Privacy Policy

Sircles Media, Inc. values the trust its customers place in it. Sircles is a map based, geo-social recommendation app designed to connect friends and family through positivity and sharing. This Privacy and Security Policy is provided for the benefit of customers of Sircles Media, Inc. ("Sircles Media") as well as other consumers and parties who seek information from or about Sircles Media and/or its website(s), particularly Sircles.com ("Website" or "Sircles.com"), and/or applications ("Apps") (collectively, "Sircles Services"). As always, if you have any questions or concerns about our handling of your personal information, you may contact our privacy officer at privacy@Sircles.com.

OPENING STATEMENTS Definitions. Across its various services, Sircles Media strives to use the same definitions for particular terms. By doing so, Sircles Media seeks to make its policies and governing documents consistent and user-friendly. For this reason, Sircles Media provides the definitions for these terms in one location and directs you to our Terms of Use for such definitions.

Our Commitment to Privacy At Sircles Media, we respect the privacy and the confidentiality of our customers' information, particularly our customers' PII (also commonly referred to as personally identifiable information) ("PII"). We are committed to keeping confidential the PII you share with us.

This Privacy and Security Policy explains how Sircles Media collects, uses, discloses and protects the information we obtain. Applicability of Privacy and Security Policy Our Privacy and Security Policy applies to all individuals and entities from whom or for the benefit of whom we receive PII, whether it be collected through our corporate owned websites; Apps; traditional mailing and/or faxing channels; telephone or electronic communications; from some other medium; and/or from our clients.

Website and Apps Not Directed to Minors The Website and Apps are not directed toward children or minors under the age of 13. U.S.-EU Framework, Privacy Shield, and GDPR.

Sircles Media values the trust its European Union ("EU") customers place in it and maintains an ongoing commitment to EU privacy laws and policies. In fact, Sircles Media maintains an ongoing commitment to treat all personal data received, from the European Union or elsewhere, under the Principles of the Privacy Shield and the EU General Data Protection Regulation ("GDPR"). Sircles Media, Inc. complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. Sircles Media, Inc. has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, please visit https://www.privacyshield.gov/. A list of Privacy Shield compliant entities can be found at https://www.privacyshield.gov/list. Additionally, Sircles Media has proceeded one step further in its efforts to meet the heightened requirements of EU data protection. Sircles Media makes every effort to comply fully with the applicable principles of the European Union General Data Protection Regulation ("GDPR"). It also subjects itself to the investigatory and enforcement powers of the Federal Trade Commission, Department of Commerce, Department of Transportation, and/or any other applicable enforcement and/or investigatory authority.

PERSONAL INFORMATION COLLECTED AND HOW IT IS USED Scope of PII Personally Identifiable Information or PII is any information that would, by itself, identify you or tend to identify you as a particular individual or entity. This PII may include, but not be limited to, your name, your address, credit card number, bank account information, and/or personal identification number (such as a social security number or driver's license number). PII does not include any public information that is readily attainable through federal, state or local public record distribution channels. PII does not include any information that, by itself, could not identify you as a particular individual or entity. PII also does not include raw data that becomes aggregated for statistical purposes and cannot, thereafter, be identified with you as a unique individual or entity. Sircles Media considers your Internet Protocol ("IP") address to be PII and will treat it as such. Information Collected Sircles Media collects information that is considered PII and other information that, by itself, would not be considered personally identifiable information ("Non-PII").

When you create an account and register for any of our Sircles Services (whether through a Website, App, or other portal), we collect information submitted by you including, but not limited to, your full name, company name (if applicable), gender, email address, zip code, phone number, and IP address. We use this information to identify our customers and send notifications related to the use of our Sircles Services. We reserve the right to request additional information from you.

For our paying customers, Sircles Media shall also collect information relating to one or more of your financial accounts for purposes of processing payments to provide you with Sircles Services. This information may likely contain both PII and Non-PII depending on the nature of the account holder information. Collecting and Using Personally Identifiable Information Sircles Media will explain how it intends to use PII either before it collects the information (such as in this Privacy and Security Policy) or contemporaneously with the solicitation of such information.

Exceptions may exist where the intended use is obvious to a reasonable person. Generally, Sircles Media collects personal identifiable information when an individual registers with or uses any of the Sircles Services. This information typically includes, at a minimum, a full name, company name (if applicable), email address, phone number, mobile phone number, and any additional information provided by the account holder that could identify that account holder. We will use the PII collected only for the purposes explained to you. Further, we limit the collection of PII to only that information which is necessary for the purposes explained to you. Generally, we use the PII collected and/or received about you in connection with our Apps, Website, Sircles Services, and their various features.

