Privacy and data security concerns are some of the most important issues of our time. We take your privacy seriously. Period.

We do our very best to safeguard the information that you provide. We follow all laws relating to the collection and safeguarding of personal and identifiable user data, as well as the deletion of such data.

We use technical, administrative and physical methods to maintain the integrity and security of our databases, to protect your personal information against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access.

We try to be as transparent as possible, and do our best at communicating intentions, scope of information collection, safe-guarding procedures, and legal obligations.

We will update this privacy policy from time to time to make sure it accurately reflects our data collection and use practices, or as applicable laws require. We will comply with applicable legal requirements regarding providing you with notice and/or consent when we make such changes, depending on the type of change made.

You are advised to consult the "Privacy" link on the Website each time you visit. Your visit to the Website is subject to this privacy policy and our Terms of Use. By accessing and using the Website, you acknowledge that you have read, understood, and agree to be bound by the terms of this privacy policy.

We welcome any questions, concerns, or feedback you may have about our Privacy Policy. You may use our contact form or send us an email: or [email protected]

This privacy policy (or "Policy”) is a legally binding agreement between you ("User”, "you” or "your”) and the operator(s) of CIRCLE.LOVE ("we," "us," or "our").

The headings, colors, and bolding used in this agreement are included for convenience only and will not limit or otherwise affect Policy.

The Policy describes how and why we might collect, store, use, and/or share ("process") your information (“Personal Information”) when you use our services ("Services"), such as when you:

• visit our website at (together with all forwarding domains and subdomains thereunder, the “Website”), or any website of ours that links to this privacy policy.

• Use our browser-based web application (“Web App”) within our Website to view and make new story entries (“Story Entries”) related to Circle Cards.

The privacy policy also describes the choices available to you regarding our use of your Personal Information and how you can access and update it.

This Policy does not apply to the practices of companies that we do not own or control, or to individuals that we do not employ or manage.

The Website may contain links to other resources that are not owned or controlled by us. If you visit any unaffiliated sites linked to the Website (for example, Facebook, X , or other social media websites), you are subject to that site’s own privacy policies, which we do not control or monitor. You should review the privacy policies of all third-party sites before you visit them. We make no representations or warranties as to the privacy practices, functioning or content of any sites linked to our Website.

We automatically collect certain information when you visit, use, or navigate our Website. When you open the Website, our servers automatically record information that your browser sends. This information does not reveal your specific identity (like your name or contact information) but may include information such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, country, location, information about how and when you use our Services, and other technical information.

This information is primarily needed to maintain the security and operation (identify potential cases of abuse) of our Services, and for our internal analytics and reporting purposes. This information is not aggregated in such a way that would identify any User of the Website.

We also capture every Circle Card code lookup (including frequency) in our Web App, along with the date, time, and IP address of the device performing the lookup on our Website. We use this information to measure the effectiveness of our programs and create global Website (and Web App) security rules to prevent abuse. This information is not aggregated with any other personally identifiable user data. If you do not want us to collect information about your geographic location, you must disable the technology that transmits this information.

Like many businesses, our Website may use third-party analytics tools that use cookies (more on that below), web beacons, or other similar information-gathering technologies to collect standard internet activity and usage information, including the page you were visiting before you came to the Website, pages of the Website that you visit, the time spent on those pages, information you search for on the Website, access times and dates, and other statistics.

We use Matomo as our third-party web analytics tool, which is focused on customer privacy. https://matomo.org/

Our Website uses “cookies” as a tool to help improve the functionality of the Website, provide a seamless experience for users, help us analyze web traffic, and make improvements to our products and services.

A cookie is a text file that is placed on your hard disk by a web server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you and can only be read by a web server in the domain that issued the cookie to you.

We use the following Cookies on our Website:

• _pk_id# is in the category of Statistics cookies and is provided by Matomo to collect statistics on the user's visits to the website, such as the number of visits, average time spent on the website and what pages have been read.

• _pk_ses# is in the category of Statistics cookies and is provided by Matomo to track page requests from the visitor during the session.

• CookieConsent is in the category of Necessary cookies and is provided by Cookiebot and is used to store the user's cookie consent state for the current domain, only for those geographic regions in which it is activated.

Please note that you have the ability to accept or decline cookies. Most web browsers automatically accept cookies by default, but you can modify your browser settings to decline cookies if you prefer.

