites, matching you to a public record listing of a property, tailoring the advertising we display on third party websites and platforms, and sending better targeted and tailored messages, including via email and/or push notifications.

B.  Registered Users of Circle’s Sites, Services and Applications

We may be required to collect certain information, including your name and email address, as a condition of certain licenses with the third-party service providers (for example: multiple real estate listing services or “MLS”, to allow you to access the full MLS listings). You give us this information when you create your Circle account. When you create a Circle account, you agree that this Privacy Policy and our Terms of Use apply. In addition, when you are signed into your Circle account and using Circle through any authorized third-party service, we may make use of the information that they provide us to further customize your experience. We may share Personal Information with such third parties to deliver Circle tailored content both on our Services and on third party sites (e.g., social media sites).

Account Password Security: Your Circle account password is encrypted on our server. It is your responsibility not to disclose your password to other people and to ensure you maintain its security.

Account Updates: In your Circle account settings, you can correct, amend, add or delete Personal Information associated with your account. However, even after you update information, we may maintain a copy of the original information in our records as required by applicable law or other legal obligation.

C.  Circle Clients

When you subscribe to a Circle account, you become a Circle client. As part of the account creation process, you will need to provide certain information for us to create an account for you in connection with our Services. This information can include, without limitation, your name, address, phone number, email address, agent or broker identifiers, brokerage, or lender affiliation, among other items of information. Once you consent to the creation of your Circle account, your relationship with Circle is governed by our online Terms of Use and this Privacy Policy.

D.  Communications with Circle

Circle may collect Personal Information from you such as email address, phone number, or mailing address when you request information about our Services, register for our newsletter, request customer or technical support, or otherwise communicate with us.

E.  Marketing

We may send marketing materials to Circle account holders and clients using various communication channels, including without limitation, email, text messages/SMS, push notifications, telephone calls, and direct mail. Individuals may also subscribe to notifications with information such as customized historical data surrounding homes that have recently sold in a particular area. Circle may send you Circle-related news and surveys in accordance with applicable law.

F.  Call Recording

We do not record any telephone calls between you and our representatives for training and quality assurance purposes.

G.  Surveys

Circle 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.

H.  Sharing with Friends or Colleagues

Circle’s Services may allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Services. Email addresses that you may provide for a friend or colleague will be used to send your friend or colleague the content or link you request in accordance with applicable law.

I.  Interactive Features

Circle may offer interactive features such as chat services, forums, and social media pages. We may collect the information you submit or make available through these features. Any content you provide on the public sections of these channels will be considered “public” and will not be subject to the privacy protections referenced herein.

J.  De-Identified and Aggregated Information

We may use Personal Information and other information about you to create de-identified and/or aggregated information, such as de-identified demographic information, de-identified location information, de-identified or aggregated trends, reports, or statistics, information about the computer or device from which you access our Services, or other analyses we create. De-identified and aggregated information is used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the Sites and Services. De-identified and aggregated information is not Personal Information, and we may use and disclose such information in several ways, including research, internal analysis, analytics, and any other legally permissible purpose.

K.  Conferences and Trade Shows

We may attend or participate in conferences and trade shows where we collect Personal Information from individuals who interact with or express an interest in Circle and/or our Services. If you provide us with any information at one of these events, we will use it for the purposes for which it was collected.

L.  Information We Collect Automatically

We do not now but may in the future collect certain information automatically when you use the Services. This information may include your Internet protocol (IP) address, user settings, IMEI, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, details about your browser, operating system or device, location information, Internet service provider, information about the links you click, and other information about how you use the Services. Information we collect may be associated with accounts and other devices.

M.  Information from Other Sources

We may obtain information about you from other sources, including through third-party services and organizations to supplement information provided by you. This supplemental information allows us to verify information that you have provided to us and to enhance our ability to provide you with the Services.

N.  Other Uses of Information

In addition to the specific collection and uses listed above, we may use any of the Personal Information we collect for the following business purposes:

• to operate our Sites and provide our Services in accordance with our Terms of Use and/or any other agreement you may have with us;
• to manage your Personal Information and accounts;
• to respond to your questions or inquiries;
• to conduct promotional activities, including contests or surveys;
• to undertake internal research for technological development and demonstration;
• to improve, upgrade or enhance our Sites and Services;
• to send you informational or promotional communications;
• to facilitate social features of the Services, such as identifying and suggesting connections with other users of the Services and providing chat or messaging functionality;
• to detect bugs, security incidents (including to protect against malicious, deceptive, fraudulent, or illegal activity, and prosecute those responsible for that activity);
• to identify and repair errors that impair existing intended functionality;
• to undertake activities to verify or maintain the quality or safety of our Sites and Services;
• to carry out other purposes that are disclosed to you and/or to which you consent; and
• to pursue our legitimate interests where your rights and freedoms do not outweigh these interests.

