For purposes of this Privacy Policy:

1. “Application” refers to the Company’s website and/or applications, which can be accessed at www.circle.net or www.circlejobs.com and through mobile application stores.

2. “Service” refers to the Company’s services accessed via the Application - we are a social network platform for businesses and employment. Our Service enable users to (including but not limited to):

   a. Connect with other users to engage in communication and share information through posts, view relevant content, reactions, and chat messages

   b. Post job profile information to job opportunities

   c. Discover and contact other users, vendors, and service providers

3. The terms “we,” “us,” and “our” refer to the Company. “You” refers to you, as a user of our Application or our Service.

4. "Personal Information" refers to any information that can identify an individual, such as name, email, phone number and business financial information, and can include information about how you engage with our Services, such as device information or IP address.

5. "Non-Personal Information" refers to information that does not identify an individual, such as data relating solely to a business, anonymous usage data, general demographic information, and aggregated data.

6. "Third-Party Services" refers to services or content (including data, information, applications, and other products and services) provided by third parties that may be used or integrated with our Service.

7. "Job Application" refers to the process and status of applying for a job, including the use of Company’s automated application features (“AI Apply”), manual submissions, and follow-up interactions (whether conducted manually by the user or assisted by AI, such as answering questionnaires, assessments, or employer requests during the application process) in the application process.

8. “Job Profile” refers to Job Application related information stored on your account, including work experience, resume information, assessment results, answers to screener questions, job search preferences, and any Personal Information relating to Job Application.

9. “Application Information” refers to all data, content, and materials submitted, generated, or transmitted in connection with the job application process through the Services. This includes, without limitation: resumes, cover letters, job preferences, responses to questionnaires, sensitive information (such as EEO data, WOTC eligibility, character assessments), AI-generated or AI-assisted application materials or information, electronic signatures, follow-up responses provided to Employers (including interview-related or compliance questions), and any communications exchanged with Employers via the Application. This may include information transmitted to third-party systems outside of Company’s control, such as an Employer’s applicant tracking system (“ATS”). Application Information may also include metadata such as submission timestamps, application status, and tracking information related to the progress of the application.

10. "Job Seeker" refers to individuals seeking employment opportunities through the Service.

11. "Employer" refers to businesses or individuals posting job opportunities on the Service.

12. "Job Posting" refers to the listings of employment opportunities posted by Employers on the Service.

13. "Resume" refers to the information contained in the resumes you upload or create through the Service, which may include your employment history, education, skills, and other information relevant to job applications.

14. “Third-Party Services” refers to services or content (including data, information, applications, and other products and services) provided by third parties that may be used or integrated with our Application or Service. This includes, without limitation, Employer applicant tracking systems (“ATS”), recruitment or compliance platforms, and other vendors that process information at your direction or on behalf of Employers.

1.1 Information You Provide.  

(a) Account Registration. To create an account, you must provide data including your name, email address, and/or mobile number, and authentication data. If you register for a premium Service, you will also need to provide payment and billing information (e.g., credit card).

(b) Profile and Job Profile Information. You may provide additional information by updating your personal profile or Job Profile, such as your location, photo, employer and/or business information, education, work experience, skills, and referrals. This may also include sensitive information (e.g., work authorization status). You do not have to provide this information, but doing so helps Employers and opportunities find you. Please do not add personal data that you would not want to be publicly available.

(c) Activity on the Application or Service. We collect information from your activities on our Service, including: (i) Content you create (posts, comments, searches, shares); (ii) Inputs to enable our AI services, including resumes, job preferences, skills, questionnaires, employer-requested information, and any attachments you upload for AI Apply or resume generation; (iii) Responses generated or submitted on your behalf through Circle AI (e.g., job application answers, assessments, personality or character evaluations, and follow-up responses to employers); (iv) Messages you send and receive, including communications with Employers and AI-assisted replies, subject to applicable law; (v) Content you provide through photos, videos, or voice features; (vi) Purchases or transactions you make, including payment card details; (vii) Features you use on our Application and the actions you take; (viii) Electronic signatures you provide when consenting to or submitting applications, forms, or compliance documents; (ix) Social media information if you interact with Company’s social media or sync your account; (x) Time, frequency, and duration of your activities on our Service.