You may at any time delete or prevent the use of cookies by using the relevant option of your web browser or by deleting the cookies on your hard drive or mobile device. Using the settings of your web browser, you can choose to have your device warn you each time a cookie is being sent, or you can choose to turn off all cookies.

For detailed information on how to manage cookies, visit: https://cookiepedia.co.uk/how-to-manage-cookies

If you choose to turn off cookies, you may not have access to many features that make your browsing of the Website simpler, and some of our services may not function properly including our web application to make new entries for Circle Cards.

If you continue to use our Website without changing your settings, you consent to our use of cookies.

Sensitive Information. We do not process sensitive information. See the European Commission definition of sensitive information, HERE.

The Personal Information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use.

You can access and use the Website without telling us who you are or revealing any information by which someone could identify you as a specific, identifiable individual. If, however, you wish to use some of the features offered on the Website, such as making a new Story Entry for a Circle Card within our Web App, the e-mail sign-up form, contact form, or make a purchase, you will be asked to provide certain Personal Information.

The Personal Information we collect may include the following: your name, phone number(s), email address(es), mailing address(es), username(s), password(s), contact preference(s), contact or authorization data, billing address(es), and debit/credit card numbers.

All Personal Information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such Personal Information.

If you choose to make a new Story Entry for any Circle Card that you have interacted with, you will be required to provide information about when (the date) you interacted with the card, and the city of interaction. You may voluntarily include details about the specific place or event in which you interacted with a card, how you received the card, including personal details about the interaction.

You will also be required to provide your name and email address during the new Story Entry creation process. Your email address is never made public. An email address is required so that we may notify you each time a new Story Entry is made relating to your Circle Card. This notification system is a core feature of our Service. You may unsubscribe from emails at any time.

During the process to make a new Story Entry, you may choose to be anonymous within the publicly available entry. That means your name will not show in the public entry that is visible to Website visitors. If you choose to provide your first and last name, we will ONLY display your first name and first letter of your last name. We do not display your full last name.

We passively collect the date and time that the new Story Entry is created (separate from the user- selected date of the interaction). The IP address of the device that is used to make the new entry is collected and aggregated along with the new Story Entry data. This provides us with information about where the Circle Cards have traveled, in addition to the User-selected location. Collecting the IP address is also important to help us flag abuse within the Web App.

We use a Google Maps/Places API to provide auto-complete (autofill) suggestions for the “City of Interaction” and “Specific Place” fields within the “add a new entry” portion of our Web App. Personally Identifiable information is not transmitted to Google. As part of Google’s API requirements for us, we must provide you with a link to their privacy policy. Click here to view: https://policies.google.com/privacy

Once you publish a new Story Entry within our Web App, you grant us a non-exclusive, worldwide, transferable and sublicensable right to use, copy, modify, distribute, publish, and process your publicly available Story Entry and any other related non-personally identifiable information, without any further consent, notice and/or compensation to you. You also grant other users of the Website a non-exclusive, worldwide, non-transferable and non-sublicensable right to share your Story Entry on other social media websites for their personal, non-commercial use only.

If you choose to make a purchase or make a voluntary donation (send a gift), we may collect billing, mailing, and contact information, including name, address, and phone number. We may also collect financial information collected by third-party payment processors on our behalf.

We use a credible third-party email verification service called Zerobounce to perform real-time verification of all email address submitted through our Website within the Web App, contact form, and email newsletter sign-up form. In addition to real-time verification, we do periodic bulk email list verification through the service. Zerobounce takes privacy seriously.

You may view their data security and privacy practices here: https://www.zerobounce.net/docs/frequently-asked-questions/data-security-and-privacy/how-does-zerobounce-ensure-the-privacy/

This Website is not targeted toward children under the age of 13. We do not knowingly collect any Personal Information from children under the age of 13 without parental consent. If you are under the age of 13, please do not submit any Personal Information through the Website.

If you have reason to believe that a child under the age of 13 has provided Personal Information to us through the Website, without verifiable parental consent, please contact us to request that we delete that child’s Personal Information. Consistent with the Children’s Online Privacy Protection Act https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-312, we will promptly use commercially reasonable efforts to delete such information from our databases.

We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce this Policy by instructing their children never to provide Personal Information through the Website and Services without their permission.

