Privacy Policy — Circle
Effective Date: 29 September 2025 Last Updated: 15 July 2026
1) Introduction
This Privacy Policy describes how Circle (“Circle,” “we,” “us,” or “our”) collects, uses, discloses, and protects information when you use the Circle mobile and web applications, and any related services (collectively, the “App”).
We are committed to protecting your privacy and being transparent about our data practices.
Contact Information
Company: CircleHub Email: hello@circlehub.io Support: hello@circlehub.io Address: Ahmed Abdel-Azim St, Maadi, Cairo, Egypt
- Account Data: name, username/handle, email or phone number, password (hashed), profile photo, age range.
- Profile & Social Fields: bio, interests, links, work/study details (optional).
- Contacts Sync (optional): with your explicit consent, we may upload and hash phone numbers from your address book to help you find friends on Circle. You can disable this at any time (see Your Choices).
- User Content: posts, messages, photos, videos, circle/event titles and descriptions, comments, reactions, attendance (RSVP/check-ins), and other content you create.
- Organizer Data (B2B): community/event details, tickets, pricing, branding, and attendee lists you manage.
- Organizer Payout & Verification Data: if you create a paid circle, event, or community, you must be onboarded as a payment recipient through our payment gateway, Paymob. Depending on your monthly transaction volume, this includes:
- Under EGP 50,000/month: a photo of your national ID card and the bank account or e-wallet number that will receive payouts, held in your name.
- EGP 50,000/month and above: commercial registration documents, tax card, and business bank account details. This data is collected to satisfy Paymob’s Know Your Customer (KYC) and anti-money-laundering (AML) obligations under Egyptian financial regulations, and to route payouts to the correct organizer.
- Communications: messages you send to support or feedback you submit.
- Payments: we receive transaction metadata (amount, currency, time, item, status) for purchases made in the App. We do not store full payment card details; these are handled directly by our payment processor, Paymob.
- Device & Tech Data: device model, OS version, app version, language, IP address, identifiers (e.g., IDFA/GAID if permitted), crash reports, performance logs.
- Usage Data: features used, pages/screens viewed, session duration, referral source, taps/clicks, in-app navigation.
- Location Data (optional): precise or approximate location only with your explicit permission to discover nearby circles/events or show relevant content.
- Cookies/Local Storage (web): to keep you signed in, remember preferences, and measure performance.
- Social/Single-Sign-On: if you log in via Apple/Google/Facebook, we receive your basic profile and a token to authenticate.
- Payment Gateway — Paymob: Paymob is our integrated payment processor for all paid circles, events, and communities on Circle. Paymob provides us with:
- Transaction confirmation and settlement data for purchases made by attendees.
- Payout status data for organizers, once an organizer’s KYC/AML verification is complete. Paymob independently collects and verifies the KYC/AML documents described above (national ID, bank/wallet details, or commercial registration and tax documents) as part of onboarding organizers as payment recipients. Paymob’s own privacy and data-handling terms also apply to this processing.
- OTP Provider: verification status from our SMS/WhatsApp one-time-code provider.
- Analytics/Crash Reporting: aggregated usage and diagnostics from our analytics and crash-reporting providers.
We use information to:
- Provide the App: create/manage your account, let you create and join circles/events/communities, enable chat and content sharing, handle tickets and paid circles.
- Operate Organizer Tools: allow businesses/hosts to manage communities, events, circles, attendees, and analytics related to their own properties.
- Process Payments & Payouts: enable attendees to pay for paid circles/events/communities through Paymob, verify organizers for payout eligibility, route payouts to organizers net of Circle’s service commission, and reconcile transactions.
- Verification & Security: OTP login, detect/prevent fraud, abuse, spam, and policy violations; content moderation (including automated and human review where necessary); support Paymob’s KYC/AML checks for organizer payouts.
- Improve & Personalize: debug issues, measure performance, recommend circles/events/people, and tailor feeds.