We also use information collected and/or received about you in connection with other users and advertisers that purchase ads through the Apps or on the Website. For example, we may use the information we receive about you (a) as part of our efforts to keep Sircles Media safe and secure; (b) to provide Sircles Services; (c) to make suggestions to you and other users on Sircles Media; and (d) provide support. Granting us this permission not only allows us to provide Sircles Media as it exists today, but it also allows us to provide you with innovative features and services we develop in the future that use the PII we receive about you in new ways. As an additional example, we currently do not use data collected to target specific ads we think you would like but rather use your data such as GPS location to stream ads from advertisers that are determined to be near you. The foregoing being said, we reserve the right to use your data for targeting of ads at a later time. Further, for purposes of clarification, we also stream ads from advertisers that may not be near you.

We may use your PII to communicate with you for the foregoing and other reasons by email, text message, phone call, or other electronic, written or oral communication method, unless you expressly indicate to Sircles Media not to use a particular method of communication. While you are allowing us to use the PII we receive about you, you always own all of your information. Your trust is important to us, which is why we don't share PII we receive about you with others unless we have received your express permission for the information to be used for such purpose.

Aggregate Information. Additionally, we may use aggregated information derived from PII to improve the Sircles Services and any related matters thereto.

Third Parties. Unless we are required to do so by law, we shall not obtain your consent before collecting PII about you from parties other than Sircles Media. Rather, Sircles Media shall presume that you have previously provided such consent to any such third party from whom Sircles Media obtains such information. This only applies to information provided by third parties to Sircles Media. Sircles Media does not provide third parties with access to your account information and only shares your personal information with third parties where we have your consent to do so.

Restricted Use. In the normal course of its business operations, Sircles Media restricts the use of your PII to Sircles Media's personnel and its Strategic Partners. However, by using Sircles Services, you may necessarily disclose PII to others when they access your information, profiles, and other Content.

Sale of Information. We shall not sell your PII in the normal course of business operations. This paragraph shall not by itself restrict the transfer of your PII to a third party for purposes discussed in the subsection on Business Transfer below. We may also use the PII you provide in registering with and using Sircles Media to inform you by electronic mail, phone, text or other communication method of additional products and services about which you might be interested, which may include our periodic e-newsletters and other promotional communications from Sircles Media. If another user uploads their contact list, we may combine information from that user's contact list with other information we have collected about you. We may collect information about you from other users and our affiliates. App developers, publishers, advertisers and other third parties may share information with us as well. We may use this information, among other ways, to help measure the performance or target ads to you.

Disclosing Personal Information. We do not share PII we obtain from your use of our Sircles Services with others except as described in this Privacy Policy and the Terms of Use. Sircles Media may use PII in the normal course of providing the Sircles Services; to operate or improve the Apps, Website and/or Sircles Services; to outsource certain services to Strategic Partners; to complete a transaction that has been requested; to develop aggregate information; and/or as otherwise disclosed to you. Sircles Media may provide PII to other persons where (a) we have your consent; (b) the disclosure is necessary to complete a transaction requested; (c) we have obtained information from a third party (presuming that you have previously provided such consent to any such third party from whom Sircles Media obtains such information); (d) we are required or permitted to do so by law; (e) the Apps, Website and/or Sircles Services are used in a manner that violates the Terms of Use or uses for purposes other than those for which they were specifically intended; and/or (f) the terms of this Privacy and Security Policy and/or the Terms of Use otherwise permit and/or provide for such disclosure. In particular, by the very nature of the Sircles Services, information submitted by our customers will be shared with other customers as applicable to the customers' particular use of Sircles Services. In some cases, Sircles Media Customers may be able to download your videos and other public information, and store them on, their computers and servers. Other Sircles Media Customers may also be able to use shared links by which they provide related parties who might not also be Sircles Media Customers access to your content.

Strategic Partners. Sircles Media may employ, engage or retain certain trusted third parties ("Strategic Partners") to perform functions and/or provide services on its behalf, such as web hosting, integrated services, or advertising. Sircles Media will share PII with these Strategic Partners only to the extent necessary to perform the functions and/or provide the services for which they have been employed, engaged or retained. Sircles Media shall also secure contractual obligations from our Strategic Partners to maintain the privacy and security of the PII shared with them at the same level of privacy protection as outlined in the Privacy Shield Principles. Upon notice of unauthorized processing by a Strategic Partner, Sircles Media will take reasonable and appropriate steps to stop and remediate unauthorized processing. Some of the Strategic Partners that may receive access to your PII to provide the Sircles Services have been listed below.

Business Transfers. Sircles Media reserves the right to sell, transfer or otherwise share some or all of its assets, including PII, in connection with a sale of assets; a merger, acquisition, or reorganization; or, filing for bankruptcy. You will have the opportunity to opt out of any such transfer if the planned processing of your information by the purchaser differs materially from that set forth in this Privacy and Security Policy.

