This Privacy Policy document outlines the types of information that is
collected and recorded by Circles, how we use it and why.
This Privacy Policy applies to all the Users whose Personal Information
has been processed by Us in the course of our business, mobile
applications, forums, blogs, and other online or offline offerings
By visiting the Platform, You (“You” or “Your”), accept and agree to be
bound by the terms and conditions of this privacy policy (“Privacy
Policy”).
By using the Service, you hereby consent to allow us to process
information in accordance with this Privacy Policy. Please also refer to
our Terms of Service, available here
https://circles.royalecheese.com/terms, which are incorporated as if
fully recited herein. Terms defined in the Terms of Service that are not
defined herein shall have the same definition as in the Terms of
Service. This policy is subject to change. If our information retention
or usage practices change, we will let you know by posting the Privacy
Policy changes on the Service and/or otherwise making you aware of the
changes. Your continued use of the Service following our notice of
changes to this Privacy Policy (or other method of legal acceptance)
means you accept such changes. Please refer to the “Effective Date”
above to see when this Policy was last updated.
Personal Information We Collect
What is Personal Information?
When we use the term “Personal Information” in this Privacy Policy, we
mean information that identifies, relates to, describes, is reasonably
capable of being associated with, or could reasonably be linked,
directly or indirectly, to an individual. It does not include aggregated
or de-identified information that is maintained in a form that is not
reasonably capable of being associated with or linked to an individual.
We collect Personal Information in connection with your visits to and
use of the Service. This collection includes information that you
provide in connection with the Service, information from third parties,
and information that is collected automatically such as through the use
of cookies and other tracking technologies.
What Personal Information is collected from you?
We collect Personal Information from you that you may provide to us
through the Service or otherwise. The categories of information we
collect may include
Contact information,For example, your first and last name,
email and mailing addresses, and phone number.
Account and profile information, For example, Personal
Information you provide to us after you create a user account. The
Personal Information we collect could include your contact information,
Demographic data, date of birth, gender, interests , credit score,
income, Transaction Data, Digital Purchase Data,Online/physical Receipt
Data, Banking data, Browsing Data, Survey Responses, Cashback Offer Data
and Health Information. We also collect additional information if you
provide it.
Communications data, based on our exchanges with you,
including when you contact us through the Service, social media, or
otherwise;
Transaction Data,This includes the data related to your
linked bank account(s) or credit or debit card(s) (a “Payment
Credential”): account numbers and card transaction data collected and
stored by our third-party providers (including credit and/or debit card
transaction data collected by our third-party providers, that covers the
prior 48 months and all subsequent transactions ), bank fees and
refunds, direct deposits, rent and/or mortgage payments, and bill
payments (collectively, the “Transaction Data”).
Digital Purchase Data,We also collect purchase information,
such as item/SKU-level data, through email accounts or digital consumer
accounts that you link to your Circles account (collectively, the
“Linked Account(s)”). Our Rewards Program allows you to link email
accounts or digital consumer accounts to your Circles account, as
directed by you, through the use of your login credentials to such
account(s) so that Circles, as your agent, can retrieve purchase
information from digital receipts from historical (up to 50 years prior)
and future purchases in your digital consumer account or email. In
processing your digital receipt data, Circles may retrieve Personal
Information such as name, payment method, billing address, mailing
address, and other information contained in the digital receipt email
(collectively, the “Digital Account Data”).
The account credentials that you enter for these accounts are not stored
with Circles, but are encrypted and stored locally on your device.
While linked, Circles will automatically collect digital receipt data
from your linked email accounts.
Survey Responses,For example, information you provide when
answering survey questions in the App, which may include information
about your activities/interests, opinions about products/services,
household information, and other demographic information.
Marketing data, such as when you sign up to receive
information regarding our products and details about your engagement
with them;
Job application data, such as information you submit in
connection with an application for a job (including information in a CV,
resume or otherwise collected through the job application process);
Third-party sources. We may combine personal information we
receive from you with personal information we obtain from other sources,
such as:
Public sources, such as government agencies, public
records, social media platforms, and other publicly available sources;
Private sources, such as social media platforms, including
Instagram, LinkedIn, and Twitter.