- Communicate: send transactional messages (e.g., confirmations, security alerts, payout notifications), respond to support requests, and — if you opt in — send product updates or marketing.
- Legal/Compliance: comply with applicable laws (including financial and AML regulations) and enforce our Terms.
Legal Bases (EU/UK)
- Contract: to provide the services you request, including processing payments and payouts.
- Legitimate Interests: analytics, security, improvement, minimal personalization.
- Consent: location, contacts sync, marketing, personalized ads (where applicable).
- Legal Obligation: tax, accounting, fraud prevention, AML/KYC, and regulatory requests.
We do not sell your personal information.
We may share:
- Service Providers (processors): cloud hosting and database providers, analytics and crash-reporting tools, messaging/OTP providers, content delivery networks, and customer-support platforms (a current list of vendors is available on request).
- Payment Gateway — Paymob: we share attendee transaction data with Paymob to process payments, and organizer identity, business, and banking information with Paymob so it can verify organizers and disburse payouts. Circle deducts its service commission from each transaction before payout; the commission amount is disclosed to organizers at the point of setting up a paid circle/event.
- Organizers/Hosts (B2B): if you join/buy a ticket for a specific event/community, we share relevant registration/attendance details with that organizer so they can operate the event (e.g., name, contact, ticket status). Organizers’ handling of your data is also governed by their own privacy terms.
- Legal/Compliance: to comply with law, enforce terms, protect rights, safety, and security, including AML/KYC obligations tied to payment processing.
- Business Transfers: in connection with a merger, acquisition, or sale of assets.
- With Your Consent: e.g., when you connect a third-party account or opt into promotions.
5) Your Choices & Controls
- Privacy & Visibility: when creating circles/events, you can choose visibility (e.g., public, followers, invite-only) and content exposure (e.g., full vs. limited details). Information you make public can be seen by anyone.
- Organizer Payout Data: organizers can review, update, or request correction of their KYC/payout information via Settings ▸ Payments, or by contacting Paymob support directly. Note that incomplete or outdated KYC information may delay or block payouts.
- Contacts Sync: turn off in Settings ▸ Privacy ▸ Contacts, and request deletion of uploaded contact hashes.
- Location: disable in device settings; you can still use the App with reduced functionality.
- Marketing: opt out via in-app settings or unsubscribe links.
- Personalized Ads (where applicable): opt out in settings (CPRA “Do Not Sell or Share” and GDPR consent tools where required).
- Cookies (web): manage via our cookie banner and your browser settings.
6) Data Retention
- Account & Profile: retained while your account is active.
- User Content: until you delete it or your account is deleted; residual copies may persist briefly in backups.
- Organizer Records & Transactions: generally retained 3 years (or longer if required for tax/audit).
- Organizer KYC/AML Documents: retained for as long as required under applicable Egyptian financial and AML regulations and Paymob’s own regulatory obligations, and in any case no longer than necessary for payout, tax, and compliance purposes.
- Analytics/Logs: typically 12–24 months (aggregated thereafter).
- Legal Holds: as required by law.
7) Your Rights
Depending on your location, you may have rights to:
Access your data; Correct inaccuracies; Delete your data; Restrict or Object to processing; Portability; Withdraw Consent (for consent-based processing).
- California (CPRA): right to know, delete, correct, and opt out of “sale”/”sharing” (we do not sell; targeted advertising may constitute “sharing” — you can opt out).
- EU/UK GDPR: contact us to exercise rights or lodge a complaint with your local authority.
- Organizer Financial Data: requests to delete KYC/payout data may be limited while regulatory retention obligations under Paymob’s AML/KYC framework are in effect.
How to exercise: use in-app Settings ▸ Privacy, or email hello@circlehub.io. We may verify your identity before responding.
8) Account Deletion & Data Export
- Delete your account: Settings ▸ Account ▸ Delete Account or email us from your registered email at hello@circlehub.io.
