Circlet Privacy Policy
Effective Date: 1/1/2025
1. Introduction
Dexterity Technologies Limited ("we",
"our", or "us") operates the Circlet messaging app.
This Privacy Policy ("Privacy Policy") helps explain our data
practices, including the information we process to provide our Services.
For example, our Privacy Policy talks about what information
we collect and how this affects you. It also explains the steps we take to
protect your privacy.
This Privacy Policy applies to all of our Services unless
specified otherwise.
Please also read Circlet’s Terms of Service ("Terms"),
which describe the terms under which you use and we provide our Services.
2. Information We Collect
Circlet must receive or collect some information to operate,
provide, improve, understand, customize, support, and market our Services,
including when you install, access, or use our Services.
The types of information we receive and collect depend on
how you use our Services. We require certain information to deliver our
Services and without this we will not be able to provide our Services to you.
For example, you must provide your e-mail address in order to create an account
to use our Services.
Our Services have optional features which, if used by you,
require us to collect additional information to provide such features. You will
be notified of such collection, as appropriate. If you choose not to provide
the information needed to use a feature, you will be unable to use the feature.
For example, you cannot share your photos in the chat room if you do not permit
us to access your photo library from your device. Permissions can be managed
through your Settings menu on both Android and iOS devices.
Information You Provide
- Your Account Information. You must provide your e-mail
address and basic information (including a display name of your choice) to
create a Circlet account. If you don’t provide us with this information,
you will not be able to create an account to use our Services. You can add
other information to your account, such as a profile picture and "description"
information.
- Your Messages. We keep your messages in encrypted
form in the ordinary course of providing our Services to you. We will
keep your messages for a period only (up to 7 days). After the period,
your messages will be removed from our servers. By default, your messages
are not stored on your device. Therefore, once you killed the app, the
messages are cleared from the memory of your device.
- We offer end-to-end encryption for our Services.
End-to-end encryption means that your messages are encrypted to protect
against us and third parties from reading them.
- Transactions And Payments Data. If you use our
payments services, or use our Services meant for purchases or other
financial transactions, we process additional information about you,
including payment account and transaction information. Payment account and
transaction information includes information needed to complete the
transaction (for example, information about your payment method, shipping
details and transaction amount). If you use our payments services
available in your country or territory, our privacy practices are described
in the applicable payments privacy policy.
- Customer Support And Other Communications. When you
contact us for customer support or otherwise communicate with us, you may
provide us with information related to your use of our Services, including
copies of your messages, any other information you deem helpful, and how
to contact you (e.g., an email address). For example, you may send us an
email with information relating to app performance or other issues.
Automatically Collected Information
- Usage And Log Information. We collect information
about your activity on our Services, like service-related, diagnostic, and
performance information. This includes information about your activity
(including how you use our Services, your Services settings, how you
interact with others using our Services (including when you interact with
a business), and the time, frequency, and duration of your activities and
interactions), log files, and diagnostic, crash, website, and performance
logs and reports. This also includes information about when you registered
to use our Services; the features you use like our messaging, groups
(including group name, group picture, group description), payments or
business features; profile photo, "description" information;
whether you are online, when you last used our Services; and when you last
updated your "description" information.
- Device And Connection Information. We collect
device and connection-specific information when you install, access, or
use our Services. This includes information such as hardware model,
operating system information, battery level, signal strength, app version,
browser information, mobile network, connection information (including
phone number, mobile operator or ISP), language and time zone, IP address,
device operations information, and identifiers.
Third-Party Information
- User Reports. Just as you can report other users,
other users or third parties may also choose to report to us your
interactions and your messages with them or others on our Services; for
example, to report possible violations of our Terms or policies. When a
report is made, we collect information on both the reporting user and
reported user. To find out more about what happens when a user report is
made.
- Third-Party Service Providers. We work with
third-party service providers to help us operate, provide, improve,
understand, customize, support, and market our Services. For example, we
work with them to distribute our apps; provide our technical and physical
infrastructure, delivery, and other systems; provide engineering support,
cybersecurity support, and operational support; supply location, map, and
places information; process payments; help us understand how people use
our Services; market our Services; help you connect with businesses using
our Services; conduct surveys and research for us; ensure safety,
security, and integrity; and help with customer service. These companies
may provide us with information about you in certain circumstances; for
example, app stores may provide us with reports to help us diagnose and
fix service issues.
- Third-Party Services. We allow you to use our
Services in connection with third-party services. If you use our Services
with such third-party services, we may receive information about you from
them.
3. How We Use Information
We use information we have (subject to choices you make and
applicable law) to operate, provide, improve, understand, customize, support,
and market our Services. Here's how:
- Our Services. We use information we have to operate
and provide our Services, including providing customer support; completing
purchases or transactions; improving, fixing, and customizing our
Services; and connecting our Services with other Systems that
you may use. We also use information we have to understand how people use
our Services; evaluate and improve our Services; research, develop, and
test new services and features; and conduct troubleshooting activities. We
also use your information to respond to you when you contact us.