2.  Personal Information Sharing

While we do not exchange your Personal Information with others for monetary consideration, we may share your Personal Information with the following categories of third parties as part of our Services to you or to assist us in conducting our marketing and advertising, or for other business or commercial purposes listed above in this Privacy Policy.

A.  Public Record Information

Please be aware that home sales and purchases may be a matter of public record, and your name and address, the price you paid, your property taxes, and other information may be available from public sites regardless of the brokerage(s), if any, who assist in the transaction. We post on our Sites some information that typically becomes part of the public record of a home sale or purchase.

B.  Non-Public Record Information

We share information obtained from you, MLSs and other third-party sources that are not on the public record to facilitate your home purchase or sale transaction. We may work with third parties to provide the Services in connection with any home transaction process and usually must share your information with those third parties. Examples include MLSs and providers of software, data storage and retrieval, and analytics providers. 

C.  Negotiations

We may post price offers and counteroffers on our Sites. We do not post your name on our Sites without your permission, but if the sale is closed, the price and the fact that you bought or sold your house at that price may be a matter of public record.

D.  Circle Corporate Family

We may share your information with members of the Circle family of entities for various purposes, including to: (i) provide the Services to you; (ii) help detect and prevent potentially illegal and fraudulent acts and other violations of our policies and agreements; (iii) help with marketing initiatives; and (iii) manage and improve Circle Sites, Services, and tools.

E.  Service Providers

We may share your Personal Information with third-party service providers that assist us in providing the Services. We use reasonable efforts do so with the appropriate contractual protection in place to ensure that your Personal Information is protected and used only in accordance with this Privacy Policy.

F.  Business Partners

We may provide Personal Information to business partners to provide you with a product or service you have requested. We may also provide Personal Information to business partners with whom we jointly offer products or services in accordance with applicable law.

G.  Third-Party Cookies and Information Used to Target Ads to You

We do not now but may in the future share the information that we collect about you with others (including advertising networks and service providers) to tailor and serve you ads on our Services, as well as other websites and social media networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising.” These advertising networks may track your online activities over time by collecting information through automated means, including through the use of technologies (e.g., cookies, web-beacons and other methods). This allows Circle to target our advertising to you through demographic, behavioral and contextual means. As a result, you may see ads for Circle on other websites and social media.

H.  APIs and SDKs

We may use third-party APIs and software development kits (“SDKs”) as part of the functionality of our Services. APIs and SDKs may allow third parties, including advertising partners, to collect your Personal Information to provide our Service-related content. SDKs allow us to perform analytics regarding the use of our mobile application, to integrate with social media, add features and functionality to our App, or to facilitate on-line advertising. For more information about our use of APIs and SDKs, please contact us as set forth below.

I.  Information Disclosed in Connection with Business Transactions

If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your Personal Information may be sold or transferred as part of such a transaction as permitted by law and/or contract.

J.  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 or legal processes (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.

K.  Other Purposes

Circle may share your Personal Information for other purposes that are clearly disclosed to you at the time you provide Personal Information or with your consent.

3.  Your Choices

A.  General

You may have the right to opt in, object to or opt out of certain uses of your Personal Information. Where you have consented to the processing of your Personal Information, you may withdraw that consent at any time by contacting us as described below. Even if you opt out, we may still collect and use Personal Information regarding your activities on our Sites, Services and/or information from the advertisements on third party websites for other legal purposes as described above in accordance with applicable law.

B. Electronic Messages, Phone Calls, and other Communications

If you receive an unwanted email from Circle, you can access your Circle account and use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails regarding products or Services you have requested. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (e.g., communications regarding the Services or updates to our Terms of Use or this Privacy Policy).

C. Opting-Out of Technologies and Tracking

Circle Cookies: We may put Circle cookies on your device’s browser to help us keep track of when you were last on the Sites, and what you last searched on the Sites. You are free to disable cookies on your browser at any time; however, we recommend that you leave cookies activated to use some of the most useful Circle features.

Third-Party Cookies for Analytics: We may use third parties, such as comScore and Google, to help us analyze how people are using the Services, and those third parties are authorized to use various technologies to access Personal Information regarding visitors to our Sites.

Google Analytics: We use the Google Analytics service to provide us with demographic data about our users on a de-identified basis. This Google service uses a cookie that can be recognized by Google or its affiliate DoubleClick when you visit other websites. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of Google Analytics’ collection and use of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout.

