Terms of Service

Privacy & Data Protection

GDPR and U.S. Consumer Privacy Compliance

Effective date: April 2, 2026. This section describes how we collect, use, disclose, and protect Personal Data in compliance with the EU General Data Protection Regulation (GDPR) and applicable U.S. consumer privacy laws (including California consumer privacy requirements). This is part of and governed by our Terms of Service. For full details see our Privacy Policy.

Scope

Applies to Personal Data about individuals located in the EEA/UK (GDPR) and to covered consumers under applicable U.S. consumer privacy laws (e.g., California). Terms used but not defined here have the meanings in our Privacy Policy.

Categories of Personal Data Collected

Identifiers (name, email, IP address), account and profile data, transactional and billing information, device and usage data, marketing and preference data, and other data provided or generated when you use our services. We may collect Sensitive Data only with explicit consent and for specified purposes.

Lawful Bases (GDPR)

We process EU/UK Personal Data on the lawful bases of: performance of a contract; compliance with legal obligations; our legitimate interests (e.g., service operation, fraud prevention, analytics, security); and, where required, your consent. Where consent is relied on, you may withdraw it at any time without affecting processing prior to withdrawal.

Consumer Rights (GDPR & U.S. Consumer Privacy Rights)

Subject to verification and applicable exemptions, you may exercise:

• Access / Right to Know: Request confirmation whether we process your Personal Data and request a copy or categories of data.
• Rectification: Request correction of inaccurate or incomplete data.
• Deletion / Right to Erasure: Request deletion of Personal Data where applicable.
• Restriction / Object: Request restriction of processing or object to processing based on our legitimate interests.
• Data Portability: Request a machine-readable copy of Personal Data you provided.
• Opt-Out of Sale (where applicable under state law): Request that we not sell or share your Personal Data for targeted advertising.
• Automated Decision-Making: Request meaningful information about automated processing and opt out where required.

To exercise these rights, contact us via the contact options below. We will verify requests in accordance with applicable law and may require information to confirm identity. We will respond within applicable statutory timeframes.

Requests, Verification, and Authorized Agents

To submit a request, contact privacy@theacircle.co. Authorized agents may submit requests on your behalf if they provide written authorization and we verify both the agent and the consumer.

Data Retention and Deletion

We retain Personal Data only as long as necessary for the purposes described (service provision, legal compliance, dispute resolution, fraud prevention) or as required by law. After the retention period expires we delete, anonymize, or aggregate data.

Disclosures to Third Parties

We may disclose Personal Data to service providers, processors, affiliates, payment processors, analytics vendors, law enforcement, and as required by law. We enter written agreements requiring processors to implement appropriate safeguards.

International Transfers

Personal Data may be transferred outside your jurisdiction. For transfers from the EEA/UK we rely on appropriate safeguards (e.g., adequacy decisions, Standard Contractual Clauses, or other lawful transfer mechanisms). Contact us for details or copies of safeguards.

Security

We implement organizational, technical, and administrative measures designed to protect Personal Data from unauthorized access, disclosure, alteration, and destruction. No method of transmission or storage is 100% secure; if a breach occurs we will notify affected individuals and regulators as required by law.

Children's Data

We do not knowingly collect Personal Data from children under applicable age thresholds (e.g., 16 under GDPR; 13 under COPPA). If we learn we have collected such data we will delete it in accordance with applicable law.

Non-Discrimination

We will not discriminate against consumers for exercising their privacy rights (e.g., by denying service, charging different prices, or degrading service), except where permitted by law.

Changes to This Section

We may update this section to reflect legal or operational changes. We will provide notice as required by law.

Contact & Supervisory Authority

For privacy inquiries, to exercise rights, or to request copies of transfer safeguards, contact: privacy@theacircle.co or 8335 Sunset Blvd., Suite 326, West Hollywood, California 90069, United States. EU/UK data subjects may also lodge a complaint with the relevant supervisory authority.