CIRCA — Privacy Policy

INTRODUCTION

CIRCA is committed to maintaining a safe, open and trusted community. Privacy and confidentiality are fundamental to everything we build.

This Privacy Policy explains how we collect, use, store, and share information when you apply for or use the CIRCA mobile application, website, and related services (collectively, the "Service").

CIRCA is a social experiences app. By using the Service, creating an account, or participating in experiences, you agree to the practices described in this Privacy Policy and our Terms of Service.

If you have any questions, you may contact us at contact@circa-experiences.com

UPDATES TO THIS POLICY

We may update this Privacy Policy from time to time to reflect changes in law, technology, or how CIRCA operates. When we do, we will update the "Last updated" date above.

Your continued use of the Service after changes are posted constitutes acceptance of the revised policy. If you do not agree, you may discontinue use and delete your account.

INFORMATION WE COLLECT

1. Information You Provide

When you create an account or use CIRCA, we may collect the following information:

• Full name
• Date of birth or age confirmation
• Gender (optional)
• Email address and phone number
• Instagram handle and publicly available Instagram information
• Photos you upload
• Biographical information
• School, affiliation, or city
• Referral information, when provided
• Messages and communications within the app
• Any information you provide when contacting CIRCA support

Some of this information may be considered sensitive in certain jurisdictions. By providing it, you consent to our processing of it for the purposes described below.

You may update certain profile information within the app at any time.

2. Information Provided by Other Users

Other users may provide information about you, for example if:

• They refer you to CIRCA
• They report a concern
• You appear in shared experiences or group chats

3. Information Collected Automatically

When you use CIRCA, we may automatically collect:

• Device type, operating system, and app version
• IP address
• General location (city/country level)
• Usage activity (features used, interactions, timestamps)
• Log and diagnostic data

If you allow location permissions, we may collect approximate or real-time location data depending on your device settings. Location sharing with other users is optional and controllable in settings.

4. Third-Party Services

If you access third-party services through CIRCA (e.g. payment providers or embedded links), those services may collect information independently. Their privacy practices are governed by their own policies.

5. Payment Information

All payments are processed through third-party providers (such as Apple, Google, Stripe, or similar).

CIRCA does not store your credit card or banking information.

6. Cookies & Similar Technologies

We may use cookies and similar technologies on our website to:

• Authenticate users
• Remember preferences
• Analyze usage patterns
• Improve performance

We do not currently respond to "Do Not Track" signals.

HOW WE USE YOUR INFORMATION

We use your information to:

• Review and evaluate applications
• Create and manage accounts
• Facilitate experiences and group interactions
• Enable communication between accepted members
• Enforce community standards
• Improve and develop features
• Conduct internal analytics and research
• Process subscriptions and payments
• Communicate with you regarding the Service
• Protect the safety and integrity of the community

We do not sell your personal information.

SHARING OF INFORMATION

1. With Other Users

If your application is accepted, certain profile information may be visible to other members, depending on your tier and settings. This may include:

• First name
• Photos
• City
• Bio
• Mutual connections or shared experiences

Messages and group chats are visible only to participants.

Applicants who are waitlisted or rejected are not visible to the community.

2. With Service Providers

We may share limited information with trusted service providers who help us operate CIRCA (e.g. analytics, infrastructure, email delivery). These providers are contractually bound to protect your information.

3. Legal & Safety Reasons

We may disclose information if required to:

• Comply with legal obligations
• Respond to lawful requests
• Protect the safety of users
• Enforce our Terms or Community Guidelines
• Address fraud, abuse, or security issues

4. Aggregated or Non-Identifiable Data

We may use or share aggregated or anonymized data for analytics, business insights, or research purposes. This data does not identify individuals.

LEGAL BASES FOR PROCESSING (EU/EEA)

We process personal data based on:

• Performance of a contract (providing the Service)
• Legitimate interests (safety, analytics, improvement)
• Your consent (where required)
• Legal obligations

You may withdraw consent at any time where applicable.

DATA SECURITY

We take reasonable technical and organizational measures to protect your information. However, no system is completely secure, and we cannot guarantee absolute security.

Use of CIRCA is at your own risk.

DATA RETENTION

We keep personal information only for as long as needed to operate CIRCA, keep the community safe, prevent fraud, and meet legal obligations. When retention is no longer necessary, we delete or anonymize the data.

Account & profile data

If you delete your account, we delete or anonymize your account and profile information within 30 days (for account recovery and safety/fraud checks).

Messages (deleted on account deletion)

We store messages while your account is active. If you delete your account, messages associated with your account are deleted globally from our servers within 30 days (for both you and any recipients) and are no longer accessible in CIRCA.

Safety & enforcement records

If content is reported, flagged, or needed to investigate abuse or fraud (e.g., reports, blocks, enforcement actions, ban history, relevant device/log signals), we may retain the necessary information for up to 12 months after the report, enforcement action, or account deletion/last activity—unless a longer period is required to resolve an investigation or comply with law.

Backups

Personal data may remain in encrypted backups for up to 90 days before being automatically overwritten or deleted.

Legal/financial records

Where required for legal or accounting purposes (for example, invoices and transaction records), we retain the relevant records for 10 years from the end of the applicable financial year.

YOUR RIGHTS

Depending on your jurisdiction, you may have the right to:

• Access your personal data
• Correct inaccurate data
• Request deletion
• Restrict or object to processing
• Request data portability

Requests can be made by contacting contact@circa-experiences.com.

We may request identity verification before fulfilling requests.

COMMUNICATIONS

By using CIRCA, you may receive:

• Account-related messages
• Experience updates
• Safety or policy notices

You may opt out of non-essential communications at any time.

AGE REQUIREMENT

CIRCA is strictly for users 18 years and older.

We do not knowingly collect information from individuals under 18. If such an account is identified, it will be removed immediately.

INTERNATIONAL DATA TRANSFERS

Your information may be transferred to and processed in countries outside your country of residence. We take reasonable safeguards to protect data in such transfers.

NO THIRD-PARTY RIGHTS

This Privacy Policy does not create rights enforceable by third parties.

GOVERNING LAW

This Privacy Policy is governed by the laws of Switzerland, without regard to conflict-of-law principles, unless otherwise required by applicable regulations.

CONTACT

For questions about this Privacy Policy or your data:

📧 contact@circa-experiences.com