1.2 Interactions with Other Users. We collect information about your connections, followers, groups, and interactions with other users. We may also infer things about you based on others’ activity (e.g., suggesting a connection if your contacts are members of a group).

1.3 Job Applications and Job Postings. When applying to jobs or posting them, you may provide additional Personal Information: (a) As a Job Seeker: resumes (AI-generated, generated with Job Profile information or uploaded), job preferences, application answers (manual or AI-generated), compliance responses (e.g., eligibility, work authorization, tax credit forms if requested by Employer), application progress, and communication history. (b) As an Employer: job titles, descriptions, requirements, compensation, benefits and business information, which may include verification documents (e.g., EIN, business registration), location, and contact details. Employers may also upload pictures, videos, and other content. We also track job application progress and related communications (e.g., invitations, follow-up requests, interview scheduling).

1.4 Information From Others.

(a) Content and News. You and others may post content that includes information about you (as part of articles, posts, comments, videos) on our Services. We also may collect public information about you, such as professional-related news and accomplishments, and make it available as part of our Service, including, as permitted by your settings, in notifications to others of mentions in the news.

(b) Partners. We may receive personal data (e.g., your job title and work email address) about you when you use the services of our customers and partners, such as employers or prospective employers, staffing agencies, non-profit organizations, and applicant tracking systems providing us job application data.

1.5 Information Collected via Technology.

In an effort to improve the quality of the Service, we track information provided to us by your browser or by our Application when you view or use the Service, such as the website you came from (known as the “referring URL”), the type of browser you use, the device from which you connected to the Service, the time and date of access, and other information that does not personally identify you. We track this information using cookies, or small text files which include an anonymous unique identifier. Cookies are sent to a user’s browser from our servers and are stored on the user's device. Each time you access the Service, your browser sends the cookie back to our servers to allow us to recognize your device and collect data about your usage patterns. Device information we collect and receive includes: (a) The device and software you’re using, and other device characteristics; (b) Signals from your device; (c) Information you’ve shared with us through device settings, like GPS location, camera access, photos and related metadata; (d) Information about the network you connect your device to and your connection, including your IP address; (e) Some location-related information, even if Location Services is turned off in your device settings. This includes using IP addresses to estimate your general location; (f) Information about our Service’s performance on your device.

This information helps us analyze and understand how the Service is being used, enabling us to enhance user experience, optimize performance, and improve the overall quality of our offerings.

1.6 Minor Users (Age 13–17).

The Application is not directed to children under 13, and we do not knowingly collect personal information from children under 13. If you believe we have collected such information, please contact us at support@circle.net so we can promptly delete it. Users ages 13–17 may use the Application only with the consent and under the supervision of a parent or legal guardian, who is deemed to have accepted this Privacy Policy and the User Agreement on the minor’s behalf. Such use is further subject to the following additional restrictions:

(a) No Advertising or Profiling. Company does not knowingly sell, share, profile, or use the personal information of minor users for targeted advertising, behavioral advertising, or automated profiling. 

(b) Parental Rights. Parents/guardians may review, correct, or request deletion of their child’s personal information by contacting support@circle.net or by using the in-app Deactivate Account function in Account settings.

(c) Employment Law Compliance. Certain employment opportunities may not be legally available to minors under federal or state labor laws (including hour and job-type restrictions). It is the responsibility of the minor and their parent/guardian to ensure compliance with all applicable employment laws.

(d) Sensitive Information. Sensitive information (including, but not limited to, race/ethnicity, disability status, veteran status, government incentive eligibility, or character assessments) will never be made visible for minors through search, suggestions, or candidate lists. Such information may only be transmitted to an Employer if the user affirmatively applies to a job posting (including through AI Apply).

