Your privacy is critically important to us. At Curiosity IO, LLC-the company that owns Your Circle (“Team”, “Your Circle”, “Curiosity IO”, “Curiosity IO, LLC”, “we”, “our”)-, we have a few fundamental principles:
- We are thoughtful about the personal information we ask you and other people who use our Services (“Users”, “you”) to provide and the personal information that we collect about you through the operation of our services. Read more in the Information We Collect section.
- We store personal information for only as long as we have a reason to keep it. Read more in the How Long We Keep Information section.
- We do not sell any of your information, anything you share in the app, or any analytics or statistics about your use in the app. We do not sell any of your information, ever. Read more in the Sharing Information section.
- We aim for full transparency on how we gather, use, and share your personal information. We share everything to you through our blog and documents like this one. Feel free to contact us to ask questions about our process you have.
Who We Are and What This Policy Covers
We are a group of people who believe in peer-to-peer emotional support. We love connecting people together to form new relationships. Our mission is to change the way emotional support is obtained when life sucks, to help build a trustworthy world, and to change the way mobile app businesses work.
- Our websites (including findyourcircle.co);
- Our mobile applications (including the Your Circle mobile app for Android and iOS);
- White-labeled mobile applications built and sold to non-profit organizations;
- White-labeled websites built and sold to non-profit organizations;
Below we explain how we collect, use, and share information about you, along with the choices that you have with respect to that information.
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Information We Collect
We only collect information about you if we have a reason to do so. For example, to provide our Services, to communicate with you, or to make our Services better for you.
We collect information: if and when you provide information to us, and automatically through operating our Services. Let’s go over the information that we collect.
Information You Provide to Us
It’s probably no surprise that we collect information that you provide to us. The amount and type of information depends on the context and how we use the information. Here are some examples:
- Account Information: We ask for basic information from you in order to set up your account. For example, we require individuals who sign up for an account through our Services to provide an email address–and that’s it. You may provide us with more information like your name, religious beliefs, gender identification, life struggle you are going through, and other personally identifiable information but we don’t require that information to create an account.
- Transaction and Billing Information: If you buy something from us such as a membership to one of our Services, for example, you will provide additional personal and payment information that is required to process the transaction and your payment. You will provide your Google Pay or Apple Pay payment information to process the transaction. All payment processing is done through Google Pay and Apple Pay services. We do not store any payment processing information.
- Communication with other users: Our Services allow you to communicate with others who can relate to you (“Chat”). All Chat messages you send through our Services are visible to the people matched with you by our Team (“Support Group”) and by our Team. Our Team has access to the Chat messages that you send for your Support Group for security reasons if a problem arises. Our Team may also view all Chat messages in your Support Group to gently introduce you to your Support Group. Our Team may start conversations in your Support Group and contact you directly asking if you feel comfortable with your Support Group. Chat messages sent between two individuals (“direct messages”, “one-on-one chat”), not in a Support Group together, are private and never read by our Team.
- Communications With Us: You may also provide us information when you respond to surveys, thank you messages to non-profits or sponsors of the app that helped pay for your membership fees, or communicate with us about a support question.
Information We Collect Automatically
We also collect some information automatically:
- Log Information: Like most online service providers, we collect information that web browsers, mobile devices, and servers typically make available, such as the browser type, language preference, referring site, the date and time of access, operating system, mobile network information, and other information about how you are accessing our Services.
- Usage Information: We collect information about your usage of our Services. For example, we collect information about the educational resources and online and offline resources such as books, movies, podcasts (“Resources”) that you view while using our Services so we may replace unpopular content with content you may find more helpful. As another example, we keep track of the last time that you sent a Chat message to your Support Group to give our Team a chance to contact you to see if you feel welcome with your currently matched Support Group.
- Location Information: At this time, our Services do collect your IP address, as do most of online service providers, however we do not view the location of the IP address. We currently view the IP address that we collect while you use our Services only if an error occurs while you access our Services that we need to fix. We are actively working on removing the collection of your IP address. Your personal location information is not collected, stored, or viewed by our Team.
- Stored Information: We may access information stored on your mobile device via our mobile app. We access this stored information through your device operating system’s permissions. For example, if you give us permission to access the photographs on your mobile device’s camera roll, our Services receive access to the photos you select and decide to upload to our Services. The only stored information accessed by our Services is information you choose to share with our Services and information generated by our Services.