Legal Compliance. Sircles Media may be required to disclose any information about you and/or Content created by you in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We may also disclose any information about you and/or Content created by you as we, in our sole discretion, believe necessary or appropriate to: (1) comply with an order from a court of competent jurisdiction, regulatory agency, and/or other governmental authority; (2) respond to claims, court orders, or other legal process (including subpoenas); (3) to enforce the terms of this and other Sircles Media agreements as well as to protect the property and rights of Sircles Media, its Strategic Partners or other third parties; (4) to protect, in Sircles Media's sole discretion, the public or any person from harm; (5) to investigate, prevent, stop, or take other action regarding any action perceived to be fraudulent, illegal, unethical, or legally actionable in Sircles Media's sole discretion; and/or, generally, (6) to comply with the law. Notice. Unless restricted from doing so, Sircles Media will attempt to notify you before it releases any of your PII or Content pursuant to (1) and (2) in paragraph 2.4 (h) only. In such cases, Sircles Media will also provide you with general information on how you may seek to block such a release of information and/or direct you to resources that can provide such general information. The provision of such general information to you is not and should not be construed as providing you with legal advice. Additionally, Sircles Media is under no other obligation to assist you in challenging or opposing a release of your information Onward Transfer Liability. Sircles Media may be liable for onward transfers of personal data to third parties in violation of this policy and the Privacy Shield.

Non-Personally Identifiable Information. In addition to collecting PII as previously described, Sircles Media also collects other non-PII. Non-PII collected by Sircles Media may be utilized without restriction Although non-PII can be used in a number of ways, you can be assured that the use of the non-PII cannot identify you as a particular individual. Because non-PII cannot be used to identify you, Sircles Media may in its discretion provide non-PII to other persons or entities.

Information Obtained From Use of Sircles Media's Services Usage information. This is information about your activity and is collected through our various services. For example, we may collect information about how you interact with our services, such as what types of recommendations you prefer, what types of places or entertainment you share, how much time you spend browsing the discover feed or other user's activity feeds, or which search queries you submit. As well as how you communicate with other Sirclers, such as their names, the time and date of your communications, the number of messages you exchanged with your friends, which friends you exchanged messages with the most, and your interactions with messages (such as when you open or send a message).

Content Information. We collect content you create on our services, such as photos you upload, and information about the content you create or provide, such as if the recipient has viewed the content and the metadata that is provided with the content.

Device Information. We collect information from and about the devices you use Sircles on. For example, we collect information about your hardware and software, such as the hardware model, operating system information, device memory, advertising identifiers, unique application identifiers, apps installed, unique device identifiers, browser type, language, battery level, and time zone. We also may collect information from device sensors, such as accelerometers, gyroscopes, compasses, microphones, and whether you have headphones connected and information about your wireless and mobile network connections, such as mobile phone number, service provider, IP address, and signal strength.

Device Phonebook. Because Sircles is all about connecting friends and family through sharing and positivity, we may-with your permission-collect information from your device's phonebook in order to better match you with people you may know.

SIRCLES MESSAGES AND CONSENT

Consent to add group members. Sircles makes it easy for you to add group members to your groups so that you can exchange messages with each other. YOU REPRESENT AND WARRANT TO US THAT EACH PERSON YOU ADD TO A GROUP HAS CONSENTED TO BE ADDED TO THE GROUP AND TO RECEIVE TEXT MESSAGES FROM YOU AND ANYONE ELSE IN THE GROUP.

Consent to receive periodic messages from Sircles. As part of the Service, Sircles sometimes causes administrative messages to be sent to members of the group. For example, upon adding a new member to a group, such new member will receive a welcome message, instructions on how to stop receiving messages, and information on how to avoid certain charges by downloading the Sircles app. Sircles also may inform group members who have not replied that they automatically will be removed from the group if they do not participate. Sircles may send other administrative messages as well. BY SIGNING UP FOR THE SERVICE, YOU AGREE TO RECEIVE TEXT MESSAGES FROM SIRCLES, AND YOU REPRESENT AND WARRANT THAT EACH PERSON YOU ADD TO A GROUP HAS CONSENTED TO RECEIVE TEXT MESSAGES FROM SIRCLES.

Camera and Photos. With your permission we may collect images and other information from your device's camera and photos. Location Information. Because Sircles is a map-based application, we require your location to use our services. With your permission, we may collect information about your precise location using methods that include GPS, wireless networks, cell towers, Wi-Fi access points, and other sensors, such as gyroscopes, accelerometers, and compasses. Log Information. We also collect log information when you use our website, such as details about how you are using our services; your device information, such as your web browser type and language; access times; pages viewed; IP address; identifiers associated with cookies or other technologies that may uniquely identify your device or browser; and pages you visited before or after navigating to our website.

