Sircles Media Inc. (“Sircles”) values the trust its customers place in it. This Privacy and Security Policy is provided for the benefit of customers of Sircles as well as other consumers and parties who seek information from or about Sircles 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.

1. OPENING STATEMENTS

1.1 Definitions.

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

1.2 Our Commitment to Privacy

At Sircles, 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 collects, uses, discloses and protects the information we obtain.

1.3 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.

1.4 Website and Apps Not Directed to Minors

The Website and Apps are not directed toward children or minors under the age of 13.

1.5 Reserved for Future Use

2. PERSONAL INFORMATION COLLECTED AND HOW IT IS USED

2.1 Scope of PII

(a) 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 first and last name, your phone number, your birthdate, address, credit card number, bank account information, and/or personal identification number (such as a social security number or driver’s license number).

(b) PII does not include any public information that is readily attainable through federal, state or local public record distribution channels.

(d) 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.

(e) Sircles considers your Internet Protocol (“IP”) address to be PII and will treat it as such.

2.2 Information Collected

(a) Sircles collects information that is considered PII and other information that, by itself, would not be considered personally identifiable information (“Non-PII”).

(b) 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 first and last name, email address, and phone number. By using the App, we also collect your location and IP address. We also ask that you share your friends with us. 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.

(c) Should any payments be made, Sircles uses a third-party processing service and does not itself possess or store your financial information. You should consult the policies of the third-party payment processing service for more information. This information may likely contain both PII and Non-PII depending on the nature of the account holder information.

2.3 Collecting and Using Personally Identifiable Information

(a) Sircles 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.

(b) Generally, Sircles collects personal identifiable information when an individual registers with or uses any of the Sircles Services. This information typically includes, at a minimum, your first and last name, birthdate, phone number, and any additional information provided by the account holder that could identify that account holder.

(c) 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.

(d) For example, we may use the information we receive about you (a) as part of our efforts to keep Sircles safe and secure; (b) to provide Sircles Services; (c) to make suggestions to you and other users on Sircles; and (d) provide support.

Granting us this permission not only allows us to provide Sircles 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.

(e) 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.

(f) 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 not to use a particular method of communication.

(g) 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.

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

(i) 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. Rather, Sircles shall presume that you have previously provided such consent to any such third party from whom Sircles obtains such information. This only applies to information provided by third parties to Sircles. Sircles does not provide third parties with access to your account information and only shares your information with third parties where we have your consent to do so.

(j) Restricted Use. In the normal course of its business operations, Sircles restricts the use of your PII to Sircles’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.

(k) 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.

(l) We may also use the PII you provide in registering with and using Sircles 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.

2.4 Disclosing Personal Information

(a) 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.

(b) Sircles 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.

(c) Sircles 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 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.

(d) 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. For example, we may use your phone number to text you.

(e) In some cases, Sircles Customers may be able to download your videos and other public information, and store them on, their computers and servers. Other Sircles Customers may also be able to use shared links by which they provide related parties who might not also be Sircles Customers access to your content.

(f) Strategic Partners. Sircles 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 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 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 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.

(g) Business Transfers. Sircles 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.

(h) Legal Compliance. Sircles 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 agreements as well as to protect the property and rights of Sircles, its Strategic Partners or other third parties; (4) to protect, in Sircles’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’s sole discretion; and/or, generally, (6) to comply with the law.

(i) Notice. Unless restricted from doing so, Sircles 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 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 is under no other obligation to assist you in challenging or opposing a release of your information

(j) Onward Transfer Liability. Sircles may be liable for onward transfers of personal data to third parties in violation of this policy and the Privacy Shield.

2.5 Non-Personally Identifiable Information

(a) In addition to collecting PII as previously described, Sircles also collects other non-PII.

(b) Non-PII collected by Sircles may be utilized without restriction

(c) 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.

(d) Because non-PII cannot be used to identify you, Sircles may in its discretion provide non-PII to other persons or entities.

2.6 Information Obtained From Use of Sircles’s Services

(a) 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 Website uses its own cookies for a number of purposes including, but not limited to:

(i) 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;

(ii) Keep track of preferences specified by our users while using the Sircles Website;

(iii) Estimate and report our total audience size and traffic;

(iv) Conduct research to improve the content and services provided on the Sircles Website; and,

(v) Identify to Third Parties that you have visited our Website

Many of our Strategic Partners may use Cookies. Sircles 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. Although Sircles 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 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.

(b) Google AdWords Marketing

Sircles may use, from time to time, Google Adwords marketing campaigns to promote its products and services. In particular, Sircles 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’s website(s). As you leave Sircles’s website(s), this cookie will later enable banners and other materials to appear through which you can return to Sircles’s website(s).

The foregoing being said, through the use of any Google AdWords marketing campaign, Sircles:

(i) SHALL NOT run an interest-based advertising campaign that collects PII;

(ii) SHALL NOT use or associate PII with remarketing lists, cookies, data feeds, or other anonymous identifiers;

(iii) 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;

(iv) SHALL NOT target children under the age of 13 through any Google AdWords campaign;

(v) SHALL NOT share any PII with Google through Sircles’s remarketing tag or any product data feeds which might be associated with Sircles’s ads;

(vi) 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’s Website(s), any of its Webpages, or Apps, whether Sircles collected it directly or associated it with a visitor, based on the visitor's profile or behavior on Sircles’s website(s), webpages, and/or through its Apps;

(vii) SHALL NOT create a remarketing list or ad that seeks to reach people through prohibited methods; and,

(viii) SHALL NOT create or produce ad content that implies knowledge of PII or sensitive information.

