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Privacy Policy

Last updated: 13 November 2026

Your information matters, and you should know exactly what we do with it. So here it is in plain English.

This policy explains what personal data CircleUp collects, why, who we share it with and what your rights are. It covers our website (circleup.space), our iOS and Android apps, our memberships, chats and events.

It applies to everyone whose data we handle: members, people on a free trial, non-members who buy a ticket or come to an event, guests, people on a waitlist, hosts, and visitors to our website.

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1. Who we are

CIRCLEUP LTD is the "controller" of your personal data, which means we decide how it is used.

  • Company number: 16142550, registered in England and Wales

  • Registered office: 2nd & 3rd Floors, Northgate House, Upper Borough Walls, Bath BA1 1RG

  • Registered with the Information Commissioner's Office: ZB890921

  • Privacy questions and requests: the contact form at circleup.space/contact-help, or hello@circleup.space

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2. What we collect

We need your name, contact details and date of birth to give you an account or a membership. The app also asks for a profile photo and your gender, where you can choose "Prefer not to say". Everything else is optional.

You give us:

  • Account details: name, email address, phone number, and how you sign in.

  • Date of birth and gender. We use your date of birth to confirm you are 18 or over and to check which cities' age ranges you are within. We ask for your gender so that we can offer Circles for women only and understand the make-up of our community. You can choose "Prefer not to say". Both are kept private and are not shown to other members.

  • Profile: photos, bio, interests, home city and anything else you choose to add. When you upload a profile photo, it is checked automatically to confirm it shows a face and is suitable. This detects that a face is present. It does not identify who you are.

  • Membership and purchases: your plan, trial, pauses, cancellations, Lifetime Membership, tickets and bookings, and the confirmations you gave at checkout. Card details are handled by our payment providers. We do not see or store your full card number.

  • Events: the plans you host, join, attend or miss.

  • Photos and videos you share in CircleUp WhatsApp groups and in Circles in the app (section 8).

  • Messages: what you send in group chats and direct messages, and who you are friends with or have blocked. We do not read chats as a matter of routine. Our team can read messages when someone makes a complaint or where there is a safety concern.

  • Contact with us: emails, forms, survey answers, feedback and waitlist sign-ups.

  • Complaints and conduct: complaints you make or that are made about you, what we found and any action we took, including a suspension or removal.

We collect automatically:

  • IP address, device and browser type, operating system, the page that referred you, and which features and pages you use.

  • Location, only if you choose to share your live location in a chat, for example on the way to a meet-up. While a share is running, the app keeps updating your location in the background so the people in that chat can see it. It stops when the share ends or you stop it.

  • Crash logs and diagnostics.

  • Your notification settings in the app, and a push token (a code from your device that lets us send notifications to it).

  • Which of our apps you use and on which days, as a record linked to your account.

  • App usage statistics that do not identify you (section 5).

We get from others:

  • Payment providers (Wix and Stripe): whether a payment succeeded, failed, was refunded or disputed.

  • Apple and Google, if you sign in with them: your name and email address, or the private relay address Apple creates if you choose "Hide My Email".

  • Other members, hosts and venues: for example who attended, or a complaint about conduct.

  • Someone who books for you or brings you as a guest: your name.

  • Travel companies that run trips for our community: who has booked and the status of their booking, so we can add you to the trip's group and support you.

  • Analytics and advertising tools on our website, if you accept those cookies (section 10).

Photos and video at events. We take photos and video at events, and members who host may share theirs with us. See section 8.

Sensitive information. We do not ask for sensitive information such as health, religion or sexual orientation. Please think before sharing it in your profile or in chats. If you tell us about an allergy or access need for an event, we use it only for that event. Complaints sometimes contain sensitive information, which we use only to handle the complaint and keep people safe.

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3. Why we use it, and our legal basis

We only use your information when we have a proper reason. This list shows each thing we do and the reason the law recognises for it.

  • Create your account, run your membership, trial, Lifetime Membership, tickets and bookings, and take payment. Legal basis: Contract with you.

  • Check you are 18 or over and within a city's age range, and offer Circles for women only. Legal basis: Contract, and our legitimate interest in running a community where people meet others at a similar stage of life.

  • Show your profile, RSVPs and messages to other members, as your privacy settings allow. Legal basis: Contract.

  • Send service messages: receipts, renewal and trial reminders, changes or cancellations to events, new messages. Legal basis: Contract, and our legitimate interest in making sure important messages arrive.

  • Answer your questions and requests. Legal basis: Contract, or legitimate interests.

  • Run day-to-day operations with the help of an AI assistant, including sorting and drafting replies to messages, organising complaints and preparing internal analysis. A person checks anything sent to you and makes every decision about you. Legal basis: Legitimate interests in running CircleUp efficiently.

