Last Updated November 21, 2018
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 records 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.
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.
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:
- 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.
- 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
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.