Privacy Policy

Effective Date: 01/01/2025

‍

Who We Are

Welcome to Circle Solutions ("we," "our," or "us"). Your privacy matters to us, and we are committed to protecting your personal data. This Privacy Policy explains how we collect, use, and safeguard your information when you use our platform, products, and services (collectively, the "Services").

Scope of This Policy

This Privacy Policy applies to all users of our Services worldwide. If you are located in the European Economic Area (EEA), the United Kingdom, or California, specific rights apply to you under the GDPR or CCPA/CPRA, which are detailed below.

1. Information We Collect

We collect information about you when you provide it to us, when you use our Services, and when other sources provide it to us.

1.1 Information You Provide to Us

• Account Information: We collect information when you register for an account, including your name, email address, phone number, and other contact details.
• Customer & Driver Data: When using our Services, you may provide data about your customers and drivers, including their contact information and locations. This information is essential for planning routes and deliveries.
• Payment Information: When registering for paid Services, we collect billing details, including your billing contact and payment card information, via secure payment processors.

1.2 Information We Collect Automatically

• Service Usage Data: We collect data about how you interact with our Services, such as features used and navigation behavior.
• Device & Connection Information: We collect details about your device, browser, IP address, operating system, and crash logs.
• Cookies & Tracking Technologies: We use cookies, web beacons, and device identifiers to enhance your experience and recognize you across different Services and devices. You can manage cookie settings via your browser.

2. How We Use Your Information

We use the collected data for:

1. Providing the Services – Using customer and driver data to plan routes and facilitate deliveries.
2. Improving the Services – Analyzing usage data to develop new features and enhance functionality.
3. Communication – Sending transactional updates, security alerts, and customer support responses.
4. Marketing & Engagement – Promoting new features and personalized offers (opt-out available).
5. Customer Support – Assisting with troubleshooting, crash analysis, and technical support.
6. Security & Compliance – Monitoring for fraud, verifying accounts, and ensuring regulatory compliance.
7. Legal Obligations – Complying with applicable laws and fulfilling legal obligations.

3. Legal Basis for Data Processing (GDPR Users)

We process personal data under the following legal bases:

• Contractual Necessity – To provide the Services you signed up for.
• Legitimate Interest – To improve our Services and secure our platform.
• Consent – Where required, such as for marketing communications.
• Legal Obligation – Compliance with tax laws, fraud prevention, and similar regulations.

4. Your Privacy Rights

4.1 GDPR Rights (EEA & UK Users)

• Right to access, correct, or delete your data.
• Right to data portability.
• Right to object to automated decision-making.
• Right to withdraw consent.

4.2 CCPA/CPRA Rights (California Users)

• Right to know what personal data we collect.
• Right to delete your personal data.
• Right to opt out of data sales or sharing.
• Right to non-discrimination when exercising privacy rights.

To exercise these rights, contact us at: contact@circlsolutions.com

5. Data Retention & Security

• We retain user data as long as necessary for service provision and legal compliance.
• Security measures are in place to protect against unauthorized access, loss, or misuse.

6. Cross-Border Data Transfers

• Our servers and infrastructure are located in the EU zone.
• If data is transferred outside the EU, it is safeguarded through Standard Contractual Clauses (SCCs) or equivalent measures.

7. Opt-Out Mechanisms & Cookies

• Marketing Communications: Users can opt out via email settings or unsubscribe links.
• Cookies & Analytics: EU users must opt-in for cookies. US users can adjust settings through browser preferences.
• California Users: A "Do Not Sell My Data" option is available under CCPA.

8. Data Breach Notification

• If a data breach occurs, we will notify affected users within 72 hours (GDPR) or as required by law (CCPA).

9. Children's Privacy

• Our Services are not intended for children under 13.
• We comply with COPPA (US) and GDPR age restrictions.

10. Who Has Access to the Collected Data

Only authorized personnel, service providers, and legal entities (where required) have access to personal data:

• Internal Staff – Employees with a legitimate business need.
• Third-Party Providers – Vendors who process payments, host infrastructure, and manage analytics (AWS, Firebase, Stripe, Twilio, Mixpanel).
• Legal Authorities – Government agencies may access personal data when required by law or as part of legal investigations.

11. Updates to This Privacy Policy

We may update this policy periodically. If significant changes occur, we will notify users via email or in-app notifications.

Last Updated: 01/01/2025

12. Contact Us

If you have any questions about this Privacy Policy, please reach out to:

Email: contact@circlsolutions.com

Address: Centris Business Gateway, Level 4/W Triq Is-Salib Tal-Imriehel Central Business District, Zone 3 Birkirkara CBD3020, Malta

Company Details: CIRCL Technologies Ltd VAT ID: MT29375710

Thank you for trusting Circle Solutions. Your privacy is our priority.