Automatic data collection. We, our service providers, and
our business partners may automatically log information about you, your
computer, and your interaction over time with the Service, our
communications and other online services, such as: Device data, such as
your computer operating system type and version, manufacturer and model,
browser type, screen resolution, RAM and disk size, CPU usage, device
type (e.g., phone, tablet), IP address, unique identifiers (including
identifiers used for advertising purposes), language settings, mobile
device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and
general location information such as city, state or geographic area;
Online activity data, such as pages or screens you viewed, how long you
spent on a page or screen, the website you visited before browsing to
the Service, navigation paths between pages or screens, information
about your activity on a page or screen, access times and duration of
access, and whether you have opened our emails or clicked links within
them.
Cookies and similar technologies. Some of the automatic
collection described above is facilitated by the following technologies:
Cookies, which are small text files that websites store on user devices
and that allow web servers to record users’ web browsing activities and
remember their submissions, preferences, and login status as they
navigate a site. Cookies used on our sites include both “session
cookies” that are deleted when a session ends, “persistent cookies” that
remain longer, “first party” cookies that we place and “third party”
cookies that our third-party business partners and service providers
place.
Data Connections, We may receive your personal and digital
data from external accounts, such as Flipkart, Amazon or Google once
connected
For Gmail users:
We comply with the
Google API Services User Data Policy, including the Limited Use requirements, and use information collected
through your use of My Purchases from your Gmail account only to provide
you points for your purchases on behalf of our participating partners
and to improve user-facing features on the App or Website. We do not
share your information that we receive through Google Gmail APIs with
third parties other than those service providers as necessary to support
functions we need to provide you points for your purchases, for legal or
security reasons, or as part of an acquisition or liquidation.
User content, For example, information about how you use
the Service and interact with us, including information associated with
any content you submit to us, and information you provide when you use
any interactive features of the Service.
Other information,
We may collect additional
types of information which we will use in accordance with this Privacy
Policy or as otherwise disclosed at the time of collection.
What Personal Information is collected from third-parties?
We also obtain Personal Information from third parties, which we often
combine with Personal Information we collect either automatically or
directly from you. We may receive the same categories of Personal
Information as described above from the following third parties:
Information we obtain from social media platforms
We may maintain pages on social media platforms, such as
Facebook, LinkedIn, Twitter, Google, YouTube, Instagram, and other
third-party platforms. When you visit or interact with our pages on
those platforms, the platform provider’s privacy policy will apply to
your interactions and their collection, use and processing of your
Personal Information. You or the platforms may provide us with
information through the platform, and we will treat such information in
accordance with this Privacy Policy.
Information we obtain from health trackers and apps
At your request, we may also collect Health Information
gathered or generated by your use of any third-party health application,
system, program and/or device that you connect to the Service (the
“Connected Health Systems”).
For example, if you choose to connect Apple’s Health app on your iPhone
or Apple Watch, we may receive information such as Activity History
(i.e., steps taken, workouts, sleep etc.,), Health Vitals (i.e., body
temperature, heart rate), Self-Reported Characteristics (i.e., height,
weight, body fat percentage, gender), Clinical Records (i.e., protein
samples, lab results) and information about the source of such data. The
data we receive from these third-party sites is dependent upon that
third party’s policies and your privacy settings on that third-party
application, system, program and/or device. You should always review,
and if necessary, adjust your privacy settings on third-party websites
and services before linking or connecting them to our Service.
Information we obtain from service providers
Our
service providers that perform services solely on our behalf, such as
payment processors, video and audio providers, or survey and certain
advertising/marketing providers, collect Personal Information and may
share some or all of this information with us.
Referrals
Users of the Service may refer friends
or other contacts to us. If you are an existing user, you may only
submit a referral if you have permission to provide the referral’s
contact information to us so that we may contact them.