2.1 Personal Information.  We may use Personal Information for the following purposes:

(a) To provide, administer, maintain and/or analyze the Service

(b) To improve our Service and conduct research

(c) To communicate with you, including to send you information about our Service and events

(d) To develop new programs and services

(e) To prevent fraud, criminal activity, or misuses of our Services, and to protect the security of our IT systems, architecture, and networks

(f) To carry out business transfers

(g) To comply with legal obligations and legal process and to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or other third parties

(h) To target (and measure the performance of) ads to users, visitors and others both on and off our Services directly or through a variety of partners, using the information collected and information inferred from data described above (e.g., using job titles from a profile to infer industry, seniority, and compensation bracket; using graduation dates to infer age or using first names or pronoun usage to infer gender; using your feed activity to infer your interests; or using device data to recognize you as a user).

Except as otherwise stated in this Privacy Policy, we do not sell, trade, rent or otherwise share for marketing purposes with third parties without your consent. We do share Personal Information with vendors who are performing services for the Company, such as the servers for our email communications who are provided access to user’s email address for purposes of sending emails from us. Those vendors use your Personal Information only at our direction and in accordance with our Privacy Policy. We may share Personal Information with outside parties if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to meet any applicable legal process or enforceable governmental request; to enforce applicable User Agreement, including investigation of potential violations; to address fraud, security or technical concerns; or to protect against harm to the rights, property, or safety of our users or the public as required or permitted by law.

2.2 Personal Information regarding Job Profile, Job Application and Job Posting.

(a) Profile. We do not sell or trade candidate profiles. Personal and sensitive information will only be shared with Employers (i) when you affirmatively apply to a job, (ii) when you choose to make your Job Profile visible to Employers by selecting “Open to Work,” or (iii) when your information is included in candidate search results or suggested matches in response to an Employer’s request, in each case consistent with your account settings.

Personal information such as contact details, work authorization, education, and resume/job profile data is stored and processed securely in accordance with industry standards. Certain categories of highly sensitive information – including, but not limited to, character or personality assessments, responses to employer questionnaires, and information related to federal or state hiring incentives (such as Work Opportunity Tax Credit (WOTC) eligibility including information about SNAP, TANF, or conviction history) – are encrypted in transit and at rest. Company maintains strict technical and organizational safeguards to ensure that such data cannot be accessed or viewed in human-readable form by Company, except as strictly necessary to transmit to Employers at your direction or to comply with applicable law.

For users between the ages of 13 and 17, additional restrictions apply: such sensitive information will never be shared through search, suggestions, or candidate lists. It may only be transmitted to an Employer if you affirmatively apply to that Employer’s job posting.

(b) Transfer of Information to Employer. We may send Job Seeker Personal Information to Employer, including, on the instruction of Job Seekers and Employers. Such transfers are performed in the course of the job search, application, and interview process. Job Seeker Personal Information transferred to Employers in this way is processed in accordance with our Terms of Use and those of the relevant Employer. This transfer may include sending your application and/or additional candidate information, such as your contact details, to other platforms that process Job Seeker Personal Information for the Employer, such as the Employer’s preferred ATS or scheduling platform.

(c) Transfer of Information to Job Seeker. We may provide certain Employer-related information to Job Seekers. This includes publishing job ads, business information and pages, and salary information on the Application and publishing Job Posting on third-party websites. We may also make available certain Employer-related information to Job Seekers, such as information about an Employer’s activity and responsiveness on the Application. This can include the Employer representative’s name, the Employer’s city/state location, whether the Employer has taken or has chosen not to take an action with regard to the Job Seekers’ resume or application such as opening, viewing, responding to or making a decision in regard to it, whether the Employer has engaged with other Job Seekers or viewed other Job Seeker’ resumes, and whether the Employer has taken an action in regard to a Job Listing such as pausing or closing it. We do this in order to help Job Seeker evaluate employment opportunities. As an Employer, when you use the Application (for example by posting a Job Posting, browsing candidate list or contacting a Job Seeker on the Application) you agree that we may provide this information to Job Seeker.

