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Privacy Policy

Last updated: 21/04/2025

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This Privacy Policy explains how CircleUp Ltd ("CircleUp," "we," "us," or "our") collects, uses, discloses, and protects information about you. This applies to your use of our website (https://www.letscircleup.co.uk), mobile applications on iOS and Android ("App"), and all services provided through them (collectively, the "Platform").

By using our Platform, you agree to the practices described in this Privacy Policy. Please read it carefully.

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1. Definitions

  • Data: Any information that you provide to us or that we collect, which can identify you directly or indirectly.

  • Data Protection Laws: UK GDPR and any applicable national privacy regulations.

  • User / you: Any person using our Platform who is not employed by CircleUp.

  • Website: https://www.letscircleup.co.uk and all associated subdomains.

  • App: CircleUp mobile apps on iOS and Android.

  • Data Controller: CircleUp Ltd, registered in England and Wales (No. 16142550), with a registered office at Lingfield House, East Grinstead Road, Lingfield, RH7 6ES.

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2. Scope

This Privacy Policy applies to your interactions with CircleUp via the Website and App. It does not apply to third-party websites, platforms, or services linked from our Platform.

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3. Information We Collect

a) Information You Provide to Us

We collect personal data when you:

  • Register for an account

  • Make payments

  • Join events or circles

  • Contact us via email or forms

  • Respond to surveys

  • Subscribe to marketing communications

This may include:

  • Name

  • Email address and phone number

  • Payment and billing details (processed by third parties)

  • Interests, photos, bios, or other optional profile information

  • Survey responses or feedback

b) Information Collected Automatically

When you use the Platform, we collect:

  • IP address

  • Device and browser type

  • Operating system

  • Referral URL

  • Usage data (e.g. features used, pages visited)

  • Geolocation data (with your permission via the App)

  • Crash logs and diagnostics

c) Information from Third Parties

  • Payment processors (e.g. Stripe)

  • Analytics tools (e.g. Google Analytics, Firebase)

  • Social platforms (if you connect or share via third-party services)

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4. How We Use Your Data

We use your information to:

  • Provide and manage your account and membership

  • Facilitate event participation

  • Process payments

  • Improve and personalise our services and recommendations

  • Communicate with you (e.g. updates, customer support)

  • Send you marketing content (with your consent or under soft opt-in)

  • Detect and prevent fraud or misuse

  • Comply with legal obligations

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5. Legal Basis for Processing

We rely on the following lawful bases:

  • Contractual necessity – to provide you with services you signed up for

  • Consent – for marketing communications and cookies

  • Legitimate interests – to improve our Platform and protect our business

  • Legal obligation – where necessary for compliance

Sensitive data (e.g. implied by group type or interests) is processed only with your explicit consent or when you voluntarily provide it.

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6. Sharing Your Information

We may share your data:

  • With other members (e.g. event RSVPs, names in chats or attendee lists)

  • With trusted service providers (e.g. Stripe, Wix, Meta, Firebase, Google)

  • With marketing or analytics partners (for targeted ads, subject to your settings)

  • If legally required to do so (e.g. by court order)

  • In connection with a merger, acquisition, or company restructure

  • In de-identified or aggregated form that cannot identify you

We do not sell your personal data.

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7. Your Choices

You can:

  • Edit your account or profile info via your settings

  • Control marketing preferences via unsubscribe links or settings

  • Enable/disable location sharing via your mobile device

  • Manage cookies via your browser or our cookie banner

  • Request deletion or access to your data at any time

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8. Your Rights

You have the right to:

  • Access your personal data

  • Correct inaccuracies

  • Request deletion ("right to be forgotten")

  • Restrict or object to processing

  • Port your data to another provider

To exercise your rights or request support, please visit our Contact Us page.

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9. Data Security

We use technical and organisational measures to protect your data, including:

  • Secure servers and encrypted connections

  • Password-protected accounts

  • Regular monitoring and security reviews

Despite our best efforts, no method of transmission is completely secure.

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10. Data Retention

We retain your data only as long as necessary for:

  • Providing services

  • Legal, accounting, or regulatory reasons

  • Fraud prevention or platform safety

We typically retain account data for up to 12 months after membership ends unless longer retention is required. Data may remain in backups or archives even after deletion requests, but will not be used.

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11. Business Changes

If CircleUp is acquired or undergoes a restructure, your data may be transferred to the new entity under the same terms of this Privacy Policy.

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12. Media at Events

We may take photos or videos at our events. These may be used in promotional materials including our website, social media, advertising, or other marketing platforms. If you do not wish to appear in photos, please let a team member know at the event or contact us via our Contact Us page.

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13. Cookies

We use cookies and similar technologies to help our website function, understand how people use it, and improve your experience.

When you visit our website for the first time, you’ll see a cookie banner asking for your consent to use non-essential cookies (such as analytics and marketing). You can choose to accept all, or manage your settings.

We use cookies for:

  • Essential functionality – These keep the website running (e.g. navigation, login)

  • Analytics – To help us understand which pages people visit and how they interact with the site

  • Marketing – To show relevant ads and track conversions via tools like Google Ads and Meta Pixel

Some cookies may be set by third-party providers we use, including Google and Meta. You can change or withdraw your consent at any time via the cookie settings in your browser or through the banner on your first visit.

If you have questions about how we use cookies, you can contact us via our Contact Us page.

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14. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be notified on the Website or via email. The "Last Updated" date at the top reflects the latest version.

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15. Contact Us

For any privacy-related enquiries, please use the form on the Contact Us page.

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Thank you for trusting CircleUp. We’re committed to protecting your privacy as we build community across the UK and beyond.

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