Cookies. Cookies can be defined as bits of data stored on your computer that allow website(s) to identify your browser and session. If you reject all cookies, you may not be able to use the Sircles Services or products that require you to "sign in" and you may not be able to take full advantage of all offerings. Most web browsers automatically accept and collect Cookies. However, most browsers also allow you to configure them to accept all cookies, reject all cookies, or notify you when a cookie is set. Depending upon your web browser's security settings, you may have the ability to reject all cookies. The Sircles Media Website uses its own cookies for a number of purposes including, but not limited to: Requiring you to re-enter your password after a certain period of time has elapsed to protect you against others accidentally accessing your account contents; Keep track of preferences specified by our users while using the Sircles Media Website; Estimate and report our total audience size and traffic; Conduct research to improve the content and services provided on the Sircles Media Website; and, Identify to Third Parties that you have visited our Website Many of our Strategic Partners may use Cookies. Sircles Media maintains no control over the use of Cookies by our strategic partners and third-party advertisers. For information on how these third parties utilize Cookies collected, you should examine their respective privacy policies. More specifically, when you use Sircles Services, cookies may be placed on your computing device that informs third parties you visited our services. Because of this, you may receive advertisements relating to Sircles Media. Although Sircles Media provides these ads to third parties and requests that they be placed when the advertising services find our cookies, we do not control the timing, location, and placement of the ads. So, though Sircles Media controls generally when and to what type of individual or cookie receives an ad, we do not control whether a specific user or consumer receives an ad. Should you wish to cease receiving such advertisements, you should opt out of these re-targeting services directly on the third party websites or platforms where possible.

Google AdWords Marketing Sircles Media may use, from time to time, Google Adwords marketing campaigns to promote its products and services. In particular, Sircles Media intends to use Google AdWords "Remarketing" campaigns In using Google Adwords marketing campaigns, Google will place a cookie on your computer when you visit Sircles Media's website(s). As you leave Sircles Media's website(s), this cookie will later enable banners and other materials to appear through which you can return to Sircles Media's website(s). The foregoing being said, through the use of any Google AdWords marketing campaign, Sircles Media: SHALL NOT run an interest-based advertising campaign that collects PII; SHALL NOT use or associate PII with remarketing lists, cookies, data feeds, or other anonymous identifiers; SHALL NOT use or associate targeting information, such as demographics or location, with any PII collected from any Google AdWords ad or landing page associated with it; SHALL NOT target children under the age of 13 through any Google AdWords campaign; SHALL NOT share any PII with Google through Sircles Media's remarketing tag or any product data feeds which might be associated with Sircles Media's ads; SHALL NOT, when creating a remarketing list, use any sensitive information (as defined by Google), or products associated with such sensitive information, about visitors to Sircles Media's Website(s), any of its Webpages, or Apps, whether Sircles Media collected it directly or associated it with a visitor, based on the visitor's profile or behavior on Sircles Media's website(s), webpages, and/or through its Apps; SHALL NOT create a remarketing list or ad that seeks to reach people through prohibited methods; and, SHALL NOT create or produce ad content that implies knowledge of PII or sensitive information. Sircles Media has no objection to Google providing notice or labels to disclose interest-based advertising to its users.

Sircles Media has no objection to Google displaying to its users the remarketing lists, including those of Sircles Media, upon which they appear. For your protection, Google will not disclose Sircles Media remarketing lists or other similar audience lists to another advertiser without Sircles Media's consent. At this time, Sircles Media shall not permit such disclosures. IP Addresses Sircles Media maintains a log of Internet Protocol (IP) addresses when Sircles Media computers, servers, Services, and/or websites (including, the Website) have been accessed. An IP address by itself does not allow us to collect additional PII about you. IP addresses may be used for various purposes including, but not limited to: Diagnose and prevent service or technology problems reported by our users or engineers that are associated with the IP addresses controlled by a specific web company or ISP; Estimate the total number of users visiting a Sircles Media computer, server and/or website from specific geographical regions. Help determine which users have access privileges to certain content, services or resources offered; and, Monitor and prevent fraud and abuse.

OTHER THAN YOUR IP ADDRESS, Sircles Media DOES NOT DIRECTLY COLLECT ANY PERSONALLY IDENTIFIABLE INFORMATION ABOUT YOU UNLESS YOU VOLUNTARILY PROVIDE US WITH THIS INFORMATION.