- Safety, Security, And Integrity. Safety, security,
and integrity are an integral part of our Services. We use information we
have to verify accounts and activity; combat harmful conduct; protect
users against bad experiences and spam; and promote safety, security, and
integrity on and off our Services, such as by investigating suspicious
activity or violations of our Terms and policies, and to ensure our
Services are being used legally.
- Communications About Our Services. We use
information we have to communicate with you about our Services and let you
know about our terms, policies, and other important updates. We may
provide you marketing for our Services.
- No Third-Party Banner Ads. We still do not allow
third-party banner ads on our Services. We have no intention to introduce
them, but if we ever do, we will update this Privacy Policy.
4. Information You And We Share
You share your information as you use and communicate
through our Services, and we share your information to help us operate,
provide, improve, understand, customize, support, and market our Services.
- Send Your Information To Those With Whom You Choose To
Communicate. You share your information (including messages) as you
use and communicate through our Services.
- Information Associated With Your Account. Your e-mail
address, display name and photo, "description" information, and
message receipts are available to anyone who uses our Services and added
you as friends.
- Third-Party Service Providers. We work with
third-party service providers to help us operate, provide, improve,
understand, customize, support, and market our Services. We work with
these companies to support our Services, such as to provide technical
infrastructure, delivery and other systems; market our Services; conduct
surveys and research for us; protect the safety, security, and integrity
of users and others; and assist with customer service. When we share
information with third-party service providers in this capacity, we
require them to use your information on our behalf in accordance with our
instructions and terms.
- Third-Party Services. When you or others use
third-party services that are integrated with our Services, those
third-party services may receive information about what you or others
share with them.
5. Assignment, Change Of Control, And Transfer
In the event that we are involved in a merger, acquisition,
restructuring, bankruptcy, or sale of all or some of our assets, we will share
your information with the successor entities or new owners in connection with
the transaction in accordance with applicable data protection laws.
6. Managing And Retaining Your Information
You can access your information in the app through the “Profile”
menu. In the “Profile” page, you can see and update your “description”
information and see and update your photo.
We store information for as long as necessary for the
purposes identified in this Privacy Policy, including to provide our Services
or for other legitimate purposes, such as complying with legal obligations,
enforcing and preventing violations of our Terms, or protecting or defending
our rights, property, and users. The storage periods are determined on a
case-by-case basis that depends on factors like the nature of the information,
why it is collected and processed, relevant legal or operational retention needs,
and legal obligations.
If you would like to further manage, change, or delete your
information, you can do that through the following tools:
- Profile Page. You can change your “description”
information and change your photo in the Profile page.
- Deleting Your Circlet Account. You can delete your Circlet
account at any time (including if you want to revoke your consent to our
use of your information pursuant to applicable law) using our in-app
delete my account feature. When you delete your Circlet account, your messages
are deleted from our servers as well as any of your other information we
no longer need to operate and provide our Services. Deleting your account
will, for example, delete your account info and profile photo, delete you
from all Circlet groups, delete all Circlet groups that you created, and
delete your message history. Be mindful that if you only delete Circlet
app from your device without using our in-app delete my account feature,
your information will continue to be stored with us, and you can still
login to Circlet using another device. Please remember that when you
delete your account, it does not affect your information related to the
groups you join before.
7. Law, Our Rights, And Protection
We access, preserve, and share your information described in
the “Information We Collect” section of this Privacy Policy above if we have a
good-faith belief that it is necessary to: (a) respond pursuant to applicable
law or regulations, legal process, or government requests; (b) enforce our
Terms and any other applicable terms and policies, including for investigations
of potential violations; (c) detect, investigate, prevent, or address fraud and
other illegal activity or security, and technical issues; or (d) protect the
rights, property, and safety of our users, Circlet, us or others, including to
prevent death or imminent bodily harm.
8. Our Global Operations
Circlet shares information globally, both internally within
the Dexterity and externally with our partners and service providers,
and with those with whom you communicate around the world, in accordance with
this Privacy Policy. Your information may, for example, be transferred or
transmitted to, or stored and processed in, the United States; countries or
territories where the Dexterity affiliates and partners, or our service
providers are located; or any other country or territory globally where our
Services are provided outside of where you live for the purposes as described
in this Privacy Policy. Circlets uses global infrastructure and data centers,
including in the United States. These transfers are necessary to provide the
global Services set forth in our Terms. Please keep in mind that the countries
or territories to which your information is transferred may have different
privacy laws and protections than what you have in your home country or
territory.
9. Updates To Our Policy
We may amend or update our Privacy Policy. We will provide
you notice of amendments to this Privacy Policy, as appropriate, and update the
“Effective Date” at the top of this Privacy Policy. Please review our Privacy
Policy from time to time.
10. Contact Us
If you have questions or issues about our Privacy Policy,
please contact us.
support@dexterity.com.hk