Circa Privacy Policy

1. Introduction

Welcome to Circa. This Privacy Policy describes how Circa Technologies, Inc. ("Circa," "we," "us," or "our") collects, uses, discloses, and protects personal information in connection with your use of our peer-to-peer bartering and rental platform, including our website, mobile applications, and related features (collectively, the "Services").

Our Services facilitate exchanges between users, utilizing technologies such as blockchain-based escrow and optional Internet of Things (IoT) device integrations for verification purposes.

By accessing or using our Services, you acknowledge that you have read, understood, and agree to the collection, storage, use, and disclosure of your personal information as described in this Privacy Policy and our Terms of Service.

2. Information We Collect

We collect information to provide and improve our Services. The types of information we collect depend on how you interact with us and are categorized as follows:

A. Information You Provide Directly to Us

• Account Registration Information: When you create a Circa account, we collect information such as your name, email address, phone number, password, and potentially other identifiers necessary for account setup and verification.
• Profile Information: You may choose to provide additional information for your public profile, such as a profile picture, a brief biography, your general location (e.g., city, neighborhood), and preferences.
• Listing Information: When you list an item for rent or barter, we collect details about the item, including its description, category, condition, estimated value (optional), availability, photos, and any specific terms you set.
• Transaction Information: When you propose, accept, or engage in a barter or rental transaction, we collect information related to the exchange, including the items involved, communication between users (via our platform), offer details, and transaction status updates.
• Communications with Us: We collect information when you contact Circa support, provide feedback, participate in surveys, or otherwise communicate with us.
• Payment Information (Indirect): While we utilize escrow mechanisms, direct payment processing for certain features might be handled by third-party payment processors. We typically do not directly store full credit card numbers, but may receive transaction identifiers and summary information from the processor.

B. Information We Collect Automatically When You Use the Services

• Usage Information: We collect information about your interactions with the Services, such as pages or content viewed, searches for listings, transactions initiated, features used, access times and dates, and other actions taken on the platform.
• Log Data and Device Information: We automatically collect log data and device information when you access and use the Services, even if you have not created an account or logged in. This includes details about how you've used the Services (including links clicked), IP address, access dates and times, hardware and software information (e.g., operating system, browser type), device information, device event information (e.g., crashes, system activity), unique identifiers, and cookie data.
• Transaction Metadata: We collect metadata related to transactions facilitated through our platform, including details recorded on the blockchain for escrow purposes (which may include pseudonymous identifiers, transaction details, and status) and data related to the progress and completion of rentals or barters.
• IoT Device Metadata (Optional): If you choose to integrate optional IoT devices for verification purposes (e.g., smart locks for rental access), we may collect metadata associated with those devices and their interactions relevant to a transaction, such as device status, event logs (e.g., lock/unlock times), and identifiers, as configured by you.
• Cookies and Similar Technologies: We use cookies, web beacons, pixels, and other similar technologies to operate and provide the Services, personalize your experience, understand usage patterns, and for analytics purposes. See Section 5 for more details.

C. Information We Collect from Third Parties

• Third-Party Services: If you link, connect, or log in to your Circa account with a third-party service (e.g., Google, Facebook), the third-party service may send us information such as your registration, profile information, and friend list from that service, as controlled by that service or as authorized by you via your privacy settings at that service.
• Background Information (Conditional): For certain high-value transactions or to enhance trust and safety, we might, where permitted by applicable law and with your explicit consent if required, obtain background check information or fraud warnings from third-party identity verification services.
• Other Sources: To the extent permitted by applicable law, we may receive additional information about you, such as demographic data or information to help detect fraud and safety issues, from third-party service providers and/or partners, and combine it with information we have about you.

3. How We Use Your Information

We use the information we collect for various business purposes, including:

• Provide, Improve, and Develop the Services: To operate the platform, facilitate listings, enable transactions (including escrow management), process information, provide customer support, and improve user experience.
• Maintain a Trusted and Secure Environment: To detect and prevent fraud, spam, abuse, security incidents, and other harmful activity; conduct security investigations and risk assessments; verify information provided by you; comply with our legal obligations; resolve disputes; and enforce our Terms of Service and other policies.
• Personalize Content, Advertising, and Marketing (Limited): To personalize your experience based on your interactions with the platform, your search history, profile information, and preferences. We may send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your preferences (you can opt-out). Circa does not sell your personal information to third parties for their marketing purposes.
• Facilitate Communications: To enable communications between users related to transactions and to send administrative messages, updates, security alerts, and account notifications.
• Analytics and Research: To understand how users interact with our Services, monitor performance, conduct research, and develop new features and services.
• Blockchain and Escrow Operations: To manage and record transaction details within our blockchain-based escrow system, ensuring transparency and security for relevant parties.
• IoT Integration (Optional): To facilitate verification or access related to transactions if you have opted to use integrated IoT devices.

4. How We Share Your Information

We are committed to maintaining your trust, and we want you to understand when and with whom we may share the information we collect.

We do not sell your personal information to third parties.

