Privacy Policy

1. Personal Data We Collect

We may collect information you provide when creating an account or using Circle, including:

• Name and username.
• Email address and phone number.
• Date of birth, gender, and city.
• Profile photo and biography.
• Interests you select.
• Activities and circles you create or join.
• Participation requests, invitations, and membership status.
• Content you publish, including discussions, photos, and experiences.
• Reports concerning users, activities, or circles.
• Support requests, complaints, and communications with us.
• Information submitted when requesting reconsideration of a moderation decision.

We may also process technical information needed to operate and protect Circle, such as device and browser information, IP addresses, usage logs, error logs, and security events, depending on the technologies used.

Where necessary, we may process information about potential violations, moderation reviews, account restrictions, suspensions, bans, content removal, and restoration decisions.

We seek to limit collection to personal data reasonably necessary for the purposes described in this policy.

2. Information Visible to Other Users

Circle is a social platform. Certain information you choose to include in your profile may be visible to other users.

This may include your name, username, profile photo, biography, city, gender, and age calculated from your date of birth.

Your phone number and full date of birth are not displayed through your public Circle profile.

Content shared in activities, circles, discussions, and experiences may be visible to users permitted to access that content through Circle's features.

Reports, complaints, and internal moderation records are not intended for public display. Access may be provided to authorized personnel and relevant service providers where necessary for legitimate purposes.

Information shared in a report may need to be reviewed or disclosed to relevant parties where necessary, appropriate, and permitted by law. We cannot guarantee anonymity in every investigation.

3. Why We Process Personal Data

We may process personal data to:

• Create, manage, and verify accounts.
• Operate Circle's social and community features.
• Enable users to discover free activities and circles.
• Manage participation, join requests, and invitations.
• Enable organizers to review participation requests.
• Provide discussions and experience sharing.
• Send service-related notifications and communications.
• Provide technical support and handle complaints.
• Receive and review reports about users, activities, and circles.
• Investigate suspected violations and protect users.
• Apply account restrictions, suspensions, bans, and content removal when appropriate.
• Review requests for reconsideration and restore access where appropriate.
• Maintain records of moderation actions for accountability and security.
• Prevent fraud, misuse, and unauthorized access.
• Diagnose errors and improve the service.
• Comply with applicable legal obligations and binding requests from competent authorities.

Circle currently supports free activities only. It does not provide paid activity bookings, payment collection, or payment receipt submission.

4. Legal Basis for Processing

We process personal data on legal grounds permitted under applicable Saudi data protection laws, depending on the data and processing purpose.

These grounds may include consent where required, processing necessary to provide a requested service, compliance with legal obligations, or legitimate interests where permitted by law and subject to applicable safeguards.

Where processing relies on consent, you may withdraw that consent through available means, without affecting processing lawfully carried out before withdrawal.

Processing necessary to review reports, address security risks, or comply with legal obligations may continue where another lawful basis applies.

5. How We Collect Personal Data

We primarily collect information:

• Directly from you when you create or update your account.
• When you create, join, or interact with an activity or circle.
• When you send or receive invitations or participation requests.
• When you publish content or interact with other users.
• When you submit a report, complaint, or support request.
• When you request reconsideration of a moderation decision.
• From reports and relevant interactions involving your account or content.
• Automatically through technologies necessary to operate and secure the service, where applicable.

6. Sharing Personal Data

We do not sell your personal data.

We may share personal data, to the extent necessary, with service providers supporting Circle's hosting, databases, infrastructure, communications, notifications, and other technical functions.

Authorized organizers or circle administrators may access relevant participation and membership information through the features available to them. They must use this information only for legitimate purposes associated with managing the activity or circle and in accordance with applicable law.

Reports, complaints, and moderation records may be accessed by authorized personnel or providers where necessary to review issues, apply policies, protect users, or meet legal obligations.

We may disclose information when required by applicable law or a binding request from a competent authority, or where disclosure is otherwise permitted by law.

We do not disclose private personal data to another user merely because they request it.