We process your Personal Information for a variety of reasons, depending on how you interact with our Services, including:

• To facilitate account creation and authentication and otherwise manage user accounts. We may process your Personal Information so you can create and login to your account, as well as keep your account in working order.

• To deliver and facilitate delivery of services to the user. We may process your Personal Information to provide you with the requested service.

• To respond to user inquiries/offer support to users. We may process your Personal Information to respond to your inquiries and solve any potential issues you might have with the requested service.

• To send administrative information to you. We may process your Personal Information to send you details about our products and services, changes to our terms and policies, and other similar information.

• To fulfill and manage your orders. We may process your Personal Information to fulfill and manage your orders, payments, returns, and exchanges made through the Services.

• To send you marketing and promotional communications. We may process the Personal Information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time.

• To protect our Services. We may process your Personal Information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.

• To save or protect an individual's vital interest. We may process your Personal Information when necessary to save or protect an individual’s vital interest, such as to prevent harm.

In Short: We only process your Personal Information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services, to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your Personal Information. As such, we may rely on the following legal bases to process your Personal Information:

Consent. We may process your Personal Information if you have given us permission (i.e., consent) to use your Personal Information for a specific purpose. You can withdraw your consent at any time.

Performance of a Contract. We may process your Personal Information when we believe it is necessary to fulfill our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.

Legitimate Interests. We may process your Personal Information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your Personal Information for some of the purposes described in order to:

• Send users information about special offers and discounts on our products and services.

• Diagnose problems and/or prevent fraudulent activities.

Legal Obligations. We may process your Personal Information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.

Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

We may process your Personal Information if you have given us specific permission (i.e., express consent) to use your Personal Information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable law to process your Personal Information without your consent, including, for example:

• If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way.

• For investigations and fraud detection and prevention.

• For business transactions provided certain conditions are met.

• If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim.

• For identifying injured, ill, or deceased persons and communicating with next of kin.

• If we have reasonable grounds to believe an individual has been, is, or may be a victim of financial abuse.

• If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or contravention of the laws of Canada or a province.

• If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records.

• If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced.

• If the collection is solely for journalistic, artistic, or for literary purposes.

• If the information is publicly available and is specified by the regulations.

In Short: We keep your Personal Information for as long as necessary to fulfill the purposes outlined in this privacy policy unless otherwise required by law.

We will only keep your Personal Information for as long as it is necessary for the purposes set out in this privacy policy, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).

A core function of our Service is to send you notifications when new Story Entries are made by other Users relating to Circle Cards that you have previously interacted/engaged with or own through purchase. We keep User’s names and email addresses to be able to provide notifications.

Each Circle Card may be passed on from person to person indefinitely, and new Story Entries related to each Circle Cards may be made for as long as a card continues to circulate.

When we have no ongoing legitimate business need to process your Personal Information, we will either delete or anonymize such information, or, if this is not possible (for example, because your Personal Information has been stored in backup archives), then we will securely store your Personal Information and isolate it from any further processing until deletion is possible.

Once the retention period expires, Personal Information shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification, and the right to data portability cannot be enforced after the expiration of the retention period.

We may use any aggregated data derived from or incorporating your Personal Information after you update or delete it, but not in a manner that would identify you personally.

Any requests to exercise your rights can be directed to us through the contact details provided in this document. Please note that we may ask you to verify your identity before responding to such requests. Your request must provide sufficient information that allows us to verify that you are the person you are claiming to be or that you are the authorized representative of such person.

You must include sufficient details to allow us to properly understand the request and respond to it. We cannot respond to your request or provide you with Personal Information unless we first verify your identity or authority to make such a request and confirm that the Personal Information relates to you.

In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your Personal Information, (ii) to request rectification or erasure; (iii) to restrict the processing of your Personal Information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. In certain circumstances, you may also have the right to object to the processing of your Personal Information. You can make such a request by contacting us by using the contact details provided in the privacy policy.

We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the EEA or UK and you believe we are unlawfully processing your Personal Information, you also have the right to complain to your Member State data protection authority or UK data protection authority.

If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Withdrawing your consent: If we are relying on your consent to process your Personal Information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us using the contact details provided in this privacy policy.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your Personal Information conducted in reliance on lawful processing grounds other than consent.