Information we obtain from other third parties
We may receive Personal Information about you from
third-party sources. For example, a business partner may share your
contact information with us if you have expressed interest in learning
specifically about our products or services, or the types of products or
services we offer. We may obtain your Personal Information from other
third parties, such as marketing partners, publicly available sources
and data providers. Personal Information obtained from these third
parties may include payroll information (e.g., hours worked, wages
earned, and tax withholdings etc., ). We also may obtain your
information from brand partnerships or through transactions such as
mergers and acquisitions.
Deidentified information
Through the provision
of our Service, we may also process deidentified information that cannot
reasonably be used to infer information about, or otherwise be linked
to, a particular consumer or household. Circles commits to maintain and
use the information in deidentified form and will not attempt to
reidentify the information, except in instances where necessary for
determining whether the deidentification process used by Circles
satisfies the requirements under applicable law.
How we use and protect your Personal Information
Circles uses your Personal Information to deliver the Service to you,
the goal of which is to help you earn money on everyday purchases and to
identify relevant savings opportunities. This includes using your
Personal Information to do the following:
Fulfill your requests and provide the Service to youThis includes
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Making the Service available to you and Participating Businesses;
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Coordinating access to your account, and establishing and
maintaining your user profile on the Service;
-
Enabling the security features of the Service, such as by sending
you security codes via email or SMS, and remembering devices from
which you have previously logged in;
-
Responding to requests, suggestions, questions, and comments, and
providing other types of user support;
-
Sending you service/transaction-related messages, such as changes to
your account;
-
Communicating about, and administering your participation in,
events, conferences, programs, contests, surveys, polls, panels,
questionnaires, and other offers or promotions; and Providing
support and maintenance for the Service.
-
Serve You Targeted Advertisements. We may use your PII to serve you
advertisements with the Service that are targeted to your interests.
Personalize your experience on our Service
This
includes providing you with content or other products or services you
might be interested in and de-emphasize content you’ve already read or
viewed.
Market our service
We will send you
communications about new features, updates, products, and special
offers. We may also use your information to serve you ads about our
products or other products or services we (or our advertising partners,
such as other third-party brands) think you might find interesting. We
may also use individual and aggregate information about you to inform
our marketing and advertising campaigns.
Communicate with you
For example, we may
communicate with you about your account activities, such as by providing
you transaction confirmations or alerting you when a subscription is up
for renewal. If you register with us, we may enroll you in our email
newsletters or other periodic electronic communications and may also
send you user surveys and promotional communications. We may communicate
with you by email, postal mail, telephone, text message, or other means.
For more information on how to adjust your communications preferences,
see “The choices you have regarding our collection, use and sharing
practices” section of this Privacy Policy.
Monitor, improve, and develop our products and servicesWe
may use your information to understand our visitors and customers and to
tailor or optimize our Service. For example, we may analyze statistics
and trends to make our Service better and to develop the Site or new
services or features.
Prevent fraud
We may use your Personal
Information and disclose it to law enforcement, government authorities,
and private parties as we believe necessary or appropriate to protect,
investigate and deter against fraudulent, harmful, unauthorized,
unethical or illegal activity.
Protect the security and integrity of our business, comply with legal
requirements and obligations, or as otherwise permitted by law
We may use information to protect Pogo, our users, and our
Service. We may also use information in order to comply with laws,
regulations, court orders, or other legal obligations or to assist in an
investigation, protect and defend our rights and property, or the rights
or safety of third parties, enforce our Terms of Use, this Privacy
Policy, or agreements with third parties, detect and prevent fraud or
for crime-prevention purposes, or for any other reason permitted by law.
We may take part in or be involved with a corporate business
transaction, such as a merger, acquisition, joint venture, or financing
or sale of company assets and may use information in connection with or
as an asset in such a corporate business transaction. Personal
Information may also be used in the event of insolvency, bankruptcy, or
receivership.
Create anonymous, aggregated or de-identified data
We may use this anonymous, aggregated or de-identified data
and share it with third parties for our lawful business purposes,
including to analyze and improve the Service and promote our business.
