Privacy Policy

Introduction

This Privacy Policy describes how Anthesis IG, Inc., a Delaware corporation ("Company," "we," "us," or "our"), collects, uses, discloses, and protects your information when you use the Circle mobile application, website, and related services (collectively, the "Service" or "Circle").

Circle is a college-exclusive social platform that connects verified college students through question-based matching, direct messaging, and group activities.

By creating an account or using Circle, you consent to the collection, use, and disclosure of your information as described in this Privacy Policy. If you do not agree with our practices, please do not use the Service.

This Privacy Policy is incorporated into and subject to our Terms of Service.

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Table of Contents

1. Information We Collect
2. How We Use Your Information
3. How We Share Your Information
4. Data Retention
5. Data Security
6. Your Rights and Choices
7. Children's Privacy
8. International Data Transfers
9. Third-Party Services
10. California Privacy Rights
11. Nevada Privacy Rights
12. Other US State Privacy Rights
13. Changes to This Privacy Policy
14. Contact Us

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1. Information We Collect

We collect information in the following ways:

1.1 Information You Provide Directly

Account Information

When you create an account, we collect:

*Passwords are collected and stored by our third-party authentication provider and are never accessible to us.

Profile Information

You provide the following information during onboarding and may update some fields later:

Note on Sensitive Data: Sexual orientation and expanded gender identity information (including transgender, non-binary, intersex, and gender nonconforming options) are considered sensitive personal information. This data is collected only with your consent during onboarding and is used solely to improve matching compatibility. You may skip providing sexual orientation and gender preference during onboarding, though this will disable the date matching feature until you complete your profile.

Gender Feedback

If you feel your gender identity is not represented in our options, you may submit feedback through the app. This feedback:

• Is stored separately from your profile;
• Is reviewed by our team to improve our options;
• Does not affect your ability to use the Service.

User-Generated Content

When you use the Service, we collect:

• Question responses: Your answers to matching questions;
• Chat messages: Messages sent to matches and in outing group chats;
• Outing information: Details of outings you create (title, description, location, date, time, filters);
• Proposed questions: Questions you submit for review;
• Reports: Information you provide when reporting users, messages, or outings, including the reason for the report (e.g., harassment, spam, inappropriate content) and optional additional details;
• Crush submissions: Email addresses you submit through the crush feature (if available).

Communications

When you contact us, we collect:

• Support requests and feedback;
• Email correspondence;
• Any other information you choose to provide.

1.2 Information Collected Automatically

When you use the Service, we automatically collect:

Device and Usage Information

• Device type, model, and operating system;
• App version;
• Device identifiers (for analytics, crash reporting, and security purposes);
• Usage patterns and feature interactions;
• Crash reports and error logs;
• Date and time of access.

Authentication Information

Through our authentication provider:

• Login timestamps;
• Authentication method used;
• Session information.

1.3 Information from Third Parties

OAuth Providers

If you sign in using Google OAuth, we may receive:

• Your Google account email address;
• Your name (as set in your Google account);
• Your profile picture (we do not store this unless you explicitly upload it).

We do not receive or store your Google password or have access to other Google services.

1.4 Data Types Not Part of Our Collection Practices

The following data types are not part of Circle's current collection practices:

• Passwords: Handled exclusively by our authentication provider;
• Precise GPS location: We store text-based venue names for outings, not GPS coordinates (see Section 1.6 for IP-based approximate location);
• Contact lists: We do not request access to your phone's contacts;
• Financial information: We do not process payments or collect payment data;
• Biometric data: We do not request fingerprints, face scans, or similar identifiers;
• Health information: We do not request health or medical data;
• Government ID numbers: We do not request Social Security numbers or similar identifiers.

This list reflects our current practices and may change if we add new features. Any material changes will be reflected in updates to this Privacy Policy.

1.5 Sensitive Information

Some information you may provide is considered sensitive under various privacy laws due to the social/dating nature of Circle:

Expanded gender options: We offer expanded gender identity options including transgender, non-binary, intersex, and gender nonconforming identities. If your identity is not represented, you may submit feedback through the app for our team to review.

