Privacy Policy

Last updated April 24, 2023

Introduction and scope

Circle Systems, Inc. and all its affiliates (“Circle,” “we,” “our,” and/or “us”) values the privacy of individuals who use our applications, APIs, and websites and otherwise interact with us online (collectively, our “Services”) such as when you:

  • Visit our website at, or any website of ours that links to this privacy policy (the “Privacy Policy”)
  • Download and use our application(s), such as our mobile application Circle Access Mobile, or any other application of ours that links to this privacy policy
  • Engage with us in other related ways ― including any sales, marketing, or events

This Privacy Policy explains how we collect, use, share and otherwise process information from buyers and users of our Services (“Users”). By using our Services, you agree to the collection, use, disclosure, and procedures this Privacy Policy describes. If you do not agree with our Privacy Policy, please do not use our Services.

Our Services are designed for businesses and their representatives. We do not target consumers – individuals who seek to use our products and services for their personal or household purposes. Accordingly, we treat all personal information we collect in connection with the Services as pertaining to individuals in their business capacity and not their individual capacity.

We provide our Services to users on behalf of our business customers, as a service provider. This Privacy Policy does not apply to any websites, applications or other online services that do not link to this policy, including any applications provided by our business customers that users access using the Services (“Corporate Applications”). To the extent we share personal information with our business customers, this Privacy Policy does not apply to our business customers’ subsequent use of that information.

Information we collect

Personal information you disclose to us.

In Short: We collect personal information that you provide to us. We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

● Your first and last name

● The name of your company

● Your telephone number

● Your email address

Payment Data. We may collect data necessary to process your payment if you make purchases, such as your payment instrument number (such as a credit card number), and the security code associated with your payment instrument. All payment data is stored by Stripe. You may find their privacy policy link(s) here:

Application Data. If you use our application(s), we also may collect the following information if you choose to provide us with access or permission:

■ Geolocation Information. We may request access or permission to track location-based information from your mobile device, either continuously or while you are using our mobile application(s), to provide certain location-based services. If you wish to change our access or permissions, you may do so in your device's settings.

■ Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device's Bluetooth, calendar, camera, own, and other features. If you wish to change our access or permissions, you may do so in your device's settings.

■ Mobile Device Data. We automatically collect device information (such as your mobile device ID, model, and manufacturer), operating system, version information and system configuration information, device and application identification numbers, browser type and version, hardware model Internet service provider and/or mobile carrier, and Internet Protocol (IP) address (or proxy server). If you are using our application(s), we may also collect information about the phone network associated with your mobile device, your mobile device’s operating system or platform, the type of mobile device you use, your mobile device’s unique device ID, and information about the features of our application(s) you accessed.

■ Push Notifications. We may request to send you push notifications regarding your account or certain features of the application(s). If you wish to opt out from receiving these types of communications, you may turn them off in your device's settings.

This information is primarily needed to maintain the security and operation of our application(s), for troubleshooting, and for our internal analytics and reporting purposes.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies. You can find out more about this in our Cookie Policy.

The information we collect includes:

■ Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called "crash dumps"), and hardware settings).

■ Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.

■ Location Data. We collect location data such as information about your device's location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, if you choose to opt-out, you may not be able to use certain aspects of the Services.

Information collected from other sources

In Short: We may collect limited data from public databases, marketing partners, social media platforms, and other outside sources.

In order to enhance our ability to provide relevant marketing, offers, and services to you and update our records, we may obtain information about you from other sources, such as public databases, joint marketing partners, affiliate programs, data providers, social media platforms, and from other third parties. This information includes mailing addresses, job titles, email addresses, phone numbers, intent data (or user behavior data), Internet Protocol (IP) addresses, social media profiles, social media URLs, and custom profiles, for purposes of targeted advertising and event promotion. If you interact with us on a social media platform using your social media account (e.g., Facebook or Twitter), we receive personal information about you such as your name, email address, and gender. Any personal information that we collect from your social media account depends on your social media account's privacy settings. 

Our promise is simple and unequivocal.  Circle is dedicated to delivering security, privacy and trust for the connected world with No Compromise on convenience and ease of use.

When powered by Circle your applications leave ZERO attack surface in the cloud thus eliminating any possible breach on the cloud and leaving you with complete “peace of mind.” With Circle, no one other than your user/customer – including Circle, the company – will ever have access to or control of their data, including meta-data across the cloud, on-premise or at edge!

How we use the information we collect

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

To operate the Services, including to:

  • Authenticate your device and enable access to Corporate Applications;
  • Contact you and authorized individuals in case of a system event;
  • Generally provide, maintain, improve, and enhance our Services;
  • Communicate with you, provide you with updates and other information relating to our Services, including via text message or push notification if you have opted in to receiving such information via text message or put notification; and
  • Provide information that you request, respond to comments and questions, and otherwise provide customer support.

For research and development, including to understand and analyze how you use our Services and develop new products, services, features, and functionality.

For marketing and advertising purposes, such as developing and providing promotional and advertising materials that may be relevant, valuable or otherwise of interest to you.

For compliance, fraud prevention and safety purposes, including (a) to protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); (b) enforcing our Terms of Service or other legal rights; (c) to protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity; or (d) as may be required by applicable laws and regulations or requested by any judicial process or governmental agency.

For other purposes for which we provide specific notice at the time the information is collected.

How we share the information we collect

Business Customers. We may share information, such as logs detailing device access attempts to Corporate Applications, with our business customers, to the extent the information pertains to the business customer’s authorized end users. Our customers have their own policies regarding the collection, use and disclosure of their authorized users’ personal information, and Circle is not responsible for our customers’ handling of such information. Our use of information processed during use of the Services is restricted by our customer agreements. To learn about how a particular customer handles your personal information, we encourage you to read the customer’s privacy statement or contact the customer directly.

Vendors and Service Providers. We may share any information we receive with other vendors and service providers retained in connection with the provision of our Services (such as customer support, hosting, analytics, email delivery, marketing, and database management services). These third parties may use your personal information only as directed or authorized by us and in a manner consistent with this Privacy Policy, and are prohibited from using or disclosing your information for any other purpose.


Marketing Communications. You can unsubscribe from our promotional emails via the link provided in the emails. Even if you opt out of receiving promotional messages from us, you will continue to receive administrative messages from us.

Third Parties. Our Services may contain links to other websites, products, or services that we do not own or operate, including those of our Integrators. We are not responsible for the privacy practices of these third parties. Please be aware that this Privacy Policy does not apply to your activities on these third-party services or any information you disclose to these third parties. We encourage you to read their privacy policies before providing any information to them.

Security. We make reasonable efforts to protect your information by using physical and electronic safeguards designed to improve the security of the information we maintain. However, as our Services are hosted electronically, we can make no guarantees as to the security or privacy of your information.

Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit

International Data Transfers. We are located in the United States and have service providers in other countries, and your personal information may be transferred to the United States or other locations outside of your state, province, or country where privacy laws may not be as protective as those in your state, province, or country.

Children’s Privacy. We do not knowingly collect, maintain, or use personal information from children under 13 years of age, and no part of our Services is directed to children. If you learn that a child has provided us with personal information in violation of this Privacy Policy, then you may alert us at [email protected].

Changes to this Privacy Policy. We will post any adjustments to the Privacy Policy on this page, and the revised version will be effective when it is posted. If we materially change the ways in which we use or share personal information previously collected from you through the Services, we may notify you through the Services, by email, or other communication in accordance with the requirements of applicable law.

Contact Information. If you have any questions, comments, or concerns about our processing activities, please email us at [email protected].

Please see our Website Terms of Service and Software as a Service License Agreement for more details