Cirqlio Privacy Policy

1. Data We Collect

We collect:

• Approximate and raw device location (processed server-side)
• Uploaded images
• Chat messages
• Call metadata (duration, participants)
• Device and IP information
• Payment transaction data (processed via Stripe or similar)

2. Legal Basis for Processing (EU Users)

Under GDPR, we process data based on:

• Consent (location services)
• Contract performance (service provision)
• Legitimate interest (fraud prevention, moderation)
• Legal obligation (law enforcement compliance)

3. Location Data Processing

• Raw GPS data is securely processed server-side.
• Only approximate distance/bearing is shared with users.
• Location history is not publicly visible.

4. Moderation & Safety Processing

Uploaded content is subject to:

• Automated AI screening
• Quarantine workflows
• Risk scoring

Illegal content may be reported to authorities in accordance with applicable law.

5. Data Retention

We retain data only as long as necessary for:

• Service operation
• Legal compliance
• Safety enforcement

Inactive sessions may be deleted automatically.

6. International Data Transfers

Data may be processed in the United States or other jurisdictions.

Where required, we rely on:

• Standard Contractual Clauses (SCCs)
• Adequacy decisions
• Appropriate safeguards

7. User Rights (EU/UK)

You may request:

• Access
• Correction
• Deletion
• Data portability
• Restriction of processing
• Withdrawal of consent

Contact: contact@cirqlio.com

You may lodge complaints with your local supervisory authority.

8. Security Measures

We implement:

• Encryption in transit (TLS)
• Access controls
• Database isolation
• AI moderation safeguards
• Rate limiting and abuse detection

No system is 100% secure.