- We will permanently delete or de-identify your personal data within 30 days, subject to legal retention (including organizer KYC/transaction records subject to Section 6).
- Export your data: request via Settings ▸ Privacy ▸ Export (if available) or email us.
9) Children’s Privacy
Circle is not intended for children under 13. We do not knowingly collect personal data from children under 13. If you believe a child provided data to us, contact us and we will delete it.
10) Child Sexual Abuse and Exploitation Policy
We have a zero-tolerance policy towards child sexual abuse and exploitation (CSAE). Our app and related services strictly prohibit any content or behavior that sexually exploits, abuses, or endangers children. This includes, but is not limited to, grooming, solicitation, distribution of child sexual abuse material (CSAM), sextortion, or any other activity that may harm or exploit minors.
We actively monitor and enforce these standards. Any user or content found violating this policy will be immediately removed and reported to the appropriate authorities.
If you encounter any content or behavior that may involve the exploitation or abuse of a child, please report it immediately to us at hello@circlehub.io, and to local authorities if appropriate.
11) International Transfers
We may process and store data in countries other than your own. Where required, we use appropriate safeguards (e.g., Standard Contractual Clauses) and implement technical/organizational measures to protect your data.
12) Security
We employ appropriate technical and organizational measures, including:
- Encryption in transit (TLS) and at rest (where applicable)
- Role-based access controls and audit logs
- Segregated environments and key management
- Routine monitoring, vulnerability management, and incident response
- For organizer KYC/payout data: identity documents and banking/business information collected for payout purposes are transmitted to and primarily held by Paymob under its own security controls; Circle limits its own retention and internal access to this data to what is necessary for support and reconciliation.
No method of transmission or storage is 100% secure. We work continuously to enhance protections.
13) Third-Party Links & Integrations
The App may link to or integrate third-party services (e.g., payments, SSO, maps). Their practices are governed by their own privacy policies. Review those policies before using such services, including Paymob’s Privacy Policy.
14) Automated Decision-Making & AI
We may use automated systems to:
- Recommend circles/events/people,
- Moderate content (e.g., flag spam/abuse),
- Improve discovery and safety, and
- Support fraud/AML screening in connection with payments (in coordination with Paymob).
These systems are regularly evaluated. You can contact us if you have questions about these tools.
15) Paid Circles, Events & Organizer Disclaimer
Circle is a technology platform that helps people discover, join, and pay for circles, events, and communities created by independent organizers. In connection with paid circles/events, please note:
- We are not a party to the event itself. Organizers, not Circle, are solely responsible for the accuracy, quality, safety, legality, and delivery of the circles/events/communities they create, and for honoring any commitments made to attendees.
- We do not verify organizer legitimacy. Circle does not vet, endorse, or guarantee that an organizer, event, or listing is genuine, safe, or as described. Users are responsible for exercising their own judgment before joining or paying for a paid circle/event.
- Payment processing is handled by Paymob. Circle facilitates the transaction through Paymob but does not hold, guarantee, or control the funds beyond what is described in Sections 2–4 above.
- Account and listing enforcement. If we suspect fraud, misrepresentation, or a violation of our Terms, we may suspend, restrict, or permanently close an account or listing at our discretion, with or without prior notice.
- No guaranteed refunds. Suspending or closing an account or listing does not obligate Circle to issue a refund to affected users. Refunds, cancellations, and disputes relating to a specific paid circle/event are between the attendee and the organizer, and/or subject to Paymob’s applicable dispute-resolution process, not guaranteed or administered by Circle.
- This section is a summary for transparency and does not replace, and should be read together with, the fuller terms set out in our Terms of Service.
16) Changes to this Policy
We may update this Policy periodically. If material changes occur, we will notify you via in-app notice, email (if available), and update the “Last Updated” date.
For privacy questions, requests, or complaints:
Email: hello@circlehub.io Support: hello@circlehub.io Mail: Ahmed Abdel-Azim St, Maadi, Cairo, Egypt