Revoking permissions. In most cases, if you allowed access to your information, you can simply revoke your permission by changing app settings or on your mobile device itself. Beware that doing so may cause certain services to fail or lose full functionality. l. Data Retention and Account Termination Sircles is all about storing your favorite places and easily sharing them with all your friends and followers. Sircles Media shall use commercially reasonable efforts to maintain storage information subject to the terms of this Privacy and Security Policy and the Terms of Use. The length of time for which Sircles Media retains PII and other information will vary depending on the nature of the services for which the information has been collected and the nature of the information. Although this period may extend beyond the end of your relationship with Sircles Media, it will be retained for only so long as necessary for Sircles Media to respond to any issues arising from your relationship with Sircles Media. When Sircles Media no longer needs or requires your personal information in the normal course of business operations and/or due diligence, Sircles Media will destroy, delete, erase or convert information to an anonymous form without notice to you. Sircles Media will store your basic account information, like your name, phone number, email address and friends, followers, following and Sircle of Trust, until you request for us to delete it. The length of time we store location information varies based on how precise it is and which services you've used. For example, if you use the Map or search for businesses near you, we continue storing this information about your favorite places so you can recall it later. If location information is associated with a share, care, check in, message or Sircles Story, we'll retain that location as long as we are storing the related content. Depending on the package of services purchased, Sircles Media may delete information including, but not limited to, stored messages, videos, audio, other content, and records of your account without notice to you. Sircles Media recommends that you back up on your own computer any critical and important information prior to allowing your Sircles Services to terminate or expire.

Should your account be terminated, Sircles Media may immediately and permanently delete all stored messages, videos, audio, other content, and records of your account without notice to you. If you ever decide to stop using Sircles, you can simply request that we delete your account by contacting our privacy officer at privacy@Sircles.com. Additionally, we will delete most of the information we've collected about you after you've been inactive for a long period of time-but not before we try to contact you first. Keep in mind, that we cannot promise deletion will occur within a specific timeframe. There may be legal requirements to store your data and we may need to retain your data if we receive valid legal process asking us to preserve content, if we receive reports of abuse or other Terms of Use violations, or if your account or content created by you is flagged for abuse or other Terms of Use violations. Additionally, we may also retain certain information in backup for a limited period of time or as required by law.

CONSENT Sircles Media may obtain personal information about you through a variety of sources. For each source or method, the manner of consent may differ. In general, Sircles Media operates on an "Opt-IN" basis. That is, Sircles Media will obtain your consent to use information provided to it by describing the intended use and requesting that you indicate your agreement. At any time, you may expressly inform Sircles Media you do not wish your information to be used in a particular manner through contacting our privacy officer at privacy@sircles.com. While there is no penalty to change your settings, Sircles Media may not be able to provide certain services without the ability to use your information in particular internal settings. Where Sircles Media obtains information about a consumer from its customers or other third parties, Sircles Media presumes that the consumer has previously provided appropriate consent to the party from whom Sircles Media obtains the information. In any case, the consumer can be assured that this Privacy and Security Policy applies to any information obtained from a third party. You have the right to object to targeted marketing.

ACCESS You have the right to access your personal data. Subject to certain limitations imposed by applicable privacy laws, you have the right to request that Sircles Media provide you with a copy of your account and/or personal information and/or information regarding how we have used that personal information. Any requests for access to information should be directed to our Privacy Officer at the contact information provided below. We will make every effort to respond to your request in a reasonable timeframe consistent with applicable law. We provide you the means to correct much information that Sircles Media may have about you. Where you cannot change incorrect information about you in our system, you may request incorrect information to be corrected at any time by contacting privacy@Sircles.com. We respect the right to delete information.

SECURITY Sircles Media takes the issue of protecting your anonymity and personal information very seriously. Sircles Media protects the information it obtains about you with appropriate, commercially reasonable safeguards and security measures consistent with standard information practices. These measures include commercially reasonable technical and procedural steps to protect your data from misuse, unauthorized access or disclosure, loss, alteration, or destruction. For security purposes, Sircles Media does not disclose all of its security measures. Be assured that Sircles Media does employ commercially reasonable industry standard measures to protect your information. Sircles Media may routinely complete audits of its systems.

DISPUTE RESOLUTION Should you have any complaints with respect to Sircles Services' compliance with our Privacy and Security Policy, our Privacy Shield commitments, and our GDPR commitments, we encourage you to contact us directly to resolve any such complaints. Sircles Media is committed to remedying any issues as they arise and expressly commits to resolve complaints about our collection or use of your personal information. We value our customers and their privacy. As such, this commitment reflects our general business philosophy but also complies with Privacy Shield and other applicable principles. Consequently, we want to hear from you should you have any issues regarding our privacy practices. You may send an email to privacy@Sircles.com. Sircles Media has further committed to refer any unresolved complaints with respect to Sircles Media Service's compliance with our Privacy and Security Policy, our Privacy Shield commitments, or our GDPR commitments to JAMS, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact or visit JAMS for more information: JAMS https://www.jamsadr.com/jams-chicago You can submit a case or file a complaint at: https://www.jamsadr.com/file-an-eu-us-privacy-shield-or-safe-harbor-claim. The services of JAMS are provided at no cost to you for any matters relating to the privacy of your data, our Privacy and Security Policy, our Privacy Shield commitments, and/or our GDPR commitments. JAMS has been identified by us as an independent recourse mechanism to hear any such disputes. Should you have any unresolved complaints with respect to Sircles Media Service's compliance with our Privacy and Security Policy, our Privacy Shield Commitments, or our GDPR commitments, you may also contact the Federal Trade Commission ("FTC") (https://www.ftccomplaintassistant.gov/) as the appropriate statutory body that has jurisdiction over any claims related to our privacy practices. However, the FTC does not generally resolve individual consumer complaints. For any of our European Union and UK customers, you also have the right to lodge a complaint with the applicable supervising authority. In compliance with the Privacy Shield Framework, you may be able to invoke binding arbitration in the event of unresolved complaints. For general cases unrelated to the privacy of your data, our Privacy and Security Policy, our Privacy Shield commitments, or our GDPR commitments, you can still file a complaint at with JAMS at https://www.jamsadr.com/about/submit-a-case. Please note that use of a private mediation service such as JAMS for complaints unrelated to the subjects specified in 6.1-6.4, you will likely require fees to be paid.