  • Share your live location in a chat, when you choose to. Legal basis: Contract.

  • Check profile photos automatically. Legal basis: Legitimate interests in keeping profiles genuine.

  • Handle complaints, enforce the Code of Conduct, keep the community safe, and stop people we have removed from rejoining. Legal basis: Legitimate interests in member safety. Where a complaint involves sensitive information or an allegation of a crime, we rely on the conditions in data protection law for preventing or detecting unlawful acts and for legal claims.

  • Prevent fraud, misuse and payment disputes. Legal basis: Legitimate interests.

  • Understand and improve the app, website and events, including analytics, crash reports and surveys. Legal basis: Legitimate interests.

  • Take and use event photos and video, and use photos and videos members share in CircleUp WhatsApp groups and in Circles, in our media, marketing and advertising (section 8). Legal basis: Legitimate interests in showing what CircleUp is really like. You can object at any time.

  • Send marketing emails, texts and notifications. Legal basis: Consent, or for existing customers the "soft opt-in". You can opt out at any time.

  • Show adverts on platforms such as Meta and Google, and stop existing members being shown adverts to join (section 6). Legal basis: Legitimate interests, and consent for advertising cookies.

  • Keep tax and accounting records, and respond to lawful requests. Legal basis: Legal obligation.

Where we rely on legitimate interests, we have weighed them against your rights. You can object (section 9). We do not make decisions about you using only automated means that have a legal or similarly significant effect on you.

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4. What other people can see

  • Other members and guests can see your profile, the plans you host or are going to, and your messages in chats you share. The app's settings let you control parts of this (You > Settings > Privacy & safety).

  • Hosts can see who is coming to their plan.

  • Venues and partners may be given a guest list (usually names only) for an event you have booked. Trips are booked directly with the travel company, which has its own privacy policy.

  • CircleUp WhatsApp groups. If you join one, the other people in it can see your phone number and WhatsApp name. WhatsApp is run by Meta and its own privacy policy applies to what you share there.

  • Your date of birth, gender, email address, phone number and payment details are not shown to other members.

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5. App analytics and crash reporting

Usage statistics that do not identify you. The app records a short list of events, for example which sign-up steps are viewed and completed, whether an RSVP goes through, and how long the app takes to open. Each event carries a random identifier created on your device and the month you first used the app. It never includes your name, email address or member ID, and we do not link it to your account or use it to identify you. We do not record your screen. This is on by default because it only produces statistics about how the app as a whole is used, which UK law (the statistical purposes exception in the Privacy and Electronic Communications Regulations) allows without asking first. You can switch it off at any time in the app (You > Settings > Privacy & safety > Share app usage analytics).

Usage records. We keep a record of which of our apps each account uses and on which days, on our own systems. Our team uses it to understand how many members use the app and to support them. The switch above does not affect this record.

Crash and error reports. When the app crashes or hits an unexpected error, we send a technical report so we can keep the app working reliably. It includes the error, your phone model and operating system, the app version, the screen you were on and your account ID. It never includes your messages or anything you have typed.

Who processes this data. PostHog (usage statistics) and Sentry (crash reports), both hosted in the EU and acting only on our instructions. Our own error log and usage records are stored with Supabase. We keep all of this for up to 12 months.

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6. Who we share it with

We do not sell your personal data. We never have. We share it only with:

  • Service providers who work for us, under contract and only on our instructions:

  • Wix (website, memberships, payments, email)

  • Stripe (payments, including any pay-later option you choose at checkout)

  • Supabase (app database and storage)

  • Stream (chat)

  • Expo, Apple, Google and Firebase (app delivery, sign-in and notifications)

  • PostHog and Sentry (analytics and crash reports)

  • Google (website analytics, email and documents, profile photo checks, and venue search)

  • Resend (sending emails) and ClickSend (sending text messages)

  • Anthropic (the AI assistant our team uses)

  • Advertising platforms (Meta and Google). If you accept advertising cookies, they receive information about your visit to our website. We also give Meta a list of current members and people who left in the last 12 months (name, email address, phone number and city) so that people who have already joined are not shown adverts to join. Meta's tool scrambles ("hashes") the list before it is uploaded, and Meta may use it only to match accounts for this purpose. You can object to this at any time through the contact form at circleup.space/contact-help.

  • Venues, partners and hosts, as described in section 4.

  • Professional advisers and insurers, where needed.

  • The police, courts and regulators, where the law requires it or where it is needed to keep someone safe.

  • A buyer or successor, if CircleUp is sold, merged or restructured. Your data would stay protected by this policy.

