Last Updated January 16, 2020 

Please note that Circle has updated Section 4 of the Circle Invest Privacy Policy.  If you have any questions, please email us at support@circle.com.

This Privacy Policy describes how Circle Internet Financial, Inc. (“Circle”) collects, uses, stores, shares and protects your information whenever you use the Circle Invest platform through Circle’s mobile applications or website. We know how important privacy is to our users, which is why we only collect the information we need and will not share your personal information with any third parties unless it is necessary. Even within Circle, access to your personal information is limited to only those employees who require such information to handle matters relating to compliance, identity verification and customer support.

We may change this Privacy Policy from time to time. When we do make updates, we’ll let you know by changing the date above. If it is a big update, we’ll send you a notification or post a notice on our website. If you ever have any questions about changes made to the Privacy Policy, just reach out to Support.

By using Circle Invest through Circle’s website or mobile apps, you consent to the practices contained in this Privacy Policy.

1. Information We Collect

What You Directly Provide Us

When you create a Circle Invest account (your “Account”), we’ll collect some important details about you such as your name, address, phone number, email, birth date, last four digits of your social security number, and password.

If you want to link a bank account as a funding source to your Account, we’ll need to collect the bank account and related financial account information, including billing name and address. As Circle adds additional features, you may also be prompted to provide additional information.

Sometimes we need to request more information to verify your identity or to meet legal and regulatory obligations. When that is necessary, you will be prompted to provide such information.

In the event that Circle integrates with other platforms, you may be prompted from time to time to grant Circle access to additional information from such platform (or grant such partner platform access to information you have provided to Circle).

What is Automatically Collected

There is some information that is automatically collected as you use Circle. This information allows us to deliver cool new features, more easily handle your customer support issues and better protect your account. This information includes:

• Device Information. We collect information about your device, including the type of device (Computer vs. iPhone vs. Android), operating system, mobile phone number, browser type and language, and device identifiers (such as IMEI and MAC address).

• Location Information. In order to surface the appropriate experience to you and to combat fraud, we record things like the IP address of each login.

• Transactions. We collect information about your transaction activity such as the type of transaction (deposit, purchase, sale, withdrawal), amount, date, time, conversion rate and other relevant details for each transaction.

• Cookies. Like most mobile apps and websites, we use cookies. Cookies are small data files that we place on your device that allow us to identify you as a Circle user and provide a customized Circle experience. We use both session and persistent cookies when you access our website or content. Session cookies expire and no longer have any effect when you log out of your account or close your browser. Longer lasting cookies, known as persistent cookies, remain on your browser until you erase them or they expire. You are free to decline our cookies if your browser or browser add-on permits, but doing so may interfere with your use of Circle. The help section of most browsers or browser add-ons provides instructions on blocking, deleting or disabling cookies.

2. Protecting Your Information

Throughout this policy, we use the term “personal information” to describe information that is associated with you or can be used to identify you. We do not consider personal information to include information that has been anonymized.

We protect your information using physical, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure and alteration. Some of the safeguards we use are firewalls and data encryption, physical access controls to our data centers, and information access authorization controls. Sometimes in order to better secure your information and use it for the purposes contemplated by this Privacy Policy, certain personal data may be stored with our third party partners and service providers. All of our physical, electronic and procedural safeguards are designed to comply with applicable laws and regulations.

3. How We Use Your Information

We collect all of this information so that we can provide you with a safe and seamless way to purchase, sell, and hold Digital Currencies. The information we collect allows us to:

• Deliver the full range of Digital Currency buying and selling functionality of the Circle product;
• Keep in touch with you - whether it be for providing customer service, notifying you of cool new features that have been added to the mobile apps, or providing security notices or information;
• Verify your identity so that we can prevent fraud or unauthorized activity;
• Improve Circle or add new product features by analyzing usage trends;
• Personalize the Circle experience by matching product features to things that we think you specifically might be interested in; and
• Fulfill any other purpose for which the information was collected.

We will never sell or rent your personal information to third parties. We may combine your information with information we collect from other companies and use it to improve and personalize the Services, as well as our content and advertising.

4. How We Share Your Information

Sharing With Third Parties

In order to provide you with the Circle product and meet our legal and regulatory obligations, we may share the information we collect as detailed below:

• If you link a bank account, we will share your account information with our banking partners so that we can process transactions. In order to make adding a bank account as easy as possible, we’ve partnered with Plaid Technologies, Inc. (“Plaid”), who will receive your account information during this process. All information shared with Plaid will be treated in accordance with Plaid’s own privacy policy, which can be found at https://plaid.com/privacy. We also may need to share your information with your own banking institution in order to verify and complete transactions.
• In order to prevent fraud, we will sometimes need to share your information with third party identity verification services. This lets us make sure you are who you say you are, by comparing the information you provide us to public records and other third party databases.
• In order to improve Circle’s functionality, we will sometimes share information with service providers that help us analyze how people are using the app. This allows us to refine popular features and improve or eliminate features people don’t use.
• As a regulated financial institution, we may need to share your information with law enforcement or government officials. We will only do this when we are compelled to do so by a specific regulation, subpoena, court order or formal request, or we otherwise believe in good faith that we need to share such information to prevent physical harm, financial loss, or are obligated to report illegal activity.
• In order to complete third party financial, technical and legal audits of Circle’s operations, we may need to share information about your Account as part of such review.
• If Circle merges with, gets acquired by, or enters into any other transaction in which another Company will assume control of all or part of the business, that Company will have access to the information you have provided to us.  If this happens, we will notify you of any such change.
• We will share your information with other third parties if you specifically authorize us to do so.

5. How To Change or Delete Your Information

If you need to add or change any information, you can just log in to your Circle Account and make the change in your settings. If it doesn’t look like you can make the change on your own, just reach out to Support and we’ll take care of it.

If you want to know what information we’re keeping on you, check out the categories listed above. We can also provide you with a copy of this information, but we won’t include any sensitive financial information.

If you want to close your Circle account, know that as a regulated financial institution we are required to retain certain information you have provided for a number of years.

6. Children’s Privacy

Unfortunately, if you’re under 18, you can’t use Circle Invest. So we don’t knowingly solicit or collect information from anyone under 18. If we become aware that a child under the age of 18 has provided us with personal information, we’ll delete it immediately.

7. Privacy Shield

Circle (including its affiliate entities that may handle your information) complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States. Circle has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov.

You may contact us regarding the Privacy Shield, including requests to access your personal information that is retained by Circle, via the Support link in the “Questions?” section below. Circle commits to cooperate with the panel established by the EU data protection authorities (DPAs) and comply with the advice given by the DPA panel with regard to personal information transferred from the EU to the United States. The Federal Trade Commission has jurisdiction over Circle's compliance with the Privacy Shield. In certain circumstances, you may be able to invoke binding arbitration with respect to adherence to the Privacy Shield. If Circle shares personal information with certain third parties, Circle may be liable if those parties process that information in a manner that is inconsistent with the Privacy Shield Principles. Circle may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

8. Questions?

If you have any questions about this Privacy Policy, feel free to reach out to Support.