Consent and lawful basis: By voluntarily providing this information, you consent to our processing it as described in this Privacy Policy. Sexual orientation and gender preference are optional—you can skip them during onboarding, though this will disable the date matching feature until you complete your profile.

Your rights: You may update or remove sensitive information at any time through your profile settings. You may also request deletion of this information by contacting us at privacy@oncircle.app.

1.6 Approximate Location from IP Address

When you access Circle, we may automatically collect your approximate location (city or region level) derived from your IP address. This is used for:

• Security and fraud prevention;
• Understanding general geographic usage patterns;
• Compliance with regional legal requirements.

We do not collect precise GPS coordinates or track your real-time location. The outing feature stores only the venue name you enter as text, not geographic coordinates.

1.7 Information You Provide About Others

Circle includes features where you may provide information about other people:

Crush Submissions

When you submit a crush, you provide the email address of another person. We use this information solely to:

• Check if that person is a Circle user;
• Determine if there is a mutual crush (both parties submitted each other);
• Notify both parties only if a mutual match occurs.

Notify a Friend

When you use the "Notify a Friend" safety feature, you provide a friend's email address. We use this information solely to:

• Send a single email containing outing details for your safety.

Rights for Non-Users

If you are a non-user whose email address was submitted through these features:

• Crush submissions: We do not contact you unless a mutual match occurs between two Circle users. Your email is automatically deleted after 6 months if no match occurs.
• Notify a Friend: You receive only the single safety notification. Your email is not stored.
• Opt-out/deletion: You may request deletion of your information by contacting privacy@oncircle.app.

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2. How We Use Your Information

We use your information for the following purposes:

2.1 Providing the Service

• Account management: Creating and maintaining your account;
• Authentication: Verifying your identity and college enrollment;
• Profile display: Showing your profile to potential matches and outing participants;
• Matching: Using your question responses and preferences to suggest compatible users;
• Messaging: Facilitating communication between matched users;
• Outings: Enabling creation, discovery, and participation in group activities;
• Notifications: Sending alerts about matches, messages, outing updates, and other Service activity.

2.2 Safety and Security

• Verification: Confirming you are a current student at a supported institution;
• Fraud prevention: Detecting and preventing fraudulent or unauthorized activity;
• Content moderation: Reviewing reported content and enforcing our Terms;
• Account security: Protecting your account from unauthorized access.

2.3 Service Improvement

• Analytics: Understanding how users interact with the Service;
• Feature development: Improving existing features and developing new ones;
• Algorithm improvement: Enhancing our matching algorithm;
• Bug fixes: Identifying and resolving technical issues.

2.4 Communications

Transactional Communications

We send transactional emails that are necessary for the Service to function:

• Service updates: Notifying you of changes to the Service or policies;
• Support: Responding to your questions and requests;
• Safety alerts: Informing you of safety-related issues;
• Account notifications: Match notifications, outing updates, verification emails.

You cannot opt out of transactional communications while maintaining an active account, as they are essential to the Service.

Marketing Communications

We may send promotional communications about:

• New features and product updates;
• Tips for using Circle;
• Surveys and feedback requests;
• News about Circle and our community.

Opt-out: You can opt out of marketing communications at any time by:

• Clicking "unsubscribe" in any marketing email;
• Adjusting your notification preferences in the app;
• Contacting us at privacy@oncircle.app.

Opting out of marketing communications will not affect transactional emails related to your account or the Service.

2.5 Legal Purposes

• Compliance: Meeting legal obligations;
• Legal claims: Establishing, exercising, or defending legal claims;
• Law enforcement: Responding to lawful requests from authorities.

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3. How We Share Your Information

3.1 With Other Users

Your information is shared with other Circle users as follows:

Important Notes:

• Before joining an outing: You appear anonymously to other users (labeled "OP," "#1," "#2," etc.);
• After joining an outing: Your real name and profile picture are visible to all outing members;
• Matches: Can see your name, photo, and profile information;
• Non-matches: Cannot see your information unless you interact in an outing.