For any other purposes with your consent, at your direction, or where
notice is provided
We may use your Personal Information for any other purposes
with your consent, at your direction, or where notice is otherwise
provided.
Purchase DataIn addition to the use cases
described above, Circles and
Participating Businesses
may use your Transaction Data, Digital Purchase Data, Other Receipts
Data, Browsing Data, Location data and Survey Responses (collectively,
the “Purchase Data”) in these ways to deliver the Service to you
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To credit you with automatic cash back when you make qualifying
purchases;
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For market research and providing insights into consumer purchasing
behaviors and conducting surveys based on past purchases;
- To provide targeted offers that may be of interest to you;
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To confirm a specific transaction occurred or rewards should be
provided;
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To create a record of your Purchase Data to use data in connection
with the Service;
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To respond to a request from government authority or a payment
organization involved in a transaction with you or a Participating
Business;
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To analyze bank fees charged on your Payment Credential to: (i)
generate an email you can send to your bank to request the bank to
provide a refund of such fees, if applicable; and (ii) recommend a
low interest loan from a partner to pay off high interest credit
card debt;
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To help identify ways you can save money on insurance, loans, bills,
utilities, prescriptions, mortgage payments and other third-party
services.
- To provide you rewards relating to item/SKU-level purchases.
Health Information With your permission, your
Health Information may be used by or shared with Circles and
Participating Businesses
in these ways to deliver the Service to you
-
For market research and providing insights into consumer health
behaviors/conditions and conducting surveys based on health
attributes;
- To build and enhance consumer profiles;
- To provide targeted offers that may be of interest to you;
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To surface clinical study or other research study opportunities for
which you may be eligible to participate in.
Security Practices
We employ a number of
organizational, technical and physical safeguards designed to protect
the Personal Information we collect.
We do not store your payment card or bank account information, and we do
not have control over or responsibility for your payment card or bank
account information. When you provide your payment card and/or bank
account information through the Site or App, it is stored and/or
processed by our third-party service providers.
Please note that security risk is inherent in all internet and
information technologies, and we cannot guarantee the security of your
Personal Information.
How we share your personal information
Circles may disclose your Personal Information when you share content
with others on the Service, when you consent or instruct us to share
your information with third parties, or when we have a legitimate
business or legal need to share your information.
For example, your information may be shared with
AffiliatesWe may share your Personal
Information with our corporate parent, subsidiaries, and affiliates, for
purposes consistent with this Privacy Policy.
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Making the Service available to you and Participating Businesses;
-
Coordinating access to your account, and establishing and
maintaining your user profile on the Service;
-
Enabling the security features of the Service, such as by sending
you security codes via email or SMS, and remembering devices from
which you have previously logged in;
-
Responding to requests, suggestions, questions, and comments, and
providing other types of user support;
-
Sending you service/transaction-related messages, such as changes to
your account;
-
Communicating about, and administering your participation in,
events, conferences, programs, contests, surveys, polls, panels,
questionnaires, and other offers or promotions; and
- Providing support and maintenance for the Service.
Participating Businesses through the Rewards Program
If you have opted in to Data Rewards, we may share your
Personal Information, including Racial / Ethnic Origin, Precise
Geolocation and Health Information, with participating businesses,
including our affiliates and subsidiaries, our service providers or
advisors, marketing/advertising and strategic partners, analytics
providers; social networks; our clients, partnered brands, retailers and
agencies (collectively, "Participating Businesses"). These Participating
Business partners will use this data in accordance with their own
privacy policies. If you have opted out of Data Rewards, we will not
share this information with Participating Businesses, in accordance with
our market research or personalized advertisements initiatives.
Service providers
We may share your Personal
Information with third party companies and individuals that provide
services on our behalf or help us operate the Service (such as customer
support, hosting, analytics, email delivery, advertising, marketing, and
database management services).
Information we process to understand how our products are used and
make improvements
Firebase, Google analytics, Sentry & more.