2.3 Sensitive Information Notice.  

(a) Scope. Sensitive information includes but is not limited to: racial or ethnic origin, gender identity, disability status, veteran status, sexual orientation, character or personality assessments, responses to employer questionnaires, and information related to federal or state hiring incentives (such as Work Opportunity Tax Credit (WOTC) eligibility, SNAP, TANF, conviction history, or veteran status). Company does not require you to provide Sensitive Information as part of creating a profile or using the Application.

(b) Consent and Reuse. Where Employers request sensitive information (such as EEO data relating to race, ethnicity, gender, veteran, or disability status), Company will collect and store such responses only with your explicit consent at the time of first submission. Once provided, this information may be securely retained in your Job Profile and reused to pre-populate or transmit subsequent job applications at your direction, including through AI Apply. Sensitive information is never used by Company for advertising, profiling, or marketing. You may review, update, or delete this information at any time in your Account settings.

(c) Withdrawal. You may withdraw consent at any time by (i) removing the information through your Profile management settings, or (ii) emailing support@circle.net with your request. If you withdraw consent, Company will no longer use the stored sensitive information for new applications. However, prior submissions already transmitted to Employers cannot be withdrawn or deleted from the Employer’s systems. Withdrawal will not affect the lawfulness of processing based on consent before its withdrawal.

(d) Encryption Safeguards. Certain categories of highly sensitive information – including, but not limited to, character or personality assessments, responses to employer questionnaires, and information related to hiring incentives (such as WOTC eligibility including SNAP, TANF, or conviction history) – are encrypted in transit and at rest. Company maintains strict technical and organizational safeguards to ensure that such data cannot be accessed or viewed in human-readable form by Company, except as strictly necessary to transmit to Employers at your direction or to comply with applicable law.

(e) Special rules for minors. For users between the ages of 13 and 17, such sensitive information will never be made visible through search, suggestions, or candidate lists. It may only be transmitted to an Employer if you affirmatively apply (including through AI Apply) to that Employer’s job posting.

(f) Prohibition on ads/profiling. Company will never use sensitive information for advertising, profiling, or marketing purposes.

2.4 Retention of Personal Information.  Company retains Personal Information only for as long as reasonably necessary to provide the Service, carry out the purposes described in this Privacy Policy, or as otherwise required to comply with legal, regulatory, or contractual obligations. Retention periods vary depending on the type of data:

(a) Account Information (e.g., name, contact details, profile data) is retained for the life of your account. Upon deletion, Company will permanently delete or anonymize such data subject to Section [Account Deletion].

(b) Job Application Data (including resumes, responses, and AI Apply submissions) may be retained to allow you to track your application history and re-use information for future applications, unless you delete such data from your profile or request deletion.

(c) Sensitive Information (such as EEO data, WOTC responses, or character assessments) is retained only with your consent and may be reused for future applications at your direction. You may withdraw consent and delete this information at any time in your Account settings.

(d) Log Data and Technical Information (e.g., device identifiers, activity logs) is retained for up to 24 months for security, auditing, and fraud-prevention purposes.

(e) Legal Holds: Certain information may be retained longer if required by applicable law, regulation, or to resolve disputes.

After these periods, Company will either delete or irreversibly anonymize Personal Information.

2.5 Non-Personal Information.  In general, we use Non-Personal Information to help us improve the Service and customize the user experience. We also aggregate Non-Personal Information in order to track trends and analyze use patterns on the Application. This Privacy Policy does not limit in any way our use or disclosure of Non-Personal Information and we reserve the right to use and disclose such Non-Personal Information to our partners, advertisers and other third parties at our discretion. In the event we undergo a business transaction such as a merger, acquisition by another company, or sale of all or a portion of our assets, your Personal Information may be among the assets transferred. You acknowledge and consent that such transfers may occur and are permitted by this Privacy Policy, and that any acquirer of our assets may continue to process your Personal Information as set forth in this Privacy Policy. If our information practices change at any time in the future, we will post the policy changes to the Application so that you may opt out of the new information practices. We suggest that you check the Application periodically if you are concerned about how your information is used.