3.2 With Service Providers

We share information with third-party service providers who perform services on our behalf. These providers fall into the following categories:

Our service providers are contractually obligated to:

• Use your information only as directed by us;
• Maintain appropriate security measures;
• Not use your information for their own purposes.

3.3 With Your Consent

We may share your information with third parties when you explicitly consent, including:

• "Notify a Friend" feature: When you use this feature, outing details are sent to the email address you specify;
• Social sharing: If we add features allowing you to share content externally.

3.4 For Legal Reasons

We may disclose your information if required or permitted by law:

• Legal process: In response to subpoenas, court orders, or legal process;
• Law enforcement: To comply with requests from law enforcement or government agencies;
• Rights protection: To protect the rights, property, or safety of Circle, our users, or others;
• Fraud prevention: To detect, prevent, or address fraud, security, or technical issues;
• Emergencies: To protect against imminent harm to any person.

3.5 Business Transfers

If Anthesis IG, Inc. is involved in a merger, acquisition, bankruptcy, reorganization, or sale of assets, your information may be transferred as part of that transaction. We will notify you of any such change and any choices you may have.

3.6 Aggregated or De-Identified Data

We may share aggregated or de-identified information that cannot reasonably be used to identify you, such as:

• Total number of users at each school;
• Aggregate statistics on question responses;
• General usage trends.

3.7 Sale of Personal Information

We do not sell your personal information as defined under the California Consumer Privacy Act (CCPA) and similar state laws. We do not share your personal information for cross-context behavioral advertising.

3.8 Content Access for Safety and Legal Purposes

We may access, review, or share your content (including messages) with service providers in limited circumstances:

• To respond to user reports and investigate violations of our Terms;
• To comply with legal obligations, court orders, or law enforcement requests;
• To detect, prevent, or address fraud, security, or technical issues;
• To protect the safety of our users or others;
• With vendors who provide trust and safety, moderation, or customer support services on our behalf (under confidentiality obligations).

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4. Data Retention

We retain your information for as long as necessary to provide the Service and fulfill the purposes described in this Privacy Policy:

Clarification on matches: A "match" consists of two parts: (1) the conversation thread between matched users, which persists until account deletion, and (2) metadata such as compatibility scores used by our algorithm, which is retained for 1 year. Deleting match metadata does not affect your ability to continue conversations with existing matches.

4.1 After Account Deletion

When you delete your account:

• Your profile is immediately removed from the Service;
• Your profile picture is deleted from storage;
• Your matches will see "Deleted User" in place of your name;
• Your chat messages may remain visible to recipients;
• Your participation in outings is anonymized;
• Some anonymized or aggregated data may be retained for analytics;
• Backup copies may persist for up to 30 days.

4.2 Legal Retention

We may retain information longer if required for:

• Legal compliance;
• Resolving disputes;
• Enforcing our Terms;
• Fraud prevention.

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5. Data Security

5.1 Security Measures

We implement appropriate technical and organizational measures to protect your information:

• Encryption in transit: All data transmitted between your device and our servers is encrypted using TLS/HTTPS;
• Secure authentication: Passwords are handled exclusively by our authentication provider, using industry-standard security practices;
• Access controls: Employee access to user data is limited and logged;
• Email verification: College emails are verified through secure OTP process;
• Duplicate prevention: System prevents multiple accounts with the same college email;
• Regular updates: We regularly update our systems and dependencies.

5.2 Third-Party Security

Our service providers maintain their own security programs, which may include:

• SOC 2 compliance;
• Encryption at rest;
• Regular security audits.

5.3 Limitations

While we use commercially reasonable efforts to protect your information, no method of transmission or storage is 100% secure. We cannot guarantee absolute security of your data.

5.4 Your Responsibilities

You are responsible for:

• Maintaining the confidentiality of your login credentials;
• Using a strong, unique password;
• Logging out on shared devices;
• Notifying us immediately of any unauthorized access.

