CIRCLEBUDGET PRIVACY POLICY
Last Modified: July 9, 2024

1. Introduction
Circle Personal Finance Solutions LLC (“CircleBudget”) is dedicated to protecting your personal information and informing you about how we use your information. This Privacy Policy applies to your use of CircleBudget Platform (as defined in the CircleBudget Terms of Service). Any capitalized words undefined in this Privacy Policy shall have the meanings as stated within the CircleBudget Terms of Service and this Privacy Policy is subject to the CircleBudget Terms of Service. Please review this Privacy Policy periodically as we may revise it from time to time. If you do not agree with or accept our Privacy Policy in its entirety, you must not access or use the Platform. If you use the Platform following a change to the terms of this Privacy Policy you agree to accept the revised policies.

2. Information Collected
At CircleBudget, we collect personally identifiable information (“PII”) and non-personally identifiable (“Non-PII”) information from you. Personally identifiable information is information that can be used to identify you personally. Non-personally identifiable information is information that must be combined with other information to identify you personally.

Personally Identifiable Information Collected
In order to fully use our Platform, we may collect user PII including but not limited to your name, email, password, login information, financial, banking, and investment information, and payment and billing information. Please be aware that PII related to billing and payment shall be collected and stored by our third party payment processors and shall be subject to their data retention policies.

Non-Identifying Information
Whenever you use our Platform, we may collect Non-PII from you, such as non-identifying personal documents and financial information, your IP address, and registration history, interactions with the Platform, usage information, location, referring URL, browser, operating system, data usage, data transferred, and Internet service provider. We may also collect information including but not limited to postings you make on the public areas of our website, messages you send to us, and correspondence we receive.

4. Accessing and Editing Your Information
If you have any questions regarding any PII collected by us, please contact us at support@circlebudget.com. Please be aware that we may keep inaccessible copies of your PII and non-PII subject to our data retention policies.

5. Removal Requests
If you wish to have any of your PII stored within the CircleBudget Platform modified or removed, please contact us. We will review your request upon our receipt of such request. Please be aware that where required by law or for liability purposes we may retain copies of your PII even after we process a removal request from you.

6. Cookies and Tracking
Cookies may be required in order for our Platform to function properly. We may use cookies to remember you, to understand how you use our Platform, and to track your preferences and purchases. If you disable cookies from your web browser some portions of our Platform may not work.

7. Third Party Access to Your Information
Although you are entering into an Agreement with CircleBudget to disclose your information to us, we do use third party individuals and organizations to assist us, including contractors, web hosts, Third Party Websites and others to allow you to access the Platform.

Throughout the course of our provision of our services to you, we may delegate our authority to collect, access, use, and disseminate your information. It is therefore necessary that you grant the third parties we may use in the course of our business the same rights that you afford us under this Privacy Policy. For this reason, you hereby agree that for every authorization which you grant to us in this Privacy Policy, you also grant to any third party that we may hire, contract, or otherwise retain the services of for the purpose of operating, maintaining, repairing, or otherwise improving or preserving our Platform.

8. Law Enforcement
You agree that we may disclose your information to authorities if compelled to by a court order. Additionally, you agree that we may disclose your information if we reasonably believe that you have violated United States laws, the terms of our Terms of Service or our Privacy Policy, or if we believe that a third party is at risk of bodily or economic harm. In the event that we receive a subpoena affecting your privacy, we may elect to notify you to give you an opportunity to file a motion to quash the subpoena, or we may attempt to quash it ourselves, but we are not obligated to do either. We may also proactively report you and release your information without receiving any request to third parties where we believe that it is proper to do so for legal reasons, where your actions violate any law of the United States or any other country having jurisdiction over us, our Platform, or our Terms of Service. You release us from any damages that may arise from or relate to the release of your information to a request from law enforcement agencies or private litigants. We may release your information under the conditions listed in this paragraph whether it is to individuals or entities and to any state or federal authorities, as required.

9. Opt Out of Commercial, Non-Commercial Communications and Do Not Track
If you decide to provide us with your contact information, you agree that we may send you communications via text and emails. However, you may unsubscribe from certain communications by notifying CircleBudget that you no longer wish to receive these communications. Where we have received such a notification, we will endeavour to promptly remove you from our contact lists. We currently do not offer functionality for you to opt out through “do not track” listings. If you wish to opt out of certain communications or information collection, please contact us at support@circlebudget.com.

10. Third Parties
CircleBudget may allow connections through APIs or may post links to Third Party Websites on Platform, which may include information that we have no control over. When accessing Third Party Websites through our Platform, you acknowledge that you are aware that these Third Party Websites are not screened for privacy or security issues by us, and you release us from any liability for the conduct of these Third Party Websites and any information or PII transferred between us and these Third Party Websites.

Please be aware that this Privacy Policy and any other policies in place, in addition to any amendments, do not create rights enforceable by third parties. CircleBudget bears no responsibility for the information collected or used by Third Party Websites. You must review their relevant agreements to understand how their information collection practices work.

11. Security Measures
We make reasonable attempts to protect your information, including usage of encryption of your User Content and PII in transit and at rest. Please be aware that although we use encryption we can make no guarantees as to the security or privacy of your information. For this reason, we recommend that you use anti-virus software, routine credit checks, firewalls, and other precautions to protect yourself from security and privacy threats.

12. Your California Privacy Rights
CircleBudget permits residents of the state of California to use its Platform, and complies with the California Business and Professions Code §§ 22575-22579. If you are a California resident you may request certain information regarding our disclosure of personal information. Various provisions throughout this Privacy Policy address requirements of the Californian privacy statutes. Although we do not disseminate your information to third parties without permission, you must presume that we collect electronic information from all visitors. You may contact us at support@circlebudget.com with any questions.

13. Age Compliance
We intend to fully comply with United States and international laws respecting children's privacy. Therefore, we do not collect or process any information for any persons under the age of 18. If you are under 18 and using our Platform, please stop immediately and do not submit any information to us. In the event that we have inadvertently collected any information from users under the age of 18 please contact us immediately.

14. International Transfer
Your information may be transferred to - and maintained on - computers located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer. PII and Non-PII that are submitted to CircleBudget will be collected, processed, stored, disclosed and disposed of in accordance with applicable U.S. law and this policy.

15. Merger and Acquisition
In the event that CircleBudget is involved in a bankruptcy, merger, acquisition, reorganization or sale of assets, your information may be sold or transferred as part of that transaction. Please be aware that once the information is transferred your privacy rights may change.

16. Amendments
Like our Terms of Service, we may amend this Privacy Policy from time to time. When we amend this Privacy Policy, we will modify the date listed on this Agreement or we may contact you. You must agree to the amendments as a condition of your continued use of our Platform. If you do not agree, you must immediately cease using our Platform and notify us of your refusal to agree by e-mailing us at support@circlebudget.com.