Legal

Privacy Policy

Last updated: May 2026

Overview

This Privacy Policy describes how CirkleUp ("CirkleUp," "we," "our," or "us") collects, uses, discloses, and safeguards information when you apply for membership, create an account, RSVP to an event, or otherwise use the CirkleUp mobile application and related services (collectively, the "Service").

By using the Service, you consent to the practices described in this Privacy Policy. If you do not agree, you must discontinue use.

We may update this Privacy Policy from time to time. If we make material changes, we will notify you through the App or by email before the changes take effect. Continued use of the Service after notice constitutes your acceptance of the updated policy. The most current version will always be available in the App and at www.cirkleup.com.

1. Information We Collect

Information You Provide

When you apply for membership, create a profile, RSVP to an event, or communicate with us, you may provide personal information including:

• Name
• Email address
• Phone number
• Date of birth
• City or location
• Photographs or profile images
• Biographical details or membership application responses
• Referrals or endorsements
• Instagram handle or publicly available profile information (requested to verify eligibility and assess membership applications)

Automatically Collected Information

We automatically collect certain information when you use the Service, including:

• Device details and identifiers
• IP address
• Operating system and app version
• Usage data, such as session duration, features used, and interactions
• Location information, if you grant permission through your device settings

Event and RSVP Data

When you RSVP to events or participate in CirkleUp-affiliated experiences, we collect and process details such as event attendance, waitlist status, and host approvals.

Contact Information (Optional)

If you grant permission, we may access your contacts to verify mutual connections and facilitate invitations.

2. How We Use Information

We use the information we collect for purposes including:

• Authenticating members and managing accounts
• Evaluating membership applications and eligibility
• Administering invitations, RSVPs, waitlists, and events
• Displaying limited profile information to other approved members in event contexts
• Communicating updates, features, and opportunities
• Personalizing and improving the Service
• Ensuring safety, integrity, and compliance with our Terms & Conditions
• Meeting legal and regulatory obligations

3. How We Disclose Information

To Other Members and Hosts

Limited profile details, such as name, profile photo, and short biography, may be visible to other approved members within event-related contexts. Event hosts may view RSVP and attendance details for events they manage.

To Service Providers

We engage trusted third-party service providers to perform services such as hosting, analytics, email delivery, and payment processing. These providers process data on our behalf and are contractually obligated to safeguard it.

For Legal and Safety Purposes

We may disclose information when required by law, court order, or governmental request, or when we believe disclosure is necessary to protect rights, safety, property, or the integrity of the Service.

In Business Transfers

In the event of a merger, acquisition, financing, or sale of assets, information may be transferred as part of that transaction, subject to applicable laws.

We do not sell or rent personal information to third parties.

4. Your Rights and Choices

Text Message Communications

CirkleUp may send transactional text messages (SMS), including one-time passcodes (OTP) for account verification and notifications related to membership applications, account status, and service updates, to users who have provided consent during registration.

During sign-up and login, users verify their phone number by entering a one-time passcode sent via SMS. By completing this verification and creating an account, users consent to receive automated transactional messages from CirkleUp. Message and data rates may apply. Message frequency varies based on account activity.

You may opt out of non-essential SMS communications at any time by replying STOP to any message. For assistance, contact info@cirkleup.com.

CirkleUp does not share phone numbers with third parties for their own marketing purposes.

• Access and Updates: You may review and update your profile information through the App.
• Communications Preferences: You may opt out of non-essential emails or push notifications in your account settings or by following unsubscribe instructions.
• Account Deletion: You may request deletion of your account by contacting us at contact@cirkleup.com. Certain data may be retained as required by law or for legitimate business purposes.
• California Residents: If you are a California resident, you may have additional rights under the California Consumer Privacy Act (CCPA/CPRA). CirkleUp does not sell personal information. To exercise your rights, contact us at info@cirkleup.com.
• EEA and UK Residents: If you are located in the European Economic Area or United Kingdom, you may have rights to access, correct, delete, restrict, or object to processing and to data portability, subject to applicable law. You may also lodge a complaint with your local data protection authority.

5. Data Retention

We retain information for as long as your account is active or as needed to provide the Service. After account deletion, certain information may be retained for up to ninety (90) days for security, fraud prevention, or legal compliance, unless a longer period is required by law.

6. Security

We use commercially reasonable safeguards to protect personal information. However, no system is completely secure. Members are responsible for maintaining the confidentiality of their account credentials and promptly notifying us of any suspected unauthorized use.

7. Children's Privacy

The Service is intended only for individuals 18 years of age or older. We do not knowingly collect personal information from anyone under 18. If we learn that a minor has provided information, we will delete it promptly.

8. International Transfers

We process and store information in the United States and may transfer it to other jurisdictions where we or our service providers operate. When we transfer information internationally, we implement appropriate safeguards consistent with applicable laws.

9. Links and External Services

The Service may contain links to third-party websites or services. CirkleUp is not responsible for the content or practices of those third parties. We encourage you to review their privacy policies before engaging with them.

10. Governing Law and Venue

This Privacy Policy and any disputes arising under it are governed by the laws of the State of Delaware, without regard to conflict-of-law principles. Subject to the arbitration clause in the Terms & Conditions, the state and federal courts located in Delaware will have exclusive jurisdiction.

11. Changes to This Policy

We may revise this Privacy Policy from time to time. If we make material changes, we will notify you via the App or email. Continued use of the Service after changes take effect constitutes acceptance of the revised Privacy Policy.

12. Contact Us

For questions or concerns about this Privacy Policy, your personal information, or our practices, please contact us at:

CirkleUp
Email: info@cirkleup.com