How And Why We Use Information
Purposes for Using Information
We use information about you as mentioned above and for the purposes listed below:
- To provide our Services–for example, to set up and maintain your account, match you with other Users into a Support Group, Chat with you, Chat with other Users in your Support Group, or charge you for any of our paid Services;
- To further develop and improve our Services–for example by adding new features that we think our users will enjoy or will help them to connect with other Users they can relate with more efficiently;
- To monitor and analyze trends and better understand how users interact with our Services, which helps us improve our Services and make them easier to use;
- To monitor and prevent any problems with our Services, protect the security of our Services, detect and prevent fraudulent transactions and other illegal activities, fight spam, and protect the rights and property of Your Circle and others, which may result in us declining a transaction or the use of our Services;
- To communicate with you, for example through an email, about offers and promotions offered by Your Circle and others we think will be of interest to you, solicit your feedback, or keep you up to date on Your Circle and our products;
Legal Bases for Collecting and Using Information
A note here for those in the European Union about our legal grounds for processing information about you under EU data protection laws, which is that our use of your information is based on the grounds that:
(1) The use is necessary in order to fulfill our commitments to you under our Terms of Service or other agreements with you or is necessary to administer your account–for example, in order to enable access to our website on your device or charge you for a paid plan; or
(2) The use is necessary for compliance with a legal obligation; or
(3) The use is necessary in order to protect your vital interests or those of another person; or
(4) We have a legitimate interest in using your information–for example, to provide and update our Services, to improve our Services so that we can offer you an even better user experience, to safeguard our Services, to communicate with you, and better understand user retention and attrition, to monitor and prevent any problems with our Services, and to personalize your experience; or
(5) You have given us your consent–for example before we place certain cookies on your device and access and analyze them later on, as described in this policy.
How We Share Information
We do not sell our Users private personal information. None of your information will be sold, ever.
We share information about you in the limited circumstances spelled out below and with appropriate safeguards on your privacy:
- Third Party Vendors: We may share information about you with third party vendors who need to know information about you in order to provide their services to us, or to provide their services to you or your site. This group includes vendors that help us provide our Services to you (like payment providers that process your credit and debit card information, fraud prevention services that allow us to analyze fraudulent payment transactions, postal and email delivery services that help us stay in touch with you, customer Chat and email support services that help us communicate with you, registrars, registries, and data escrow services that allow us to provide domain registration services), those that assist us with our marketing efforts (e.g. by providing tools for identifying a specific marketing target group or improving our marketing campaigns), those that help us understand and enhance our Services (like analytics providers), who may need information about you in order to, for example, provide technical or other support services to you. We require vendors to agree to privacy commitments in order to share information with them. Other vendors are listed in our more specific policies.
- Legal Requests: We may disclose information about you in response to a subpoena, court order, or other governmental request.
- To Protect Rights, Property, and Others: We may disclose information about you when we believe in good faith that disclosure is reasonably necessary to protect the property or rights of Your Circle, third parties, or the public at large. For example, if we have a good faith belief that there is an imminent danger of death or serious physical injury, we may disclose information related to the emergency without delay.
- Aggregated or De-Identified Information: We may share information that has been aggregated or reasonably de-identified, so that the information could not reasonably be used to identify you. For instance, we may publish aggregate statistics about the use of our Services. We may also share aggregate statistics with a non-profit organization customer of our Services as part of their License agreement to determine the impact of using our Services. This information may also be used by the Your Circle team to make public on a homepage or in other marketing material.
Information Shared Publicly
Everything that you do with our Services is shared only with our Team and the Users of your Support Group you are matched with. None of your information is shared publicly.
How Long We Keep Information
We feel that it is important that your information is permanently deleted after it is no longer needed. Below is the policy for your data:
- The answers to your bio questions are deleted immediately after you are matched with your Support Group. In the event that you need to be matched to a new Support Group, you will be asked to answer the bio questions again.
The answers to your bio questions are stored in a Google Sheet and Typeform database. By answering the bio questions, you are accepting the privacy policies of Google Drive and Typeform.
- Chat messages sent to your Support Group or to Users in a one-to-one direct message is deleted after 7 days. This includes Chat messages stored in our database as well as Chat messages stored in our database backups.
Chat messages are stored in a database maintained by our Team and is located in New York, United States by Digital Ocean and database backups stored in Oregon by Amazon AWS. By using our Services, you are accepting the privacy policies of Digital Ocean and AWS.
- Analytics information is stored forever. There is currently no way at this time to delete analytics events stored while you use our Services.
- Customer support messages sent to our Team are stored forever. This is so we can refer back to your history of past help requests to help you solve your current and future issues.
Customer support requests are received by email and stored in a G Suite email address. By contacting our Team, you are accepting the privacy policies of G Suite.
