Privacy Policy
Effective Date: 21.08.2023
Circle21 ("we," "our," or "us") is committed to protecting your personal data and your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you access or use our platform ("Services").
By using the Services, you agree to the terms of this Privacy Policy. If you do not agree, please do not use the Services.
1. Data Controller
For GDPR purposes, the data controller responsible for your information is:
Circle21 Global Limited
8-10 South Street
Epsom, Surrey
KT18 7PF
England
Email: contact@circle21.app
If you have any questions about this policy, please contact us
2. Information We Collect
2.1 Information You Provide
We collect personal data directly from you in the following circumstances:
- Name, email address, and payment information,
- Account Creation: When you create an account, we collect personal data such as your date of birth, name, email address, password, and country.
- Event Registration: When you register for an event, we collect information required to process your registration, such as:
- Additional details requested by event organizers, which may include:
- Address
- T-shirt size,
- Phone number,
- Emergency contact information,
- Social media handles (e.g., Instagram, Facebook, Twitter).
- Customer Support: When you contact customer support, we collect the information necessary to respond to your inquiries or resolve issues.
- Content Submission: When you submit content (e.g., reviews, feedback, or event-related media), we collect the information you provide in your submissions.
2.2 Information We Automatically Collect
We may collect information automatically when you use the Services, including:
- Device information (e.g., IP address, browser type),
- Usage data (e.g., pages visited, time spent on the Site)
- Cookies and tracking technologies.
2.3 Payment Information
All payments are processed via third-party providers such as Stripe or PayPal. We do not store payment card details. Please review their privacy policies for details on data handling.
3. How We Use Your Information
We process your personal data for the following purposes:
- To provide, operate, and improve the Services,
- To manage registrations for events and facilitate payments,
- To communicate with you, including sending notifications, updates, and support responses,
- To enforce our Terms of Service and detect fraud,
- To comply with legal obligations.
4. Legal Basis for Processing
We process your data under the following legal bases:
- Contractual Necessity: To provide the Services you request, such as registering for events,
- Legitimate Interests: To improve our Services, detect fraud, and enhance security,
- Consent: Where required, we will seek your consent for specific data processing activities,
- Legal Obligations: To comply with laws or regulations.
5. Sharing Your Information
We may share your data with:
- Third-Party Processors: Payment providers like Stripe or PayPal, hosting services, and analytics providers,
- Event Organizers: Limited information (e.g., name and email) for event registration purposes,
- Legal Authorities: When required to comply with legal obligations or protect our rights.
All third parties are contractually obligated to handle your data securely and in compliance with GDPR.
6. Meta Business Integration
Circle21 provides an optional integration with Meta Business services that allows event organizers to connect their Meta Business account with Circle21 and measure interactions with their competitions and registration flows. When an event organizer chooses to connect a Meta Business account, Circle21 may receive and process information and permissions made available through Meta's APIs, such as information relating to the connected Meta Business assets, advertising or measurement assets, and identifiers required to configure and use the integration. The Meta Business integration is used solely to provide measurement and analytics functionality for event organizers. In particular, Circle21 may use the integration to send measurement events to Meta, including events relating to:
- Viewing competition or registration content (ViewContent),
- Initiating a purchase or registration (InitiateCheckout),
- Completing a purchase or registration (Purchase).
Depending on the event and the applicable configuration, information associated with an interaction may be transmitted to Meta for the purpose of measuring and attributing these events. This may include technical information such as browser or device information, IP address, cookies or similar identifiers, and other information necessary to support event measurement. Where applicable, information may be transformed or hashed before being transmitted to Meta. Circle21 does not use information obtained through the Meta Business integration for purposes unrelated to providing the integration and its measurement functionality. We do not sell Meta account information or use it for independent advertising purposes. The connection to a Meta Business account is initiated by the event organizer and requires the organizer to authorize the requested permissions through Meta's authorization flow. The organizer may disconnect the Meta Business integration from Circle21 at any time. Disconnecting the integration prevents Circle21 from using the connection for future event measurement, although information already transmitted to Meta may remain subject to Meta's own policies and retention practices. Meta processes information in accordance with its own policies and terms. For more information about how Meta collects, uses, stores and protects information, please review the Meta Privacy Policy and applicable Meta Platform Terms and policies. If you wish to request deletion of information associated with your Circle21 account or Meta Business integration, you may contact us at contact@circle21.app. We will process deletion requests in accordance with our legal obligations and applicable data protection laws.
7. International Data Transfers
If your data is transferred outside the European Economic Area (EEA), we ensure adequate safeguards are in place, such as Standard Contractual Clauses or reliance on adequacy decisions by the European Commission.
8. Data Retention
We retain your personal data only as long as necessary to provide the Services or comply with legal requirements. For example:
- Account data is stored until you delete your account,
- Transaction data is retained as required by financial regulations.
9. Your Rights
As an EU/EEA user, you have the following rights under GDPR:
- Access: Request a copy of your personal data,
- Rectification: Correct inaccuracies in your data,
- Erasure: Request deletion of your data ("right to be forgotten"),
- Restriction: Limit how your data is processed,
- Portability: Receive your data in a structured, commonly used format,
- Objection: Object to certain types of processing,
- Withdraw Consent: Withdraw consent where processing is based on consent.
To exercise your rights, contact us at contact@circle21.app.
10. Data Security
We implement appropriate technical and organisational measures to protect your data against unauthorised access, loss, or misuse. These include encrypted data storage, access controls, and secure servers.
11. Cookies and Tracking
We use cookies and similar technologies to enhance your experience, analyse usage.
For more details, refer to our Cookie Policy.
12. Children's Privacy
Our Services are not intended for children under the age of 10 (or the applicable age in your country). We do not knowingly collect personal data from children without parental consent.
13. Updates to This Privacy Policy
We may update this Privacy Policy from time to time. Significant changes will be communicated to you via email or prominent notices on the Site. Please review this policy periodically.
14. Complaints
If you believe we have violated your data protection rights, you can file a complaint with your local Data Protection Authority.
In the UK: UK Information Commissioner's Office (ICO)
Contact Us
If you have any questions about this Privacy Policy or wish to exercise your rights, please contact us:
Circle21 Global Limited
contact@circle21.app