2.6 Business Information.  In all circumstances, we are committed to safeguarding the privacy and security of your business information, especially financial information. We do not store or share individual-level business financial data. To provide the Service, we employ advanced security measures, including encryption and data aggregation, designed to ensure the confidentiality and integrity of your information.

2.7 Legal Bases.  For users located in the European Union, United Kingdom, or other jurisdictions with similar laws, Company processes your Personal Information only when we have a valid legal basis: (a) Consent (e.g., when you allow us to store and reuse sensitive information for job applications, or when you opt into marketing communications); (b) Contract (e.g., when processing is necessary to provide the Service you request, such as creating an account, generating resumes, or submitting job applications); (c) Legal Obligation (e.g., retaining records to comply with tax, employment, or regulatory requirements); (d) Legitimate Interests (e.g., maintaining and improving our Services, ensuring security and preventing fraud, and enabling communication between Job Seekers and Employers, provided these are not overridden by your fundamental rights).

You may withdraw consent at any time by adjusting your settings or contacting support@circle.net. Withdrawal will not affect the lawfulness of processing based on consent before withdrawal.

2.8 Disclaimer: Automated Tools and Communications Limitations.  Company uses automated features, including its AI Apply functionality, to assist in creating application materials, generating resumes, answering job application questions, submitting applications, and transmitting responses to Employers. Company does not make employment decisions on your behalf. All hiring decisions are made exclusively by Employers.

Through AI Apply, Company may generate and submit job applications on your behalf using the information you provide. AI Apply may also generate responses tailored to the requirements of a particular job posting. While Company strives to represent your background and experience accurately, AI Apply outputs may contain errors, omissions, or incomplete information. You remain responsible for reviewing and confirming the accuracy and completeness of all information submitted.

Company cannot guarantee the successful generation, submission, delivery, receipt, or review of any application or communication transmitted through AI Apply. Company may also provide you with credentials or links to access an Employer’s ATS directly where available. You are encouraged to use both the Application and any direct ATS access to confirm receipt by Employers. Company is not responsible or liable for missed updates, delayed responses, or failures to transmit communications that are beyond what is reasonably within its technical and operational control, including inherent limitations of its systems and resources.

When you consent to store personal information or prior application responses for re-use in future applications (including through AI Apply), you acknowledge that such reuse may affect eligibility determinations made by Employers. Company is not responsible for any consequences, decisions, or outcomes resulting from the reuse of previously submitted information.

We implement security measures designed to protect your information from unauthorized access. Your account is protected by your account password and we urge you to take steps to keep your personal information safe by not disclosing your password and by logging out of your account after each use. We further protect your information from potential security breaches by implementing certain technological security measures including encryption, firewalls and secure socket layer technology. However, these measures do not guarantee that your information will not be accessed, disclosed, altered or destroyed by breach of such firewalls and secure server software. By using our Service, you acknowledge that you understand and agree to assume these risks.

When you apply to a job through the Application, Company transmits your Job Application and Job Profile information to the relevant Employer or its designated ATS. Once transmitted, the Employer becomes the data controller (or equivalent under applicable law) for that information. Company does not control, and is not responsible for, how Employers (or their ATS providers or service vendors) use, store, or retain your Personal Information after receipt. Employers are solely responsible for complying with their own legal and contractual obligations regarding data protection, retention, and deletion.

If you have questions about how an Employer processes your information, or if you wish to exercise privacy rights (such as access, correction, or deletion) with respect to information already transmitted, you must contact the Employer directly. Company’s obligations under this Privacy Policy apply only to Personal Information in its possession and control prior to transfer to the Employer.

Company is based in the United States. Accordingly, your Personal Information may be transferred to and processed in the U.S. or other jurisdictions whose data protection laws may not provide the same level of protection as those in your home country. Such transfers are necessary in order to provide the Services, including transmitting applications and related information to Employers, ATS, or other third-party service providers involved in the hiring process.

Where required, Company relies on appropriate safeguards to ensure adequate protection of your Personal Information, including the European Commission’s Standard Contractual Clauses (SCCs) together with the UK Addendum/IDTA, and supplementary measures consistent with applicable law. If Company certifies under the EU-U.S. Data Privacy Framework (and the UK/Swiss extensions), those commitments will also apply to covered transfers.