5.5 Security Incidents

If we become aware of a security breach affecting your personal information, we will:

• Notify affected users as required by applicable law;
• Take appropriate remediation steps;
• Cooperate with relevant authorities.

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6. Your Rights and Choices

6.1 Account Information

You can:

• Access your profile information through the app;
• Update your profile information at any time;
• Delete your account through the profile settings.

6.2 Communication Preferences

You can:

• Disable date matching in your profile settings;
• Leave outings you no longer wish to participate in;
• Control notifications through your device settings.

6.3 Data Access and Portability

You may request:

• A copy of the personal information we hold about you;
• Information about how we use your data.

To make a request, contact us at privacy@oncircle.app.

6.4 Data Deletion

You may request deletion of your personal information by:

• Deleting your account through the app; or
• Contacting us at privacy@oncircle.app.

Please note:

• Some information may be retained as described in Section 4;
• We may retain information if required by law.

6.5 Correction

If you believe any information we hold about you is inaccurate, you can:

• Update it directly in the app; or
• Contact us at privacy@oncircle.app.

6.6 Objection and Restriction

You may object to or request restriction of certain processing by contacting us at privacy@oncircle.app. We will consider your request in accordance with applicable law.

6.7 Response Time

We will respond to verified requests within:

• 30 days for most requests;
• 45 days if an extension is necessary (we will notify you).

6.8 Verification

To protect your privacy, we may need to verify your identity before processing requests. This may include:

• Confirming your email address;
• Asking security questions;
• Requiring additional documentation.

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7. Children's Privacy

7.1 Age Restriction

Circle is not intended for individuals under 18 years of age. We do not knowingly collect personal information from children under 18.

7.2 Parental Notice

If you are a parent or guardian and believe your child under 18 has provided us with personal information, please contact us immediately at privacy@oncircle.app. We will:

• Investigate the report;
• Delete the child's account and information;
• Take steps to prevent future access.

7.3 COPPA Compliance

While Circle is not directed to children under 13, if we learn we have collected information from a child under 13, we will delete that information in compliance with the Children's Online Privacy Protection Act (COPPA).

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8. International Data Transfers

8.1 Data Location

Circle is based in the United States. Your information is processed and stored in the United States and potentially other countries where our service providers operate.

8.2 Transfer Mechanisms

If you are located outside the United States, please be aware that:

• Your information will be transferred to and processed in the United States;
• U.S. data protection laws may differ from those in your country;
• By using Circle, you consent to this transfer.

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9. Third-Party Services

9.1 Authentication Providers

If you sign in using Google OAuth:

• Google may share your email, name, and profile picture with us;
• Your use of Google is subject to Google's Privacy Policy;
• We do not have access to your Google password.

9.2 App Stores

Circle is available through:

• Apple App Store (subject to Apple's Privacy Policy);
• Google Play Store (subject to Google's Privacy Policy).

9.3 External Links

The Service may contain links to third-party websites or services. We are not responsible for their privacy practices. We encourage you to read their privacy policies.

9.4 Analytics

We use analytics services to understand how users interact with the Service. We configure our analytics to minimize collection of personally identifiable information and to help us improve the Service and user experience. Analytics may collect device identifiers and usage events.

You can control certain analytics through your device settings.

9.5 SDKs, Cookies, and Similar Technologies

Circle uses software development kits (SDKs) and similar technologies to operate the Service:

Mobile SDKs

Our mobile app may include SDKs for:

Website Cookies

Our marketing website (oncircle.app) may use:

• Essential cookies: Required for website functionality and authentication;
• Analytics cookies: To understand website usage patterns.

We do not use:

• Advertising cookies or tracking pixels;
• Cross-site tracking technologies;
• Third-party advertising SDKs.

Device Identifiers

We collect device identifiers (such as IDFV on iOS) for analytics, crash reporting, and security purposes. We configure our analytics to minimize data collection, and we do not use advertising identifiers (IDFA/AAID) for targeted advertising.

