Privacy Policy

Effective Date: January 15, 2025
Last Updated: November 13, 2025

Introduction

Welcome to Circles ("the App," "we," "us," or "our"). This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you use our mobile application.

Developer: Elliott Opie, an individual developer based in the United Kingdom
Contact: support@circlesapp.co.uk
ICO Registration Number: ZC038337

  • We are committed to protecting your privacy and complying with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and other applicable data protection laws

  • By using the App, you consent to the data practices described in this policy

1. Information We Collect

1.1 Information You Provide Directly

Account Information:

  • Email address (for account creation and communication)

  • Username (chosen by you)

  • Full name

  • Profile picture (optional)

  • Bio/description (optional)

  • Date of birth (to verify you are 17 years or older)

Content You Create:

  • Photos and images you upload to posts

  • Circle images (photos for circles you create)

  • Captions and text you add to posts

  • Comments on posts

  • Likes and reactions

  • Circles you create or join

  • Friend connections

Privacy and Safety:

  • Your friends list

  • Users you have blocked

  • Users who have blocked you

  • Reports you submit about content or users

Communications:

  • Support requests and correspondence with us

  • Feedback and survey responses

1.2 Information Collected Automatically

Device Information:

  • Device type and model

  • Operating system and version

  • Unique device identifiers

  • Mobile network information

Usage Information:

  • Features you use and actions you take

  • Time and frequency of your activities

  • Posts you view or interact with

  • Search queries

Technical Information:

  • IP address

  • Browser type

  • App version

  • Crash reports and performance data

  • Time zone and language settings

1.3 Information from Third Parties

Apple Sign-In:
If you create an account using Apple Sign-In, we receive:

  • Your name (or anonymous identifier if you choose to hide it)

  • Email address (or Apple's private relay email)

No Other Third-Party Integration:

  • We do not currently integrate with other social media platforms or third-party services for account creation

1.4 Information We Do NOT Collect

We do not intentionally collect:

  • Precise geolocation data (we do not track your location)

  • Payment information (the App is currently free)

  • Biometric data

  • Health information

  • Government-issued identification numbers

2. How We Use Your Information

2.1 To Provide and Improve the App

  • Create and manage your account

  • Enable you to post content and interact with other users

  • Facilitate communication within circles

  • Display your content to users you choose to share with

  • Personalize your experience

  • Develop new features and improve existing ones

  • Analyze usage patterns and trends

2.2 To Communicate with You

  • Send you important updates about the App

  • Respond to your requests and support inquiries

  • Send you notifications about activity on your account (if you enable notifications)

  • Inform you of changes to our Terms or Privacy Policy

2.3 For Safety and Security

  • Detect, prevent, and address fraud and abuse

  • Enforce our Terms of Service

  • Protect against spam and malicious activity

  • Investigate and respond to violations of our policies

  • Comply with legal obligations

2.4 For Analytics

  • Understand how users interact with the App

  • Monitor and analyze trends and usage

  • Measure the effectiveness of features

  • Troubleshoot technical issues

We do NOT:

  • Sell your personal information to third parties

  • Use your information for advertising purposes

  • Share your information with data brokers

3. How We Share Your Information

3.1 With Other Users

Public Information:

  • Your username and profile picture are visible to other users

  • Your bio/description is visible to users who view your profile

Content You Share:

  • Posts are visible only to members of the circles where you post them

  • Comments and likes are visible to members of the relevant circle

  • Your friends list may be visible to your friends

3.2 With Service Providers

We may share your information with trusted third-party service providers who assist us in operating the App, including:

Firebase (Google LLC):

  • Authentication services

  • Database hosting (Firestore)

  • Cloud storage for images

  • Crash reporting and analytics

Data Processing Location:

  • Firebase services may process data in the United States and other countries where Google operates data centers

Safeguards:

  • We use service providers that comply with applicable data protection laws and have appropriate security measures in place

3.3 For Legal Reasons

We may disclose your information if required to do so by law or if we believe such action is necessary to:

  • Comply with legal obligations or government requests

  • Enforce our Terms of Service

  • Protect our rights, property, or safety

  • Protect the rights, property, or safety of our users or the public

  • Prevent or investigate possible wrongdoing

3.4 Business Transfers

  • If we are involved in a merger, acquisition, or sale of assets, your information may be transferred

  • We will notify you of any such change and any choices you may have

3.5 With Your Consent

  • We may share your information with third parties when you give us explicit consent to do so

4. Data Retention

4.1 Active Accounts

  • We retain your information for as long as your account is active and as necessary to provide you with the App's services

4.2 Account Deletion

When you delete your account:

  • Your profile information is deleted within 30 days

  • Your posts and content are removed from the App within 30 days

  • Some information may be retained in backup systems for up to 90 days

  • We may retain certain information if required by law or to resolve disputes

4.3 Legal Retention

We may retain information for longer periods if required to:

  • Comply with legal obligations

  • Resolve disputes

  • Enforce our agreements

  • Prevent fraud and abuse

4.4 Anonymized Data

  • We may retain anonymized or aggregated data indefinitely for analytics and research purposes

  • This data cannot be used to identify you personally

5. Your Rights and Choices

5.1 UK GDPR Rights

If you are in the UK or EU, you have the following rights:

Right of Access:

  • You can request a copy of the personal information we hold about you

Right to Rectification:

  • You can request that we correct inaccurate information

Right to Erasure ("Right to be Forgotten"):

  • You can request that we delete your personal information in certain circumstances

Right to Restrict Processing:

  • You can request that we limit how we use your information

Right to Data Portability:

  • You can request a copy of your information in a structured, commonly used format

Right to Object:

  • You can object to our processing of your information in certain circumstances

Right to Withdraw Consent:

  • You can withdraw consent for processing at any time (where we rely on consent)

Right to Lodge a Complaint:

  • You can complain to the Information Commissioner's Office (ICO) if you believe we have mishandled your data

5.2 How to Exercise Your Rights

  • To exercise any of these rights, please contact us at support@circlesapp.co.uk

  • We will respond to your request within one month (or sooner if required by law)

  • We may ask for additional information to verify your identity

5.3 Account Settings

You can:

  • Update your profile information in the App settings

  • Control who can see your content through circle privacy settings

  • Delete your account at any time through the App settings

  • Manage notification preferences

5.4 Marketing Communications

  • We do not currently send marketing emails

  • If we do in the future, you can opt out at any time

6. Security

6.1 Our Security Measures

We implement appropriate technical and organizational measures to protect your information, including:

  • Encryption of data in transit (HTTPS/TLS)

  • Encryption of data at rest in Firebase

  • Secure authentication (Firebase Authentication)

  • Regular security assessments

  • Access controls and user authentication

  • Secure password storage (hashed and salted)

6.2 Your Responsibilities

You are responsible for:

  • Keeping your password secure and confidential

  • Using a strong, unique password

  • Notifying us immediately if you suspect unauthorized access

  • Logging out of shared devices

6.3 No Guarantee

  • While we strive to protect your information, no method of transmission or storage is 100% secure

  • We cannot guarantee absolute security

6.4 Data Breaches

  • In the event of a data breach that affects your personal information, we will notify you and the ICO as required by law

7. Children's Privacy

7.1 Age Requirement

  • The App is not intended for children under 16 years of age

  • We do not knowingly collect personal information from anyone under 16

7.2 Parental Notice

  • If you are a parent or guardian and believe your child under 16 has provided us with personal information, please contact us at support@circlesapp.co.uk

  • We will delete such information from our systems

8. International Data Transfers

8.1 Global Availability

  • Circles is available to users worldwide

  • While we are based in the United Kingdom, users from any country can access and use the App

  • Your information may be transferred to and processed in countries outside the UK/EU, including the United States, where Google operates Firebase services

8.2 Safeguards

Google has implemented appropriate safeguards, including:

  • Standard Contractual Clauses approved by the European Commission

  • Compliance with the EU-US Data Privacy Framework (where applicable)

  • Adequate technical and organizational security measures

8.3 Your Consent

  • By using the App, you consent to the transfer of your information to countries outside the UK/EU as described in this policy

9. Cookies and Tracking

9.1 Cookies

  • The App does not use traditional browser cookies

  • However, Firebase and our service providers may use similar technologies (such as local storage) for:

    • Authentication and session management

    • Analytics and performance monitoring

    • Remembering your preferences

9.2 Analytics

We use Firebase Analytics to understand how users interact with the App. This includes:

  • Screen views and navigation patterns

  • Feature usage statistics

  • Device and OS information

  • Crash reports

You can limit analytics tracking by:

  • Disabling analytics in your device settings

9.3 Do Not Track

  • The App does not respond to Do Not Track signals as there is no industry standard for how to respond to such signals

10. Third-Party Services

10.1 Firebase/Google

11. Changes to This Privacy Policy

11.1 Updates

  • We may update this Privacy Policy from time to time to reflect changes in our practices or for legal, regulatory, or operational reasons

11.2 Notification

We will notify you of material changes by:

  • Posting the updated policy in the App

  • Sending you an email notification

  • Displaying a prominent notice in the App

11.3 Your Continued Use

  • Your continued use of the App after changes constitutes your acceptance of the updated Privacy Policy

11.4 Review

  • We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information

12. Data Controller

For the purposes of UK GDPR, the data controller is:

Elliott Opie
Individual Developer
Circles App
United Kingdom
Email: support@circlesapp.co.uk
ICO Registration Number: ZC038337

13. Supervisory Authority

If you have concerns about how we handle your personal information, you have the right to lodge a complaint with the UK supervisory authority:

Information Commissioner's Office (ICO)
Website: https://ico.org.uk
Phone: 0303 123 1113
Address: Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

Our ICO Registration Number: ZC038337

14. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

Email: support@circlesapp.co.uk
Developer: Elliott Opie
App: Circles
Location: United Kingdom
ICO Registration: ZC038337
Response Time: We aim to respond within 48 hours

15. Specific Provisions for UK/EU Users

15.1 Legal Basis for Processing

We process your personal information on the following legal bases:

Performance of Contract:

  • To provide you with the App's services

  • To create and manage your account

Legitimate Interests:

  • To improve and develop the App

  • To ensure security and prevent fraud

  • To analyze usage and performance

Consent:

  • For optional features you choose to use

  • For communications you opt into

Legal Obligation:

  • To comply with applicable laws and regulations

15.2 Automated Decision-Making

  • We do not use automated decision-making or profiling that produces legal or similarly significant effects

16. California Privacy Rights (If Applicable)

  • If you are a California resident, you may have additional rights under the California Consumer Privacy Act (CCPA)

  • Please contact us for more information

Version: 1.1
Effective Date: January 15, 2025
Last Updated: November 13, 2025

BY USING THE APP, YOU ACKNOWLEDGE THAT YOU HAVE READ AND UNDERSTOOD THIS PRIVACY POLICY.