Opting Out of Circle’s Interest-Based Advertising: If you do not want Circle to collect, use and share information about you to deliver interest-based advertising, you can access your Circle account and opt-out.  Just follow the provided instructions. Please note that most opt-out mechanisms are cookie-based and will only affect the specific computer and browser that is used to submit an opt-out request. If you have multiple computers or change computers, or use multiple browsers, you will need to submit opt-out requests for each such computer or browser. In addition, if you delete, block, or otherwise restrict cookies, you will need to renew the opt-out choices to ensure that any opt-out cookies remain effective.

Opting Out of Interest-Based Advertising Generally: The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these, and learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/managing/opt_out.asp, http://www.youronlinechoices.eu/, and https://youradchoices.ca/choices/, and www.aboutads.info/choices/. To separately make choices for mobile apps on a mobile device, you can download DAA’s AppChoices application from your device’s app store. Please note you must separately opt out in each browser and on each device.

Browser Solutions for Disabling Cookies: If you wish to prevent cookies from tracking your activity on our website or visits across multiple websites, you can set your browser to block certain cookies or notify you when a cookie is set. The Help portion of the toolbar on most browsers will tell you how to prevent your device from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Sites who disable cookies will be able to browse the Sites, but some features may not function.

Opting Out of Mobile Device ID Tracking: We may use the information that we collect about you (whether directly from our Sites, from our Services, through your device(s), or from a third party) to help us and our third-party service providers identify other devices that you use (e.g., a mobile phone, tablet, other computer, etc.). We and our third-party service providers also may use the cross-device use and other information we learn about you to serve targeted advertising on your devices and to send you emails. Mobile device users may opt out of receiving some interest-based advertising in their mobile apps by following the instructions for Android and iOS. Please note that precise instructions may vary by device.

Do Not Track: Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. 

Flash Cookies: Circle does not currently use flash cookies (or “locally stored objects”), but we may in the future. If we do use flash cookies in the future, you will be provided with an opportunity to control what information that may collect. Please note that flash cookies do not reside in your browser, so your browser settings will not affect them.

D. Mobile Devices

We may send you push notifications through the Circle mobile application. You may at any time opt-out from receiving these types of communications by changing the settings on your mobile device. Circle may also collect location-based information if you use our mobile applications. You may opt-in or opt-out of this collection by changing the settings on your mobile device.

E. Delete your Account

You may delete your Circle account on your Account Settings page. We retain Personal Information for as long as we have a valid business purpose to or to meet our legal obligations. Circle may be required to keep a copy of your Personal Information in accordance with Section 5 below.

4.  Individual Rights in Personal Information

In accordance with applicable law, you may have the right to: (i) request confirmation of whether we are processing your Personal Information; (ii) obtain access to or a copy of your Personal Information; (iii) receive an electronic copy of Personal Information that you have provided to us, or ask us to send that information to another company (the “right of data portability”); (iv) restrict our uses of your Personal Information; (v) seek correction or amendment of inaccurate, untrue, incomplete, or improperly processed Personal Information; and (vi) request erasure of Personal Information held about you by Circle, subject to certain exceptions prescribed by law. If you would like to exercise any of these rights, please contact us as set forth below.

We will process such requests in accordance with applicable laws. To protect your privacy, Circle may take steps to verify your identity before fulfilling your request. We collect and report annual metrics on how we respond to requests.

5.  Personal Information Retention

Circle retains the information we receive 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.

6.  Personal Information Storage and Security

Circle is headquartered in the United States. You agree that we may store and process the information we collect anywhere in the world, including but not limited to, the United States, the European Union, or other countries.

We take commercially reasonable steps to ensure that your information is stored and treated securely and in accordance with this Privacy Policy. Unfortunately, the Internet cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unintentional disclosure.

By using the Services or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Services, by mail or by sending an e-mail to you.

7.  Other Important Information

A.  California Privacy Policy Provisions

The follow provisions supplement the information contained in our Privacy Policy and applies solely to individuals who reside in the State of California (“consumer” or “you”) in our role as a business. We adopt this notice to comply with the California Consumer Privacy Act of 2018, as amended (“CCPA”), and any terms defined in the CCPA have the same meaning when used in this document.

Information We Collect

In providing our Services, we may collect 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 (“Personal Information”).

Personal Information does not include:

• publicly available information from government records;

• de-identified or aggregated consumer information

• information excluded from the CCPA’s scope, like:

• health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; or

• Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

We may use or disclose the Personal Information we collect for the business purposes described in this Privacy Policy. We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you additional notice and the ability to opt-out of such information collection.

Disclosures of Personal Information for a Business Purpose

We may disclose your Personal Information to the third parties or others as described in this Privacy Policy for any of the business purposes described in this Privacy Policy. When we disclose Personal Information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing the contract.