Sircles has no objection to Google providing notice or labels to disclose interest-based advertising to its users.

Sircles has no objection to Google displaying to its users the remarketing lists, including those of Sircles, upon which they appear.

For your protection, Google will not disclose Sircles remarketing lists or other similar audience lists to another advertiser without Sircles’s consent. At this time, Sircles shall not permit such disclosures.

Sircles may collect information about your browser and session at the Website and/or using the Website Services.

(d) IP Addresses

Sircles maintains a log of Internet Protocol (IP) addresses when Sircles 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:

(i) 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;

(ii) Estimate the total number of users visiting a Sircles computer, server and/or website from specific geographical regions.

(iii) Help determine which users have access privileges to certain content, services or resources offered; and,

(iv) Monitor and prevent fraud and abuse.

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

2.7 Data Retention

(a) Sircles shall use commercially reasonable efforts to maintain storage information subject to the terms of this Privacy and Security Policy and the Terms of Use.

(b) The length of time for which Sircles 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.

(c) Although this period may extend beyond the end of your relationship with Sircles, it will be retained for only so long as necessary for Sircles to respond to any issues arising from your relationship with Sircles.

(d) When Sircles no longer needs or requires your personal information in the normal course of business operations and/or due diligence, Sircles will destroy, delete, erase or convert information to an anonymous form without notice to you.

(e) Depending on the package of services purchased, Sircles may delete information including, but not limited to, stored messages, videos, audio, other content, and records of your account without notice to you. Sircles recommends that you back up on your own computer any critical and important information prior to allowing your Sircles Services to terminate or expire.

(f) Should your account be terminated, Sircles may immediately and permanently delete all stored messages, videos, audio, other content, and records of your account without notice to you.

3. CONSENT

3.1 Sircles may obtain personal information about you through a variety of sources. For each source or method, the manner of consent may differ.

3.2 In general, Sircles operates on an “Opt-IN” basis. That is, Sircles will obtain your consent to use information provided to it by describing the intended use and requesting that you indicate your agreement.

3.3 At any time, you may expressly inform Sircles you do not wish your information to be used in a particular manner through account settings. While there is no penalty to change your settings, Sircles may not be able to provide certain services without the ability to use your information in particular internal settings.

3.4 Where Sircles obtains information about a consumer from its customers or other third parties, Sircles presumes that the consumer has previously provided appropriate consent to the party from whom Sircles 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.

3.5 You have the right to object to targeted marketing.

4. ACCESS

4.1 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 provide you with a copy of your account and/or personal information and/or information regarding how we have used that personal information.

4.2 Any requests for access to information should be directed to our Privacy Officer at the contact information provided below.

4.3 We will make every effort to respond to your request in a reasonable timeframe consistent with applicable law.

4.4 We provide you the means to correct much information that Sircles 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.

4.5 We respect the right to delete information.

5. SECURITY

5.1 Sircles takes the issue of protecting your anonymity and personal information very seriously. Sircles 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.

5.2 For security purposes, Sircles does not disclose all of its security measures. Be assured that Sircles does employ commercially reasonable industry standard measures to protect your information. Sircles may routinely complete audits of its systems.

6. DISPUTE RESOLUTION

6.1 Should you have any complaints with respect to Sircles Services’ compliance with our Privacy and Security Policy, we encourage you to contact us directly to resolve any such complaints. Sircles 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. 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.

7. 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 is not responsible for the privacy practices or the content of such websites and specifically disclaims any such responsibility. Sircles 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 owned website, you need to contact the Privacy Officer of the website about which you have a question.

As stated above, Sircles cannot control the targeted advertising you receive when you leave our Sircles Services. Depending on your settings, you may receive Sircles advertisements off of our website because your browser contains retained data from Sircles Services. While Sircles 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.

8. INCORPORATION OF OTHER APPLICABLE TERMS.

8.1 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.

9. 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).

10. ADDITIONAL INFORMATION

10.1 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 warns you to be careful in posting information accessible to the public.

10.2 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 warns you to be careful in posting information accessible to the public.

11. CUSTOMER OBLIGATIONS

By using the Sircles Services, you agree to use any information about any other Sircles 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.

12. REVISIONS TO PRIVACY AND SECURITY POLICY

12.1 Sircles 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.

12.2 Sircles shall provide notice of such changes by posting the revised policies to the applicable Sircles 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.

12.3 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.

13. CALIFORNIA CONSUMER PRIVACY ACT (“CCPA”)

13.1 Sircles continuously keeps abreast of privacy and security developments. And, while certain laws may not specifically apply to Sircles or its operations, it strives to implement best practices across its business operations.

13.2 California enacted the CCPA to protect the privacy of its consumers. The CCPA applies to businesses that meet certain criteria. While Sircles does not meet these criteria, Sircles nonetheless acknowledges the principles of the CCPA and our Privacy and Security Policy addresses the requirements of the CCPA.

13.3 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.

13.4 Subject to Section 4.5 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.

13.5 Sircles will not discriminate against anyone for exercising their privacy rights provided under any law, particularly the CCPA. Indeed, Sircles does not discriminate against any of its customers.

13.6 Sircles does not provide financial incentives in exchange for the use of your personal data and does not sell your personal information.

14. SIRCLES GROUP MESSAGING SERVICE

14.1 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.

For Additional Information or Questions, Contact Our Privacy Officer

Sircles has a designated Privacy Officer. If you have additional questions or concerns regarding how Sircles is managing or using your personal information, please send your concerns in writing to our Privacy Officer by e-mail at privacy@Sircles.com.