DISCLAIMER AS TO THIRD-PARTY CONTENT Although our corporate owned websites may contain links to other third-party websites and/or may be advertised on such third-party websites, Sircles Media is not responsible for the privacy practices or the content of such websites and specifically disclaims any such responsibility. Sircles Media does not monitor the privacy practices or content of these websites. If you have any questions about the privacy practices of a website other than a Sircles Media owned website, you need to contact the Privacy Officer of the website about which you have a question.

As stated above, Sircles Media cannot control the targeted advertising you receive when you leave our Sircles Services. Depending on your settings, you may receive Sircles Media advertisements off of our website because your browser contains retained data from Sircles Services. While Sircles Media provides third parties with advertisements and your computing devices may retain data that you visited Sircles Services, we cannot control the computers or servers owned by third parties. You can adjust settings with some of these Third Parties to opt out of targeted advertising. You can also choose to use an incognito or other function that precludes retention of browser information. But. modifications of your browser settings may affect the quality of Sircles Services you receive.

INCORPORATION OF OTHER APPLICABLE TERMS Your use of our Apps, Website, and Sircles Services is subject to this Privacy and Security Policy as well as the Terms of Use and Free Flight Terms and Conditions, the terms of which are incorporated into this Privacy and Security Policy by reference. You should carefully review the Terms of Use.

DATA PROCESSING AGREEMENT (EU CUSTOMERS ONLY). For those Sircles Media customers using PII from EU residents, we include here as part of our Privacy and Security Policy our Data Processing Agreement.

STANDARD CONTRACTUAL CLAUSES (EU CUSTOMERS ONLY). For our EU Customers, we will provide a copy of the EU Standard Contractual Clauses upon request.

PRIVACY OF CHILDREN We make it a practice not to knowingly obtain and/or retain information about individuals under the age of thirteen (13). Indeed, no part of Sircles Services is directed to anyone under the age of thirteen (13).

ADDITIONAL INFORMATION When you post content on and/or through the Sircles Services, you have the ability to post content which may include personally identifiable information or PII about yourself. You are responsible for the information you (a) post online; (b) post through use of the Sircles Services; or, (c) share with another website that you link to from our Website. You do so at your own risk. Sircles Media warns you to be careful in posting information accessible to the public. If you post personal information online that is accessible to the public, you may receive unsolicited messages from other parties or other unwanted and possibly harmful contact. Sircles Media warns you to be careful in posting information accessible to the public.

CUSTOMER OBLIGATIONS By using the Sircles Services, you agree to use any information about any other Sircles Media Customer, particularly PII, obtained through Sircles Services in a manner consistent with the Terms of Use, this Privacy and Security Policy, and the privacy protections provided for in such policies.

REVISIONS TO PRIVACY AND SECURITY POLICY Sircles Media reserves the right to revise, amend, or modify this Privacy and Security Policy, our Terms of Use, and other online policies and agreements at any time and in any manner. Sircles Media shall provide notice of such changes by posting the revised policies to the applicable Sircles Media owned websites and by either (a) providing you a message the next time you login into your account or (b) sending you electronic mail to the email address you provided when creating your account. With respect to this Privacy and Security Policy, you should visit our website at Sircles.com from time to time to review the then-current terms. At any time, the current-posted policies govern and shall be binding.

CALIFORNIA CONSUMER PRIVACY ACT ("CCPA") Sircles Media continuously keeps abreast of privacy and security developments. And, while certain laws may not specifically apply to Sircles Media or its operations, it strives to implement best practices across its business operations. California enacted the CCPA to protect the privacy of its consumers. The CCPA applies to businesses that meet certain criteria. While Sircles Media does not meet these criteria, Sircles Media nonetheless acknowledges the principles of the CCPA. In fact, Sircles Media has for some time reflected the principles of the CCPA in its business practices and policies. Specifically, our Privacy and Security Policy addresses the requirements of the CCPA. Nonetheless, in this section, we emphasize certain of our business practices that align with specific aspects of the CCPA to make them more prominent for our California customers. Subject to our Section 5(L) above, individuals have the right to request deletion of their personal information. You may request that your personal information be deleted at any time by contacting privacy@Sircles.com. However, consistent with Section 5(L), the request for deletion of information will be sent to the applicable data controller. Sircles Media will not discriminate against anyone for exercising their privacy rights provided under any law, particularly the CCPA. Indeed, Sircles Media does not discriminate against any of its customers. Sircles Media does not provide financial incentives in exchange for the use of your personal data and does not sell your personal information.

