Last updated: June 28, 2025

Welcome to Cirqle. This Privacy Policy applies to Cirqle services, which include Cirqle apps, websites, software and related services (the “Platform”). The Platform is provided and controlled by CIRQLE (PRIVATE LIMITED) (UEN Number 202507094Z), a company incorporated in Singapore with its registered office at 22 SIN MING LANE #06-76, MIDVIEW CITY, Singapore 573969. (“Cirqle”, “we” or “us”).

We are committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, share, and otherwise process the personal information of users, and other individuals. If you do not agree with this policy, you should not use the Platform.

What Information We Collect

We may collect information from and about you, including information that you provide, information from other sources, and automatically collected information.

Information You Provide

When you create an account, upload content, contact us directly, or otherwise use the Platform, you may provide some or all of the following information:

Account and profile information, such as name, age, username, password, language, email, phone number, social media account information, and profile image.
User-generated content, including comments, photographs, livestreams, audio recordings, videos, text, hashtags, and virtual item videos that you choose to create with or upload to the Platform (“User Content”) and the associated metadata, such as when, where, and by whom the content was created. Even if you are not a user, information about you may appear in User Content created or published by users on the Platform. When you create User Content, we may upload or import it to the Platform before you save or post the User Content (also known as pre-uploading), for example, in order to recommend audio options, generate captions, and provide other personalized recommendations. If you apply an effect to your User Content, we may collect a version of your User Content that does not include the effect.
Messages, which include information you provide when you compose, send, or receive messages through the Platform’s messaging functionalities. They include messages you send through our chat functionality when communicating with sellers who sell goods to you, and your use of virtual assistants when purchasing items through the Platform. That information includes the content of the message and information about the message, such as when it was sent, received, or read, and message participants. Please be aware that messages you choose to send to other users of the Platform will be accessible by those users and that we are not responsible for the manner in which those users use or share the messages.
Information, including text, images, and videos, found in your device’s clipboard, with your permission. For example, if you choose to initiate information sharing with a third-party platform, or choose to paste content from the clipboard onto the Platform, we access this information stored in your clipboard in order to fulfill your request.
Purchase information, including payment card numbers or other third-party payment information (such as PayPal) where required for the purpose of payment, and billing and shipping address. We also collect information that is required for extended warranty purposes and your transaction and purchase history on or through the Platform.
Your phone and social network contacts, with your permission. If you choose to find other users through your phone contacts, we will access and collect information such as names, phone numbers, and email addresses, and match that information against existing users of the Platform. If you choose to find other users through your social network contacts, we will collect your public profile information as well as names and profiles of your social network contacts.
Your choices and communication preferences.
Information to verify an account such as proof of identity or age.
Information in correspondence you send to us, including when you contact us for support.
Information you share through surveys or your participation in challenges, research, promotions, marketing campaigns, events, or contests such as your gender, age, likeness, and preferences.

Information From Other Sources

We may receive the information described in this Privacy Policy from other sources, such as:

If you choose to sign-up or log-in to the Platform using a third-party service such as Facebook, Twitter, Instagram, or Google, or link your Cirqle account to a third-party service, we may collect information from the service–for example, your public profile information (such as nickname), email, and contact list.
Advertisers, measurement and other partners share information with us about you and the actions you have taken outside of the Platform, such as your activities on other websites and apps or in stores, including the products or services you purchased, online or in person. These partners also share information with us, such as mobile identifiers for advertising, hashed email addresses and phone numbers, and cookie identifiers, which we use to help match you and your actions outside of the Platform with your Cirqle account. Some of our advertisers and other partners enable us to collect similar information directly from their websites or apps by integrating our Cirqle Advertiser Tools (such as Cirqle Pixel).
We may obtain information about you from certain affiliated entities within our corporate group, including about your activities on their platform.
We may receive information about you from others, including where you are included or mentioned in User Content, direct messages, in a complaint, appeal, request or feedback submitted to us, or if your contact information is provided to us.
We may also collect or receive information about you from organizations, businesses, people, and others, including, for example, publicly available sources, government authorities, professional organizations, and charity groups.

Automatically Collected Information

We automatically collect certain information from you when you use the Platform, including internet or other network activity information such as your IP address, geolocation-related data, unique device identifiers, browsing and search history (including content you have viewed in the Platform), and Cookies.