7. Transfers Outside Saudi Arabia

Some technical services used to operate Circle may involve processing or storing personal data outside the Kingdom of Saudi Arabia.

Where personal data is transferred internationally, we will handle the transfer in accordance with applicable Saudi requirements, including relevant safeguards where required.

This may include data associated with accounts, activities, circles, reports, complaints, and moderation records.

8. Data Retention

We retain personal data for as long as reasonably necessary to fulfill the purposes for which it was collected or processed, or as required under applicable legal, security, or regulatory obligations.

Participation, membership, invitation, complaint, report, and moderation records may be retained where necessary for service administration, security, abuse prevention, legitimate disputes, and applicable legal obligations.

When the purpose for retaining personal data ends, the data will be deleted or destroyed using appropriate procedures unless a lawful reason requires or permits longer retention.

When you request deletion of your Circle account, we aim to process the request within 30 days.

Certain information may remain for a limited additional period where necessary for backups, security, handling reports or disputes, or compliance with legal obligations.

9. Protecting Personal Data

We use reasonable technical and organizational measures designed to protect personal data against unauthorized access, use, alteration, disclosure, and loss.

Depending on the service and type of information, these measures may include access controls, authorization rules, and protections for databases and technical infrastructure.

Access to complaint, report, and moderation information is intended to be restricted to authorized persons with an appropriate operational or legal need.

No electronic system or service can guarantee absolute security.

10. Your Personal Data Rights

Subject to applicable laws, regulations, and exceptions, your rights may include:

• The right to be informed about the legal basis and purpose of collecting and processing your personal data.
• The right to access your personal data.
• The right to obtain a copy of your data in a clear and readable format, subject to applicable requirements.
• The right to request correction, completion, or updating of inaccurate data.
• The right to request destruction of personal data where applicable.
• The right to withdraw consent where consent is the basis for processing.

These rights may apply to information in reports and complaints, subject to applicable exceptions and the privacy and rights of other individuals.

Some rights may be exercised through Circle's features. For other requests, please contact us. We may need to verify your identity before fulfilling certain requests.

11. Account Deletion

You can request deletion of your Circle account through:

Profile → Account → Delete Account

After confirmation, the deletion process begins in accordance with this policy and applicable legal and technical requirements.

We also provide a web-based account deletion option for users who cannot access this feature within Circle.

Deletion may not immediately remove data required by law, temporarily retained in backups, or needed for legitimate security or legal purposes.

This may include certain report, complaint, or moderation records where lawful retention grounds apply.

12. Users Under 18

Circle is intended only for individuals 18 years of age or older.

Individuals under 18 may not create an account or use Circle.

If we determine that an account was created in violation of this requirement, we may take appropriate action, including closing the account.

13. Third-Party Services

Circle may rely on services and technologies provided by third parties to operate certain features.

Personal data processed by these providers may be subject to applicable contractual and data protection requirements.

Circle may contain links to independent third-party websites or services. This policy does not govern services that we do not operate.

14. Reports, Complaints, and Moderation

Circle may process personal data submitted through reports about users, activities, or circles, as well as general complaints and support requests.

Reports may concern harassment, threats, impersonation, misleading activities, privacy violations, unsafe conduct, or other suspected policy violations.

Authorized personnel may review relevant information and record moderation actions, including content removal, restrictions, suspensions, bans, or restoration decisions.

A report does not automatically establish wrongdoing or result in a sanction.

Information may be retained where necessary to investigate misuse, review moderation decisions, protect users, or comply with applicable legal requirements.

Submitting a report through Circle does not constitute an official report to law enforcement, a government authority, or emergency services.

15. Changes to This Privacy Policy

We may update this policy as Circle evolves, features change, technical services change, or legal requirements develop.

The updated version will be published with a revised "Last updated" date.

Where a material change requires user notice or renewed consent under applicable law, we will take appropriate steps.

16. Contact and Exercise of Rights

For privacy questions, complaints about personal data processing, or requests to exercise your data rights, you may use Contact Us within Circle or the contact information below.

This includes inquiries about personal data processed in reports, complaints, and moderation records, subject to applicable legal requirements.