Pharmaceutical and healthcare partners
At your
direction, we may share your Personal Information, including your Health
and Location Data, with our pharmaceutical and healthcare partners.
Lending and insurance partners
We may share your
pre-qualification information (i.e., birthdate, credit score, gender,
and income) with our loan and insurance partners.
Other users of the Service and the public
We may
enable you to disclose Personal Information to other users of the
Service or the public at your direction. For instance, you may be able
to maintain a user profile with information about yourself that you can
make available to other users or the public. You may also be able to
submit content to the Service (such as comments, reviews, surveys,
blogs, photos, and videos), and we will display your name, username, and
a link to your user profile along with the content you submit. We do not
control how other users or third parties use any Personal Information
that you make available to such users or the public.
Professional advisors
We may disclose your
Personal Information to professional advisors, such as lawyers, bankers,
auditors and insurers, where necessary in the course of the professional
services that they render to us.
For compliance, fraud prevention and safety
We
may share your Personal Information for compliance, fraud prevention and
safety purposes.
Law enforcement, regulators, and other parties for legal
reasons
We may share your Personal Information with third parties
as required by law or subpoena or if we reasonably believe that such
action is necessary: (a) to comply with the law and the reasonable
requests of law enforcement; (b) to enforce our Terms of Use or to
protect the security or integrity of our Service; and/or (c) to exercise
or protect the rights, property, or personal safety of Circles, our
users, visitors, or others.
Business transfers
We may sell, transfer or
otherwise share some or all of our business or assets, including your
Personal Information, in connection with a business transaction (or
potential business transaction) such as a corporate divestiture, merger,
consolidation, acquisition, reorganization or sale of assets, or in the
event of bankruptcy or dissolution.
With your consent or according to your instructions
We may share information in other ways if you give us
consent or direct us to do so, such as sharing your Personal Information
for market research or personalized advertisements.
Our third party data collection and online advertising practices
Circles may participate in interest-based advertising and use third
party advertising partners to collect information from visitors to the
Service for the purpose of displaying interest-based advertisements on
other websites, apps or services, social networks, or on other devices
you may use. Typically, though not always, these third-party ad networks
use cookies and tracking technologies to recognize your browser or
device and to collect information about your visit to our Service to
provide you with customized content, advertising, and commercial
messages which may be more relevant to your interests, as well as to
provide advertising-related services such as reporting, attribution,
analytics, and market research.
Please see the section below to learn how you can opt out of
interest-based advertising.
Are There Other Ways My Personal Data Could Be Shared?
You may elect to share certain personal information with
individuals, entities, or with the public via your use of the Service.
In this case, you will control such sharing via settings that we
provide. For example, the Service may make it possible for you to
publicly share information via Platforms such as Facebook, or Instagram.
Be aware that when you choose to share information with friends, or with
the public at large, you may be disclosing sensitive information, or
information from which sensitive information can be inferred. Always use
caution when sharing information through the Service. You understand and
agree that we are not responsible for any consequences of your sharing
of information through and beyond the Service.
Your choices
In this section, we describe the rights and choices available to all
users:
Access or Update Your Information
If you have
registered for an account with us, you may review certain Personal
Information in your account profile by logging into your account and
navigating to “Profile” in the App. To delete your account, you can
contact us at
arjav@royalecheese.com
Opt-out of marketing communications. You may opt-out of
marketing-related emails by
contacting us at arjav@royalecheese.com. Please note that
if you choose to opt-out of marketing-related emails, you may continue
to receive service-related and other non-marketing emails.
Opt in for Data Rewards
By default when you sign
up on Circles, you will be opted in to sharing certain Personal
Information for market research or personalized advertisements, you will
earn rewards in connection with this opt-in (“Data Rewards”).
You may opt out of this by contacting us at arjav@royalecheese.com
Please note that if you are not opted-in to Data Rewards, certain
incentives and Services affiliated with the Circles Rewards Program may
not be available to you.