Opting out of marketing and promotional communications: We offer email newsletters to which you may voluntarily subscribe at any time. We are committed to keeping your e-mail address confidential and will not disclose your email address to any third parties except for the purposes of using a secure third-party provider to validate/verify your email address and utilizing a secure third-party provider to send such emails. We will maintain the information sent via e-mail in accordance with applicable laws and regulations.

In compliance with the CAN-SPAM Act, all e-mails sent from us will clearly state who the e-mail is from and provide clear information on how to contact the sender. You may choose to stop receiving our newsletter by following the unsubscribe instructions included in these emails or by contacting us.

However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

Account Information: If you would at any time like to review or change the information in your account or terminate your account, you may contact us using the contact at or email us at [email protected]

Upon your request to terminate your account, we will deactivate or delete your account and Personal Information from our active databases. However, we may retain some Personal Information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

Most web browsers incorporate a Do Not Track feature that signals to websites you visit that you do not want to have your online activity tracked. Tracking is not the same as using or collecting Personal Information in connection with a website. For these purposes, tracking refers to collecting personally identifiable information from consumers who use or visit a website. How browsers communicate the Do Not Track signal is not yet uniform. As a result, the Website is not yet set up to interpret or respond to Do Not Track signals communicated by your browser. Even so, as described in more detail throughout this Policy, we limit our use and collection of your Personal Information.

Our Website and Services may include social media features, such as the Facebook and X (formerly Twitter) buttons, “Share This” buttons, etc (collectively, “Social Media Features”). These Social Media Features may collect your IP address, what page you are visiting on our Website, and may set a cookie to enable Social Media Features to function properly. Social Media Features are hosted either by their respective providers or directly on our Website. Your interactions with these Social Media Features are governed by the privacy policy of their respective providers.

We secure Personal Information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use, or disclosure. We maintain reasonable administrative, technical, and physical safeguards in an effort to protect against unauthorized access, use, modification, and disclosure of Personal Information in our control and custody. However, no data transmission over the Internet or wireless network can be guaranteed.

Therefore, while we strive to protect your Personal Information, you acknowledge that (i) there are security and privacy limitations of the Internet which are beyond our control; (ii) the security, integrity, and privacy of any and all information and data exchanged between you and the Website and Services cannot be guaranteed; and (iii) any such information and data may be viewed or tampered with in transit by a third party, despite best efforts.

In the event we become aware that the security of the Website has been compromised or Users’ Personal Information has been disclosed to unrelated third parties as a result of external activity, including, but not limited to, security attacks or fraud, we reserve the right to take reasonably appropriate measures, including, but not limited to, investigation and reporting, as well as notification to and cooperation with law enforcement authorities.

In the event of a data breach, we will make reasonable efforts to notify affected individuals if we believe that there is a reasonable risk of harm to the User as a result of the breach or if notice is otherwise required by law. When we do, we will send you an email.

We reserve the right to modify this Policy or its terms related to the Website at any time at our discretion. When we do, we will revise the updated date at the bottom of this page. We may also provide notice to you in other ways at our discretion, such as through the contact information you have provided.

An updated version of this Policy will be effective immediately upon the posting of the revised Policy unless otherwise specified. Your continued use of the Website and Services after the effective date of the revised Policy (or such other act specified at that time) will constitute your consent to those changes. However, we will not, without your consent, use your Personal Information in a manner materially different from what was stated at the time your Personal Information was collected.

You acknowledge that you have read this Policy and agree to all its terms and conditions. By accessing and using the Website and submitting your Personal Information you agree to be bound by this Policy.

You agree that this Policy and your use of this Website shall be governed in all respects by the laws of the State of Colorado. Any dispute relating to this privacy policy and your use of this Website shall be resolved solely in the state or federal courts located in Colorado. You consent and submit to the personal jurisdiction of such courts for the purposes of any such dispute, controversy or claim. If any provision of this privacy policy is held to be unenforceable, such provision will be reformed only to the extent necessary to make it enforceable.

If you have any questions, concerns, or complaints regarding this Policy, the Personal Information we hold about you, or if you wish to exercise your rights, we encourage you to contact us using the details below:

or email to: [email protected]

We will attempt to resolve complaints and disputes and make every reasonable effort to honor your wish to exercise your rights as quickly as possible and in any event, within the timescales provided by applicable data protection laws.

This document was last updated on February 1, 2024