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 and/or 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 readiness to apply, the state of being open to work, and any related Personal Information used for creating candidate lists.

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

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

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

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

12. "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.

1.1 Information you provide

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

b. Information you provide us by updating your profile and Job Profile.. To use the Service after registration, you have choices about further Personal Information, which may include your location, photo, employer and/or business information. You also have choices about the information on your Job Profile, such as your education, work experience, skills, photo, location and referrals. You don’t have to provide additional information on your personal profile or Job Profile; however, this information helps you to get more from our Services, including helping Employer and business opportunities find you. It’s your choice whether to include sensitive information on your profile and to make that sensitive information public. Please do not post or add personal data to your profile that you would not want to be publicly available.

c. Information you provide us through your activities while using our Service. When you use our Service, you can post or upload content, send messages, take photos and videos. We call all of the things you can do on our Service "activity." We collect your activity across our Service, such as:

• Content you create, like posts, comments, view, perform a search, share articles and/or posts

• Content you provide through our camera feature or your camera roll settings, or through our voice-enabled features.

• Messages you send and receive, including their content, subject to applicable law: We collect information about you when you send, receive, or engage with messages in connection with our Services. For example, if you get a connection request, we track whether you have acted on it and will send you reminders. We collect information from types of messages that aren’t personal, which include messages to and from business accounts, messages exchanged with us when using our Service through our AI agent, and messages in features designed to be more public, like Job/Business messages. We may use automatic scanning technology on messages to support and protect our Application and disclose them in connection with investigations related to use of the Service, as well as our efforts to improve the Service.

• Information that is included in the input, file uploads, or feedback that you provide to our AI agent Service.

• Types of content, including ads, you view or interact with, and how you interact with it

• Features you use on our Application, and what actions you take in them.

• Social media information: When you interact with our social media pages or upload your social media information to your profile, we will collect Personal Information that you elect to provide to us, such as your contact details. In addition, the companies that host our social media pages may provide us with aggregate information and analytics about our social media activity.

• Purchases or other transactions you make, including credit card information.

• The time, frequency and duration of your activities on our Service

d. Information you provide us by interacting with other users.. We collect information about connections, followers, groups, accounts, other users and communities you’re connected to and interact with. This includes how you interact with them across our Services and which ones you interact with the most. We also collect information about you based on others' activity, when others share or comment on a photo you’re tagged in, send you a message, invite you to join a conversation or community. We also infer things about you based on others' activity. For example, we may suggest a connection to you or we take into account whether your friends belong to a group when we suggest you join it.

e. Information you provide us for Job Application and Job Posting.. When you use our Service, you may provide additional Personal Information. This includes, but is not limited to, Personal Information provided through Job Application, and Job Posting. For example, as a Job Seeker, you may submit your Resume, job preferences, and responses to screener questions. As an Employer, you may provide details about Job Posting, such as job titles, job descriptions, requirements, compensation information, and business description Employer’s business information may include verification documentation about your business, employee contact details and physical location of business (including a Federal Employer Identification Number (EIN), business registration as well as videos, pictures and other content about your business). We also collect your job application data such as your Resume and other materials shared when you apply to a job through us, your activity in relation to that application, messages that you send for Job Application and Job Posting through “Job/Business message” on our Service. This information helps facilitate the job matching process and enhances the functionality of our Service by allowing Employers to find suitable candidates and Job Seekers to find relevant job opportunities.

1.2 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.

1.3 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:

• The device and software you’re using, and other device characteristics.

• Signals from your device.

• Information you’ve shared with us through device settings, like GPS location, camera access, photos and related metadata

• Information about the network you connect your device to and your connection, including your IP address

• 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.

• Information about our Service’s performance on your device

1. 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.

1.4 Children’s Privacy.Our Application and Service are not directed to anyone under the age of 18. The Application does not knowingly collect or solicit information from anyone under the age of 18, or allow anyone under the age of 18 to sign up for the Service. In the event that we learn that we have gathered personal information from anyone under the age of 18 without the consent of a parent or guardian, we will delete that information as soon as possible. If you believe we have collected such information, please contact us at support@circle.net

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

• To provide, administer, maintain and/or analyze the Service

• To improve our Service and conduct research

• To communicate with you, including to send you information about our Service and events

• To develop new programs and services

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

• To carry out business transfers

• 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

• 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 Terms of Use, 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 Your profile is fully visible to all users of our Service. Subject to your settings, it can also be visible to others on or off of our Services (e.g., visitors to our Services or users of third-party search engines). Degree of connection with the viewing other user, the subscriptions they may have, their usage of our Services, access channels and search types (e.g., by name or by keyword) impact the availability of your profile and whether they can view certain fields in your profile.

• 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 applicant tracking system (ATS) or scheduling platform.

• c. Transfer of Information to Job Seeker.We may certain Employer-related information to Job Seeker. 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 Seeker’s 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 Retention of Personal Information. We retain personal information as long as reasonably necessary to provide the Service, carry out the purposes described in this Privacy Policy or as otherwise required in order to comply with our records retention periods (which reflect the applicable law). For example, we may retain information about users of our Services in order to comply with our legal and regulatory obligations or to protect our interests as part of providing the Service.

2.4 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.

2.5 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.

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.

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.

5.1 Deletion of your account. If you choose to delete your account, you can do so directly through our Application settings. Go to Account Settings > Additional Settings > Delete Account to initiate the account deletion process. You will be required to verify your username to complete the deletion of your account.

5.2. 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'.

• 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.

Our app is designed for users aged 17 and older and is not intended for children under 13. We do not knowingly collect, store, or process personal data from children under 13, in compliance with applicable laws such as COPPA (Children’s Online Privacy Protection Act). If we become aware that we have inadvertently collected personal information from a child under 13, we will take immediate steps to delete such data. Parents or guardians who believe their child may have provided personal information without consent can contact us at support@circle.net to request its removal. Additionally, our app does not feature child-directed content, nor do we use age-inappropriate advertising or tracking mechanisms targeted at minors.

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.