We may share your information in the following circumstances:

• Sharing Between Users: To help facilitate transactions and interactions, we may need to share certain information with other users. For example:
  • When you initiate a barter or rental request, certain information like your profile name, profile picture (if provided), and request details may be shared with the item owner.
  • When a transaction is confirmed, additional information like communication methods (if enabled by users) or specific location details (if relevant and agreed upon for pickup/dropoff) may be shared between the parties involved.
  • Information you share publicly on your profile or in listings is, by definition, visible to others.
• Service Providers: We share information with third-party vendors and service providers who perform services on our behalf, such as cloud hosting, database management, analytics, customer support platforms, communication tools, security monitoring, and potentially identity verification or payment processing (under strict confidentiality agreements). These providers only have access to the information necessary to perform their functions and are obligated to protect the information.
• Compliance with Law, Responding to Legal Requests, Preventing Harm, and Protection of Our Rights: We may disclose your information to courts, law enforcement, governmental authorities, tax authorities, or authorized third parties, if and to the extent we are required or permitted to do so by law or if such disclosure is reasonably necessary: (i) to comply with our legal obligations, (ii) to comply with a valid legal process or governmental request, (iii) to enforce our Terms of Service or other policies, (iv) to respond to claims asserted against Circa, (v) to protect the rights, property or personal safety of Circa, its employees, its users, or members of the public, or (vi) in connection with security investigations or fraud prevention activities.
• Business Transfers: If Circa undertakes or is involved in any merger, acquisition, reorganization, sale of assets, bankruptcy, or insolvency event, then we may sell, transfer or share some or all of our assets, including your information in connection with such transaction or in contemplation of such transaction (e.g., due diligence). We will notify you before your personal information is transferred and becomes subject to a different privacy policy.
• Aggregated Data: We may also share aggregated information (information about our users that we combine together so that it no longer identifies or references an individual user) and other anonymized information for regulatory compliance, industry and market analysis, research, demographic profiling, marketing and advertising, and other business purposes.

5. Cookies and Similar Technologies

We use cookies, web beacons, log files, pixels, and similar technologies to collect information about the pages you view, the links you click, and other actions you take when using our Services.

Cookies are small text files stored on your device. We may use both session cookies (which expire after you close your browser) and persistent cookies (which stay on your device until you delete them or they expire).

We use these technologies to:

• Keep you signed in.
• Understand how you use the Services.
• Personalize your experience (e.g., remember preferences).
• Measure the effectiveness of features or communications.
• Provide essential security features.
• Gather analytics data on usage and performance.

You can typically control cookies through your browser settings. However, disabling certain cookies may affect the functionality of the Services.

6. Your Privacy Rights and Choices

You have certain rights and choices regarding your personal information. Depending on your location and applicable law, these may include the right to:

• Access Your Information: Request access to the personal information we hold about you and receive a copy of it.
• Rectify Your Information: Request correction of inaccurate or incomplete personal information we hold about you. You can often update profile and account information directly through your account settings.
• Delete Your Information: Request the deletion of your personal information, subject to certain exceptions (e.g., legal obligations, fraud prevention).
• Restrict or Object to Processing: Request that we restrict or stop processing your personal information in certain circumstances (e.g., for direct marketing).
• Data Portability: Request a copy of certain personal information in a machine-readable format.
• Withdraw Consent: Withdraw your consent at any time where we rely on consent as the legal basis for processing your information. This will not affect the lawfulness of processing based on consent before its withdrawal.
• Manage Communication Preferences: Opt-out of receiving promotional communications from us by using the unsubscribe link within each email or by updating your account settings. You may still receive essential transactional or administrative messages related to your account or the Services.

To exercise these rights, please manage your account settings or contact us using the information provided in Section 12. We will respond to your request consistent with applicable law and may need to verify your identity before fulfilling certain requests.

7. Data Security

We are continuously implementing and updating administrative, technical, and physical security measures to help protect your information against unauthorized access, loss, destruction, or alteration. Some of the safeguards we use include firewalls, data encryption, and information access controls.

While we strive to protect your personal information, no security system is impenetrable. We cannot guarantee the absolute security of your data transmission or storage, and we cannot guarantee that information will not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.

It is also important for you to protect against unauthorized access to your password and to your computer or device. Be sure to sign off when finished using a shared computer.

8. Data Retention

We generally retain your personal information for as long as is necessary for the performance of the contract between you and us (e.g., maintaining your account) and to comply with our legal obligations. The criteria used to determine our retention periods include:

• The length of time we have an ongoing relationship with you and provide the Services to you.
• Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them).
• Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

If you request the deletion of your account, we will generally delete your personal information, except we may retain certain information as necessary for our legitimate business interests, such as fraud detection and prevention, safety enhancement, compliance with legal obligations, and dispute resolution.

9. Children's Privacy

The Services are not intended for or directed to individuals under the age of 13 (or other age as required by local law). We do not knowingly collect personal information directly from children. If we become aware that we have collected personal information from a child without verification of parental consent, we will take steps to remove that information from our servers.

If you believe that we might have any information from or about a child, please contact us using the details in Section 12.

10. International Data Transfers

Circa is based in the United States. If you are accessing our Services from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States, where our servers are located and our central database is operated.

The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country. By using our Services, you consent to your information being transferred to our facilities and to the facilities of those third parties with whom we share it as described in this Privacy Policy.

11. Changes to This Privacy Policy

We reserve the right to modify this Privacy Policy at any time in accordance with this provision. If we make material changes to this Privacy Policy, we will post the revised Privacy Policy on the Services and update the "Last Updated" date at the top. We may also provide you with notice of the modification by email or through the Services before the date the changes become effective.

If you disagree with the revised Privacy Policy, you may cancel your Account. If you do not cancel your Account before the date the revised Privacy Policy becomes effective, your continued access to or use of the Services will constitute acceptance of the revised Privacy Policy.

12. Contact Us

If you have any questions, comments, or concerns about this Privacy Policy or our information practices, please contact us at:

Circa Technologies, Inc.
Attn: Privacy Officer
Email: privacy@trycirca.com