For Additional Information or Questions, Contact Our Privacy Officer Sircles Media has a designated Privacy Officer. If you have additional questions or concerns regarding how Sircles Media is managing or using your personal information, please send your concerns in writing to our Privacy Officer by e-mail at privacy@Sircles.com. For those Sircles Media customers using PII from EU residents, we include below our Data Processing Agreement.

SCHEDULE 1 DATA PROCESSING AGREEMENT For those Sircles Media customers using PII from EU residents, we include here as part of our Privacy and Security Policy our Data Processing Agreement.

INTRODUCTION This Sircles Media Data Processing Agreement ("DPA") reflects the parties' agreement with respect to the terms governing the processing of personal data and is included as a subsection of the Sircles Media Privacy and Security Policy ("Privacy Policy"). As such, the terms of the Privacy and Security Policy and Sircles Media Terms of Use ("Terms of Use") apply to this DPA. In all cases, Sircles Media ("Processor"), or a third party acting on behalf of the Processor, acts as the processor of personal data and the ___________________ shall be the Controller. The terms of this DPA shall follow the terms of the Privacy Policy and the Terms of Use and any terms not otherwise defined in the DPA shall follow the definitions used in the Terms of Use.

THIS DPA INCLUDES:

(i) Standard Contractual Clauses, attached hereto as

SCHEDULE 1.

(a) APPENDIX 1 to the Standard Contractual Clauses, specifying the types of personal data processed by Sircles Media.

(b) APPENDIX 2 to the Standard Contractual Clauses, which includes a description of the technical and organizational security measures implemented by Sircles Media. (ii) List of Subcontractors, attached hereto as

SCHEDULE 2.

1. Scope and Responsibility The Processor will process personal data on behalf of Controller, as necessary to perform the services pursuant to the Privacy Policy, the DPA, and the Terms of Use ("Policies"). Processing shall include such actions as may be specified in the Policies. The Processor will process personal data for the duration of the Policies and other relevant contracts unless otherwise agreed upon in writing. The Controller shall be entitled to demand the modification, deletion, blocking and making available of personal data during and after the applicable term in accordance with the further specifications of such agreement on return and deletion of personal data. The terms of this DPA shall equally apply if testing or maintenance of automatic processes or of processing equipment is performed on behalf of Controller, and access to personal data in such context cannot be excluded.

2. Obligations of Processor The Processor shall collect, process and use personal data only within the scope of Controller's instructions. If the Processor thinks that an instruction of the Controller infringes the E.U. General Data Protection Regulation or the U.S.-E.U. Privacy Shield protections, it shall point this out to the Controller without delay. The Processor shall structure the Processor's internal corporate organization to ensure compliance with the E.U. General Data Protection Regulation or the U.S.-E.U. Privacy Shield protections. Such measures hereunder shall include, but not be limited to,

`a) preventing unauthorized access to personal data processing systems (physical access control);`

`b) preventing unauthorized processing or use of personal data (logical access control);`

`c) ensuring that persons entitled to use a personal data processing system gain access only to such personal data as they are entitled to access, and that, in the course of processing or use and after storage, personal data cannot be read, copied, modified or deleted without authorization (data access control);`

`d) ensuring that personal data cannot be read, copied, modified or deleted without authorization during electronic transmission, transport or storage on storage media, and that the target entities for any transfer of personal data by means of data transmission facilities can be established and verified (data transfer control);`

`e) ensuring proper records are maintained to document whether and by whom personal data has been entered into, modified in, or removed from personal data processing systems (entry control);

`f) ensuring that personal data is processed solely in accordance with the instructions of the Controller (control of instructions);`

`g) ensuring that personal data is protected against accidental destruction or loss (availability control);`

`h) ensuring that personal data collected for different purposes can be processed separately (separation control); An overview of the above listed technical and organizational measures shall be attached to this DPA as APPENDIX 2. The Processor shall ensure that any personnel entrusted with processing Controller's personal data have undertaken to comply with the principle of data secrecy in accordance with the E.U. General Data Protection Regulation and the U.S.-E.U. Privacy Shield protections and have been duly instructed on them. Sircles Media has identified a Data Protection Officer in its Privacy and Security Policy. Processor shall, without undue delay, inform the Controller in case of a serious interruption of operations or violations by the Processor or persons employed by it of provisions to protect personal data or of terms specified in this DPA. In such an event, the Processor shall implement the measures necessary to secure the Personal Data and to mitigate potential adverse effects on the data subjects without undue delay. The Controller shall retain title as to any carrier media provided to Processor as well as any copies or reproductions thereof. The Processor shall store such media safely and protect them against unauthorized access by third parties. The Processor shall, upon Controller's request, provide to Controller all information on Controller's personal data and personal information. Processor shall be obliged to securely delete any test and scrap material based on an instruction issued by the Controller on a case-by-case basis. Where the Controller so decides, the Processor shall hand over such material to the Controller or store it on the Controller's behalf. The Processor shall be obliged to audit and verify the fulfillment of the above-entitled obligations and shall maintain an adequate documentation of such verification.`