Deleting Your Information
you can contact us
directly at
arjav@royalecheese.com
Cookies & Other Tracking Technologies
To
manage cookies, an individual may have the ability to change their
browser settings to (for example): (i) notify them when they receive a
cookie, so the individual can choose whether or not to accept it; (ii)
disable existing cookies; or (iii) automatically reject cookies (or
certain types of cookies, such as cookies set by third parties). Note
that similar controls may exist for other tracking technologies, such as
pixels, SDKs, and localStorage. Please check your device or browser
settings and related documentation for more information.
Further, note that restricting the use of these technologies might
negatively impact an individual’s experience using our Service, as some
features or offerings may be less personalized or may not work as
otherwise intended. Depending on an individual’s device and operating
system, the individual may not be able to delete or block all cookies or
other tracking technologies described in this Privacy Policy. In
addition, if an individual wants to reject cookies across all browsers
and devices, the individual will need to do so on each browser and
device they use. An individual may also have options within their email
client to prevent the automatic downloading of images that may contain
technologies that would allow us to know whether they have accessed our
email and performed certain functions with it.
Advertising choices. You may be able to limit use of your
information for interest-based advertising through the following
settings/options/tools:
Browser settings. Changing your internet web browser
settings to block third-party cookies.
Privacy browsers/plug-ins. Using privacy browsers and/or
ad-blocking browser plug-ins that let you block tracking technologies.
Platform settings. Google and Facebook offer opt-out
features that let you opt-out of use of your information for
interest-based advertising.
We cannot offer any assurances as to whether the companies we work with
participate in the opt-out programs described above.
Right to Know/Right to Delete. You may submit a request to
know, access, correct or delete the information we have collected about
you by sending a request to arjav@royalecheese.com. You can also update
your account information or delete your account / data by contacting us
through the above email.
Our policies on other sites, mobile apps and services
The Service may contain links to other websites, mobile applications,
and other online services operated by third parties. These links are not
an endorsement of, or representation that we are affiliated with, any
third party. In addition, our content may be included on web pages or in
mobile applications or online services that are not associated with us.
We do not control third party websites, mobile applications or online
services, and we are not responsible for their actions. Other websites,
mobile applications and services follow different rules regarding the
collection, use and sharing of your Personal Information. We encourage
you to read the privacy policies of the other websites, mobile
applications and online services you use.
Children
The Service is not directed to, and we do not knowingly collect Personal
Information from, anyone under the age of 18. If a parent or guardian
becomes aware that his or her child has provided us with information
without their consent, he or she should contact us and we will promptly
delete such information. We encourage parents with concerns to contact
us at arjav@royalecheese.com
Retention
We will usually store the Personal Information we collect about you for
no longer than necessary to fulfill the purposes for which it was
collected, and in accordance with our legitimate business interests and
applicable law. However, if necessary, we may retain Personal
Information for longer periods of time, until set retention periods and
deadlines expire, for instance where we are required to do so in
accordance with legal, tax and accounting requirements set by a
legislature, regulator or other government authority.
To determine the appropriate duration of the retention of Personal
Information, we consider the amount, nature and sensitivity of the
Personal Information, the potential risk of harm from unauthorized use
or disclosure of Personal Information and if we can attain our
objectives by other means, as well as our legal, regulatory, tax,
accounting and other applicable obligations.
Once retention of the Personal Information is no longer necessary for
the purposes outlined above, we will either delete or deidentify the
Personal Information or, if this is not possible (for example, because
Personal Information has been stored in backup archives), then we will
securely store the Personal Information and isolate it from further
processing until deletion or deidentification is possible.
Changes to this Privacy Policy
We reserve the right to modify this Privacy Policy at any time. If we
make material changes to this Privacy Policy, we will notify you
including by updating the “Effective date” at the top of this Privacy
Policy. Any modifications to this Privacy Policy will be effective upon
our posting the new terms and/or upon implementation of the new changes
on the Service (or as otherwise indicated at the time of posting).
How to contact us
Please direct any questions or comments about this Privacy Policy or
privacy practices to arjav@royalecheese.com.