This Privacy Policy describes how personal data is collected, used, stored, disclosed, and protected when you access or use the website and platform available at https://joincirclo.com (the “Platform”).
The Platform is operated by the owner and administrator of the domain joincirclo.com, based in Panama City, Republic of Panama (the “Operator,” “circlo,” “we,” “us,” or “our”).
By using the Platform, you acknowledge that you have read and understood this Privacy Policy.
The data controller responsible for processing personal data collected through the Platform is:
Operator of joincirclo.com
Panama City, Republic of Panama
Contact: hello@joincirclo.com
If paid features are introduced, payment processing is handled by third-party providers. We do not store full credit card details.
Depending on your jurisdiction, we process personal data under one or more of the following bases:
If you are located in the European Economic Area (EEA), United Kingdom, or similar jurisdiction, applicable data protection laws such as the General Data Protection Regulation (GDPR) may apply.
We process personal data for the following purposes:
We do not sell personal data.
We retain personal data for as long as necessary to:
As a general guideline:
Unless legally required otherwise, personal data is not automatically deleted.
If you request deletion, we will review and respond to your request within 30 business days. Complex requests may require an additional 30 business days. We will delete data where legally permissible. However:
The Platform uses cookies and similar technologies. We distinguish between two categories:
These are required for core Platform functionality and are used without requiring consent:
These are used for analytics and usage tracking to improve the Platform:
Non-essential cookies are only activated after you provide explicit consent via our cookie consent banner. You may accept all cookies, allow only essential cookies, or reject non-essential cookies entirely. Your preference is stored and respected across sessions.
Cookies are small text files stored on your device. Certain core functions of the Platform rely on essential cookies. If you disable all cookies:
Disabling essential cookies may therefore limit or disrupt core Platform functionality.
The Platform may use automated systems to:
Such systems may rely on behavioral and usage data. Certain features involve processing user data through third-party artificial intelligence service providers (such as language model APIs). Data sent to these providers is used solely for generating the requested output and is subject to those providers’ own data processing policies.
Automated processing is used to enhance user experience and maintain platform security. It does not constitute automated decision-making with legal or similarly significant effects on users, nor does it involve financial, legal, or credit decision-making.
We may share personal data with:
We do not sell or rent personal data.
Personal data may be stored or processed outside your country of residence, including but not limited to Panama, the United States, or other jurisdictions where our service providers operate.
Where required by applicable law, we implement appropriate safeguards for international data transfers, which may include Standard Contractual Clauses (SCCs) or other mechanisms recognized under applicable data protection legislation.
We implement commercially reasonable technical and organizational measures, including:
However, no method of transmission or storage is completely secure. We cannot guarantee absolute security.
Use of the Platform is at your own risk.
Depending on applicable law, you may have the right to:
Requests must be submitted to: hello@joincirclo.com
We will acknowledge receipt of your request and respond within 30 business days. Complex or voluminous requests may require an additional 30 business days, in which case we will inform you of the extension.
We may require identity verification before processing requests.
Certain data may be retained where legally required or necessary for legitimate interests.
The Platform is not intended for individuals under the age of 18.
We do not knowingly collect personal data from minors.
If we become aware of such collection, we will take appropriate steps to remove it.
In the event of a material data breach, we will take appropriate remedial measures and provide notification to affected users and relevant authorities where legally required, within the timeframes established by applicable law (including within 72 hours where required under the GDPR).
The Platform may contain links to third-party websites. We are not responsible for the privacy practices or content of those websites.
If you are located in the European Economic Area (EEA) or the United Kingdom, you are entitled to the rights set forth under the General Data Protection Regulation (GDPR). These rights are reflected in Section 11 above.
In addition, you have the right to lodge a complaint with your local data protection authority if you believe your personal data has been processed in violation of applicable data protection law.
The legal bases for processing your data are set out in Section 3. Where we rely on consent, you may withdraw it at any time by contacting us or adjusting your cookie preferences.
To the fullest extent permitted by applicable law, the Operator assumes no liability whatsoever for any damages, losses, claims, or consequences — whether direct, indirect, incidental, special, consequential, or punitive — arising from or related to the collection, use, storage, disclosure, or processing of personal data as described in this Privacy Policy.
The Operator shall have no obligation to provide compensation, refunds, credits, or any form of monetary or non-monetary remedy to any user in connection with data processing activities.
Use of the Platform constitutes acceptance of the data practices described herein. If you do not agree with these practices, you must discontinue use of the Platform.
We may update this Privacy Policy from time to time.
The updated version will be posted on the Platform with a revised “Last Updated” date.
Continued use of the Platform constitutes acceptance of the updated policy.
For questions regarding this Privacy Policy or data protection matters:
circlo
Panama City, Republic of Panama
Email: hello@joincirclo.com