3. Obligations of Controller The Controller and the Processor shall be separately responsible for conforming with such statutory data protection regulations as are applicable to them in accordance with the E.U. General Data Protection Regulation and the U.S.-E.U. Privacy Shield protections. The Controller shall inform the Processor without undue delay and comprehensively about any errors or irregularities related to statutory provisions on the processing of personal data detected during a verification of the results of such processing. The Controller shall, upon instruction or termination or expiration of the Terms, stipulate, within a period of time set by the Processor, the reasonable measures to return data carrier media or to delete stored data.

4. Enquiries by Data Subjects to Controller Where the Controller, based upon applicable data protection law, is obliged to provide information to an individual about the collection, processing or use or its personal data, the Processor shall assist the Controller in making this information available, provided that:

(i) the Controller has instructed the Processor in writing to do so, and

(ii) the Controller reimburses the Processor for the costs arising from this assistance. Where a data subject requests the Processor to correct, delete or block personal data, the Processor shall refer such data subject to the Controller.

5. Subcontractors The Processor shall be entitled to subcontract the Processor's obligations defined in the Policies to third parties only with the Controller's written consent (which shall be affirmed by a Controller's agreement to the policies). Controller consents to Processor's subcontracting to Processor's affiliated companies and third parties, as listed in SCHEDULE 2, of Processor's contractual obligations hereunder. If the Processor intends to instruct subcontractors other than the companies listed in SCHEDULE 2, the Processor must notify the Controller thereof in writing (email to the email address(es) on record in Processor's account information for Controller is sufficient) and must give the Controller the possibility to object against the instruction of the subcontractor within 30 days after being notified. The objection must be based on reasonable grounds (e.g. if the Controller proves that significant risks for the protection of its Personal Data exist at the subcontractor). If the Processor and the Controller are unable to resolve such objection, either party may terminate the Terms of Use by providing written notice to the other party. The provisions of this section also apply if the Processor uses a subcontractor in a third country. The Controller hereby authorizes the Processor, to agree in the name and on behalf of the Controller with a subcontractor which processes or uses the personal data of the Controller outside of the EEA, to enter into EU Standard Contractual Clauses for the Transfer of Personal Data to Processors Established in Third Countries dated 5 February 2010. This applies accordingly from the date of this authorization with respect to EU Standard Contractual Clauses (Processors) already concluded by the Processor with such subcontractors.

6. Duties to Inform Where the Processor's personal data becomes subject to search and seizure, an attachment order, confiscation during bankruptcy or insolvency proceedings, or similar events or measures by third parties while being processed, the Processor shall inform the Controller without undue delay. Processor shall, without undue delay, notify to all pertinent parties in such action, that any personal data affected is the Controller's sole property and area of responsibility. In case of any conflict, the regulations of this DPA shall take precedence over the regulations of the Policies. Where individual regulations of this DPA are invalid or unenforceable, the validity and enforceability of the other regulations of this DPA shall not be affected. The Standard Contractual Clauses in SCHEDULE 1 will apply to the processing of Personal Data by Processor under the Policies. Upon the incorporation of this DPA into the Terms of Use, the parties are agreeing to the Standard Contractual Clauses in SCHEDULE 1 and all appendixes attached. In the event of any conflict or inconsistency between this DPA and the Standard Contractual Clauses, the Standard Contractual Clauses shall prevail. The Standard Contractual Clauses apply only to personal data that is transferred from the European Economic Area (EEA) to outside the EEA, either directly or via onward transfer, to any country or recipient: (i) not recognized by the European Commission as providing an adequate level of protection for personal data (as described in the EU Data Protection Directive), and (ii) not covered by a suitable framework recognized by the relevant authorities or courts as providing an adequate level of protection for personal data, including but not limited to binding corporate rules for processors.

7. Parties to this DPA This DPA is an amendment to and forms part of the Privacy and Security Policy. The legal entity agreeing to this DPA as Controller represents that it is authorized to agree to and enter into this DPA for, and is agreeing to this DPA solely on behalf of, the Controller. SCHEDULE 2 Standard Contractual Clauses Sircles Media has implemented the EU sanctioned Standard Contractual Clauses and will make them available upon request List of Subprocessors