Some of our service providers (such as our authentication provider) may collect device or network identifiers as part of their security and fraud prevention services.

Your Choices

You can control these technologies through:

• iOS: Settings > Privacy & Security > Tracking (to limit app tracking);
• Android: Settings > Privacy > Ads (to opt out of personalized ads);
• Browser: Use your browser's cookie settings or private browsing mode;
• In-app: Contact us at privacy@oncircle.app to request limitation of certain processing.

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10. California Privacy Rights

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA):

10.1 Right to Know

You have the right to request information about:

• Categories of personal information we collect;
• Purposes for which we use your information;
• Categories of third parties with whom we share your information;
• Specific pieces of personal information we have collected about you.

10.2 Right to Delete

You have the right to request deletion of your personal information, subject to certain exceptions.

10.3 Right to Correct

You have the right to request correction of inaccurate personal information.

10.4 Right to Opt-Out of Sale or Sharing

We do not sell your personal information. We do not share your personal information for cross-context behavioral advertising purposes.

10.5 Right to Non-Discrimination

We will not discriminate against you for exercising your privacy rights.

10.6 Categories of Information Collected

In the preceding 12 months, we have collected the following categories of personal information:

10.7 How to Exercise Your Rights

To exercise your California privacy rights:

• Email: privacy@oncircle.app
• In-app: Delete account through profile settings

We will verify your identity before processing your request.

10.8 Authorized Agents

You may designate an authorized agent to make requests on your behalf. The agent must provide:

• Written authorization from you; and
• Proof of their identity.

10.9 "Shine the Light" Law

California Civil Code Section 1798.83 permits California residents to request information about disclosure of personal information to third parties for their direct marketing purposes. We do not disclose personal information to third parties for their direct marketing purposes.

10.10 Do Not Track

We do not currently respond to "Do Not Track" browser signals, as there is no industry standard for this feature.

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11. Nevada Privacy Rights

If you are a Nevada resident, you have the right to opt out of the sale of certain personal information. We do not sell your personal information as defined under Nevada law. If you have questions, contact us at privacy@oncircle.app.

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12. Other US State Privacy Rights

Several other US states have enacted comprehensive privacy laws, including but not limited to Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, and others. While the specific rights vary by state, residents of these states generally have similar rights to those described in Section 10 (California Privacy Rights), including:

• Right to access your personal information;
• Right to correct inaccurate information;
• Right to delete your personal information;
• Right to data portability (receive a copy of your data);
• Right to opt-out of certain data processing activities.

Important: We do not sell your personal information or use it for targeted advertising purposes, so opt-out rights related to these activities are not applicable.

To exercise your rights under any US state privacy law, please contact us at privacy@oncircle.app. We will verify your identity and respond within the timeframes required by applicable law (typically 30-45 days).

If we decline your request, you may have the right to appeal. To appeal, contact us at privacy@oncircle.app with "Privacy Appeal" in the subject line, and we will respond within the timeframe required by your state's law.

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13. Changes to This Privacy Policy

13.1 Modifications

We may update this Privacy Policy from time to time. When we make changes:

• We will update the "Last Updated" date at the top;
• For material changes, we will notify you by email to your registered college email address or through the Service;
• Continued use of the Service after changes constitutes acceptance.

13.2 Review

We encourage you to review this Privacy Policy periodically to stay informed about our data practices.

13.3 Prior Versions

Prior versions of this Privacy Policy are available upon request.

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14. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

General Privacy Inquiries

Email: privacy@oncircle.app

Mailing Address

Anthesis IG, Inc. Attn: Privacy 251 Little Falls Drive Wilmington, DE 19808 United States

Registered Agent (for legal service)

Anthesis IG, Inc. c/o CSC 251 Little Falls Drive Wilmington, DE 19808

Response Time

We aim to respond to all inquiries within 30 days.

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Summary of Key Points

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© 2026 Anthesis IG, Inc. All rights reserved.

Circle™ is a trademark of Anthesis IG, Inc.