- At this time, server logs are kept forever until our Team manually deletes them. Our Team is actively working on automatically removing server logs after a set amount of time.
While using our Services, we have the option of showing you goods and services of non-profit organizations as advertisements. Non-profit organizations have the right to advertise their goods and services through our Services to provide more options for you to receive help.
We have the option of promoting the goods and services of non-profit organizations to you depending on your personally identifiable information through your bio question answers. For example, if a non-profit organization has a scholarship available for high school students, we have the option of promoting the scholarship to Users between the ages of 16 and 19. This information is analyzed by our team only and is never shared with a non-profit organization, ever.
No information is shared to non-profit organizations, ever. Learn more about how none of your information is ever sold in the Sharing Information section.
While no online service is 100% secure, we work very hard to protect information about you against unauthorized access, use, alteration, or destruction, and take reasonable measures to do so, such as monitoring our Services for potential vulnerabilities and attacks.
We keep our systems and software up-to-date with the latest security patches, test our software against unauthorized access, store sensitive information encrypted, contact you in the event of a security breach, and store backups of our database.
You have several choices available when it comes to information about you:
- Limit the Information that You Provide: If you have an account with us, you can choose not to provide the optional account information, answers to bio questions, and paid Services. Please keep in mind that if you do not provide this information, certain features of our Services–for example, match making and Chat–may not be accessible.
- Opt-Out of Electronic Communications: You may opt out of receiving promotional messages from us. Look for the “Unsubscribe” text to click and stop receiving emails from us. If you opt out of promotional messages, we may still send you other messages, like those about your account and legal notices.
- Close Your Account: If you no longer want to use our Services, you can close your Your Circle account. Please keep in mind that we may continue to retain some of your information after closing your account, as described in How Long We Keep Information above–for example, when that information is reasonably needed to comply with (or demonstrate our compliance with) legal obligations such as law enforcement requests, or if data cannot be deleted by our third-party tools. At this time, the only method to close your account is by contacting us and asking us to close your account.
If you are located in certain countries, including those that fall under the scope of the European General Data Protection Regulation (AKA the “GDPR”), data protection laws give you rights with respect to your personal data, subject to any exemptions provided by the law, including the rights to:
- Request access to your personal data;
- Request correction or deletion of your personal data;
- Object to our use and processing of your personal data;
- Request that we limit our use and processing of your personal data; and
- Request portability of your personal data.
You can access, correct, or delete your personal data by contacting us. We will respond to you and delete your information that we are able to described in How Long We Keep Information above within 72 hours of notifying you we will delete your information.
EU individuals also have the right to make a complaint to a government supervisory authority.
Controllers and Responsible Companies
Your Circle’s Services are worldwide. Curiosity IO, LLC is the controller of personal information, which means that they are the company responsible for processing that information, based on the particular service and the location of the individual using our Services.
Depending on the Services you use, more than one company may be the controller of your personal data. Generally, the “controller” is the Curiosity IO, LLC company that entered into the contract with you under the Terms of Service for the the product or service you use.
Worldwide controller for Your Circle information:
Curiosity IO, LLC
PO Box 2567
Cedar Rapids, IA, United States
How to Reach Us
Other Things You Should Know
- In the case of US based entities, entering into European Commission approved standard contractual arrangements with them, or ensuring they have signed up to the EU-US Privacy Shield; or
- In the case of entities based in other countries outside the EEA, entering into European Commission approved standard contractual arrangements with them.
You can ask us for more information about the steps we take to protect your personal information when transferring it from the EU.
We do not knowingly solicit data from or market to children under the age of 16 with our Services. If a parent or guardian becomes aware that their child has provided us with information without their consent, they should contact us. We will delete such information as described in How Long We Keep Information above.
You must be at least 16 years of age to use our Services. We are not responsible for Users who lie about their age.
That’s it! Thanks for reading.
Generic, non-personally identifiable reports are shared with non-profits. - 2018-07-06
More details about this update can be found in this blog post.
- Last bullet point under section, “Sharing information” has been updated. Generic, non-personally identifiable reports are generated and shared with non-profit organizations that pay Your Circle to offer Your Circle to people they help. These statistical reports are to help the non-profits understand their impact in Your Circle.
Add more privacy to users. Be more clear. - 2018-05-28
More details about this update can be found in this blog post.
- Chat messages sent in the app are deleted 7 days later.
- None of your personal information is sold, ever. None of your personal information is public.
- Section added for advertisements where non-profits can advertise their programs and services to you in the app. None of your information is sold or shared with anyone outside of our team including non-profits, ever.
- More details have been added to the policy to be more readable and less vague.