In the preceding twelve (12) months, we have not disclosed any of the above categories of Personal Information as we have not yet made our Sites and Services commercially available to the public. When we commence commercial operation, we will update this Privacy Policy accordingly.

The CCPA defines “sales” broadly to include not only traditional selling of data for monetary consideration, but also data sharing arrangements where the recipient can use the Personal Information that they receive for the recipient’s own business purposes. While we do not “sell” your Personal Information for monetary consideration, we do share certain categories of Personal Information available to receive certain benefits or services, such as when we make browsing information available to third party ad companies (through third party tags on our Sites) in order to improve and measure our ad campaigns and reach users with more relevant ads and content. This sharing can constitute “sales” under the CCPA.

In the preceding twelve (12) months, we have not “sold” any of the above categories of Personal Information as we have not yet made our Sites and Services commercially available to the public. When we commence commercial operation, and any “sales” occur, we will update this Privacy Policy accordingly.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.

Right to Know

You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your request, we will disclose to you:

• the specific pieces of Personal Information we collected about you;

• the categories of Personal Information we collected about you;

• the categories of sources from which the Personal Information is collected about you;

• our business or commercial purpose for collecting or selling that Personal Information;

• the categories of third parties with whom we share that Personal Information; and

• if we sold or disclosed your Personal Information for a business purpose.

Right to Delete

You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies. We may not be able to honor your deletion request if retaining the information is necessary for us or our service provider(s) to:

• complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;

• detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;

• debug products to identify and repair errors that impair existing intended functionality;

• exercise free speech, ensure the rights of other consumers to exercise their free speech rights, or exercise another right provided for by law;

• comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.);

• engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the business’ deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent;

• enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;

• comply with a legal obligation; or

• make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Your Right to Know and Right to Delete

To exercise the access and deletion rights described above, please submit your request to us in writing at the address listed below in this Privacy Policy. Only you, or an authorized agent registered with the California Secretary of State that you authorize to act on your behalf, may make a consumer request related to your Personal Information. You may also make a consumer request on behalf of your minor child (12 and under). If you have any questions about your access or deletion rights described above, you may also contact us regular U.S. mail at the contact information set forth below. 

You may only make a Right to Know request twice within a 12-month period.

We cannot respond to your request to delete or provide you with Personal Information if we cannot verify your identity or your authority to make the request and confirm the Personal Information relates to you.

We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

Where possible, we will respond to a verified consumer request within forty-five (45) days of its receipt; however, if we require more time, we will inform you of the reason and extension period.

Any disclosures we provide will only cover the 12-month period preceding the verified consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Personal Information Sales Opt-Out and Opt-In Rights

If you are age 16 or older, you have the right to direct us to not sell your Personal Information at any time. We do not sell the Personal Information of consumers we actually know are less than 16 years old.

To exercise your right to opt-out of “sales” of your Personal Information, you can use a browser with the Global Privacy Control browser extension, or you can use the “Do Not Sell My Personal Information” link available at the bottom of our website homepage. Please also see the “Your Choices” section above for information on your choices with respect to opting out of Circle interest-based advertising and interest-based advertising generally.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• deny you goods or services;

• charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;

• provide you a different level or quality of goods or services; or

• suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer, will reasonably relate to your Personal Information’s value to us and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Sites and Services who are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please contact us using the contact information provided below in this Privacy Policy.

B.  Children

Our Sites and Services are not directed to children under 18 (or other age as defined by local law), and we do not knowingly collect Personal Information from children. If you learn that your child has provided us with Personal Information without your consent, you may contact us at the email address below with the subject line “COPPA Child Information Request.” If we learn that we have collected any Personal Information from a child in violation of applicable law, we will promptly take steps to delete such information.

C.  Supervisory Authority

If you are located in the European Economic Area, you have the right to lodge a complaint with a supervisory authority if you believe our processing of your Personal Information violates applicable law.

D.  Links to Third Party Sites/Applications

Our Sites and Services may contain links to other websites/applications and other websites/applications may reference or link to our Sites and Services. These other websites and applications are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. Circle does not endorse, screen, or approve, and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.

E.  Changes to this Privacy Policy

Circle may revise this Privacy Policy from time to time in our sole discretion. If there are any material changes to this Privacy Policy, we will notify you as required by applicable law, which may include updating our notice on our Sites. You understand that you will be deemed to have accepted the updated Privacy Policy if you continue to use the Services after the new Privacy Policy takes effect.

E. Contact Us

If you have any questions about our privacy practices or this Privacy Policy, please contact us at:

Attn: Legal Dept

Circle The People Inc.

1700 Aviara Parkway #130095

Carlsbad, CA 92011