You may request a copy of the safeguards relied upon for international transfers by contacting us at support@circle.net.

If you are a resident of a U.S. state with comprehensive privacy laws (including California, Colorado, Connecticut, Virginia, and Utah), you may have rights to access, delete, correct, opt out of “sale” or “sharing” of data, and limit use of sensitive Personal Information.  If we deny a privacy rights request, you may appeal by contacting support@circle.net with “Appeal” in the subject line. Company does not sell or “share” (as defined under California law) the Personal Information of users aged 13–17 for targeted advertising. You may exercise your rights by contacting support@circle.net or using the controls available in the Application.

You have the right at any time to prevent us from contacting you for marketing purposes.  When we send a promotional communication to a user, the user can opt out of further promotional communications by following the unsubscribe instructions provided in each promotional e-mail. You can also indicate that you do not wish to receive marketing communications from us in the “settings” section of the Application. Please note that notwithstanding the promotional preferences you indicate by either unsubscribing or opting out in the “settings” section of the Application, we may continue to send you administrative emails including, for example, periodic updates to our Privacy Policy.

8.1 Deletion of Your Account.  If you choose to delete your account, you can do so directly through our Application settings. Go to Account settings > Privacy & Settings > Additional Settings > Deactivate Account to initiate the account deletion process. You can also request to delete your account by sending an email to support@circle.net. You may be required to verify your username or contact information to complete the deletion of your account. For minors under 18, you or your parent/guardian may also request deletion of your Account and all associated data by contacting support@circle.net.

8.2 Permanent Deletion of Your Personal Information.  You have the right to request the deletion of your account or any specific content. If you make such a request, it may take us up to 90 days to delete your information from our active systems once we begin the account deletion process or receive your content deletion request. Additionally, please note that after your information is deleted from our active systems, it may take up to another 90 days to remove it from our backups and disaster recovery systems. This means that while your information will no longer be accessible or used in our active systems, it may still exist in backup storage until the backup cycle is complete. During the deletion process, your data will be securely stored and handled in accordance with our privacy and security policies to ensure its protection until it is permanently deleted. You can request deletion through the steps below:

(a) Email Request.  To request the deletion of your personal information or specific content, please send an email to support@circle.net with the subject line 'Deletion Request'. Include your account details and specify the information or content you wish to delete.

(b) Verification.  To ensure the security of your information, we may request additional details to verify your identity before processing your deletion request. This could include verifying your registered email address, phone number, or other account-specific information.

(c) Processing.  After verifying your request, we will start the deletion process. This process may take up to 90 days to fully complete in our active systems.

(d) Backup Removal.  Please note that after your information is deleted from our active systems, it may take up to an additional 90 days to fully remove it from our backups and disaster recovery systems.

Please ensure that your deletion request is clear and provides any necessary details to facilitate the process. If you have any questions or need assistance, our support team is available to help.

As part of the Service, we may provide links to or compatibility with other websites or applications. However, we are not responsible for the privacy practices employed by those websites and/or applications, or the information or content they contain. This Privacy Policy applies solely to information collected by us through the Application and the Service. Therefore, this Privacy Policy does not apply to your use of a third party website and/or applications accessed by selecting a link on our Application or via our Service. To the extent that you access or use the Service through or on another website or application, then the privacy policy of that other website or application will apply to your access or use of that site or application. We encourage our users to read the privacy statements of other websites before proceeding to use them.

The Company reserves the right to change this policy and our User Agreement at any time.  We will notify you of significant changes to our Privacy Policy by sending a notice to the primary email address specified in your account or by placing a prominent notice on our site. Significant changes will go into effect 30 days following such notification. Non-material changes or clarifications will take effect immediately. You should periodically check the Application and this privacy page for updates.

If you have any questions regarding this Privacy Policy or the practices of this Application, please contact us by sending an email to support@circle.net or writing us at the address below:

Circle Global, Inc.
1460 Broadway, New York, NY 10036, United States