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7. Sending data outside the UK

Some of our providers are based in, or store data in, the United States or the European Union. When your data leaves the UK we make sure it is protected, by using providers in countries the UK government has approved as having adequate protection (including the EU, and US companies certified under the UK-US data bridge), or by using the contract terms approved by the UK Information Commissioner. You can ask us for details.

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8. Photos and video

We take photos and video at events, and members who host may share theirs with us. We use them in the app, on our website and social media, and in adverts. We do this because showing real events is the best way to explain what CircleUp is.

Photos and videos shared in CircleUp groups. We also use photos and videos that members share in CircleUp WhatsApp groups and in Circles in the app, in our media, marketing and advertising, including paid adverts. Our Terms of Service give us a licence to do this. We do not use private direct messages, and we do not use a photo that appears to show someone under 18.

If you are in a photo that someone else shared, you have the same rights as the person who shared it, whether or not you are a member.

Your right to say no. If you would rather not appear, tell the person with the camera at the event, or use the contact form at circleup.space/contact-help at any time. You do not need to give a reason. Once you have told us which images, we will stop using them and remove ones already posted where we reasonably can. We cannot recall something already printed or shared by other people.

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9. Your rights

It's your information, so you stay in control. You have the right to:

  • ask for a copy of your data;

  • have inaccurate data corrected;

  • have your data deleted;

  • ask us to restrict how we use it;

  • object to us using it, including for photos and videos, advertising and anything else based on legitimate interests;

  • stop marketing at any time, using the unsubscribe link, your app settings or by emailing us;

  • receive your data in a portable format;

  • withdraw consent, where we rely on it.

To use any of these, use the contact form at circleup.space/contact-help. It is free, and we will reply within one month. We may need to check who you are first.

You can also, in the app:

  • edit your profile and privacy settings (You > Settings > Privacy & safety);

  • turn notifications on or off (You > Settings > Notifications), or stop the app sharing your notification settings with us. Your notifications keep working;

  • switch off usage statistics (You > Settings > Privacy & safety > Share app usage analytics);

  • stop sharing your location in the chat, or turn location off for CircleUp in your phone's settings;

  • delete your account (You > Settings > Delete account). If you signed in with Apple, this also revokes that sign-in.

Complaints. If you are unhappy with how we have handled your data, please tell us first. We will acknowledge your complaint within 30 days and tell you the outcome without undue delay. You also have the right to complain to the Information Commissioner's Office: ico.org.uk, 0303 123 1113.

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10. Cookies

Our website uses cookies and similar technologies.

  • Essential: needed for the site to work, such as navigation and logging in. Always on.

  • Analytics: help us understand which pages people visit (for example Google Analytics). Only with your consent.

  • Marketing: let us show relevant adverts and measure them (for example Google Ads and the Meta Pixel). Only with your consent.

The cookie banner asks for your choice on your first visit. You can change it at any time through the banner or your browser settings.

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11. How long we keep it

We keep things only as long as we need them.

  • Account, profile and messages: while you have an account. You can delete your account at any time. We review accounts with no membership and no recent activity at least once a year and delete those unused for more than 12 months.

  • If you delete your account: we delete your account, profile, RSVPs and chat messages promptly, normally within 30 days. Messages needed for an open complaint are kept with the complaint. Complaints you made or that were made about you are kept, as described below, without a link to a live account. Payment records are kept as below. Copies in backups are removed as the backups expire and are not used in the meantime.

  • Payment and tax records: 6 years after the end of the financial year, as the law requires.

  • Complaints and conduct records, including removals: up to 6 years after the matter closes, so we can deal with any later claim and stop removed members rejoining.

  • Non-members who book an event: up to 12 months after the event, plus payment records as above.

  • Notification settings: only your latest settings, deleted with your account. Delivery records for recent notifications: 90 days.

  • Analytics, crash reports and usage records: up to 12 months.

  • Event photos and video, and photos and videos shared in CircleUp groups: while they are useful for showing CircleUp, or until you ask us to remove you.

  • Marketing: until you opt out. We then keep only what we need to make sure we do not contact you again.

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12. Keeping it safe

We protect your data with encrypted connections, access controls that limit who in our team can see what, and regular monitoring. No system is completely secure. If a breach is likely to put you at risk, we will tell you and the Information Commissioner's Office as the law requires.

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13. Age

CircleUp is for people aged 18 or over. We do not knowingly collect data from anyone under 18. If you think we have, tell us and we will delete it.

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14. Links to other services

Our website and app link to services we do not run, such as venues' websites and social media. Their own privacy policies apply to them.

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15. If we change this policy

We may update this policy. If a change is significant, we will tell you by email or in the app before it takes effect. The date at the top shows the latest version.

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