Usage Information. We collect information regarding your use of the Platform and any other User Content that you generate through or upload to our Platform.
Device Information. We collect certain information about the device you use to access the Platform, such as your IP address, user agent, mobile carrier, time zone settings, identifiers for advertising purposes, model of your device, the device system, network type, device IDs, your screen resolution and operating system, app and file names and types, keystroke patterns or rhythms, battery state, audio settings and connected audio devices. We automatically assign you a device ID and user ID. Where you log-in from multiple devices, we will be able to use information such as your device ID and user ID to identify your activity across devices. We may also associate you with information collected from devices other than those you use to log-in to the Platform.
Location Data. We collect information about your approximate location, including location information based on your SIM card and/or IP address. In addition, we collect location information (such as tourist attractions, shops, or other points of interest) if you choose to add the location information to your User Content. We may collect precise or approximate GPS information about your devices. By continuing to use the platform, it constitutes your irrevocable consent and agreement to the above.
Image and Audio Information. We may collect information about the videos, images and audio that are a part of your User Content, such as identifying the objects and scenery that appear, the existence and location within an image of face and body features and attributes, the nature of the audio, and the text of the words spoken in your User Content. We may collect this information to enable special video effects, for content moderation, for demographic classification, for content and ad recommendations, and for other non-personally-identifying operations. We may collect biometric identifiers and biometric information as defined under Singapore laws, such as faceprints and voiceprints, from your User Content. Where required by law, we will seek any required permissions from you prior to any such collection.
Metadata. When you upload or create User Content, you automatically upload certain metadata that is connected to the User Content. Metadata describes other data and provides information about your User Content that will not always be evident to the viewer. For example, in connection with your User Content the metadata can describe how, when, where, and by whom the piece of User Content was created, collected, or modified and how that content is formatted. It also includes information, such as your account name, that enables other users to trace back the User Content to your user account. Additionally, metadata includes data that you choose to provide with your User Content, e.g., any hashtags used to mark keywords to the video and captions.
Cookies. We and our service providers and business partners use cookies and other similar technologies (e.g., web beacons, flash cookies, etc.) (“Cookies”) to automatically collect information, measure and analyze how you use the Platform, including which pages you view most often and how you interact with content, enhance your experience using the Platform, improve the Platform, provide you with advertising, and measure the effectiveness of advertisements and other content. We and our partners also use Cookies to promote the Platform on other platforms and websites. Cookies enable the Platform to provide certain features and functionality. Web beacons are very small images or small pieces of data embedded in images, also known as “pixel tags” or “clear GIFs,” that can recognize Cookies, the time and date a page is viewed, a description of the page where the pixel tag is placed, and similar information from your computer or device. To learn how to disable certain Cookies, see the “Your Choices” section below.

We may link your contact or account information with your activity on and off our Platform across all your devices, using your email or other log-in or device information. We may use this information to display advertisements on our Platform tailored to your interests, preferences, and characteristics.

We are not responsible for the privacy practices of our service providers and business partners, and the information practices of these service providers and business partners are not covered by this Privacy Policy.

We may aggregate or de-identify the information described above. Aggregated or de-identified data is not subject to this Privacy Policy.

How We Use Your Information

As explained below, we use your information to improve, support and administer the Platform, to allow you to use its functionalities, and to fulfill and enforce our Terms of Service. We may also use your information to, among other things, show you suggestions, promote the Platform, and customize your ad experience.

We generally use the Information We Collect:

To fulfill requests for products, services, Platform functionality, support and information for internal operations, including troubleshooting, data analysis, testing, research, statistical, and survey purposes and to solicit your feedback.
To customize the content you see when you use the Platform. For example, we may provide you with services based on the country settings you have chosen or show you content that is similar to content that you have liked or interacted with.
To send promotional materials from us or on behalf of our affiliates and trusted third parties.
To improve and develop our Platform and conduct product development.
To measure and understand the effectiveness of the advertisements we serve to you and others and to deliver advertising, including targeted advertising, to you on the Platform.
To make suggestions and provide a customized ad experience.
To support the social functions of the Platform, including to permit you and others to connect with each other (for example, through our Find Friends function), to suggest accounts to you and others, and for you and others to share, download, and otherwise interact with User Content posted through the Platform.
To use User Content as part of our advertising and marketing campaigns to promote the Platform.
To understand how you use the Platform, including across your devices.
To infer additional information about you, such as your age, gender, and interests.
To help us detect abuse, fraud, and illegal activity on the Platform.
To promote the safety and security of the Platform, including by scanning, analyzing, and reviewing User Content, messages and associated metadata for violations of our Terms of Service, Community Guidelines, or other conditions and policies.
To verify your identity in order to use certain features, such as livestream or verified accounts, to ensure that you are old enough to use the Platform (as required by law), or in other instances where verification may be required.
To communicate with you, including to notify you about changes in our services.
To announce you as a winner of our contests or promotions if permitted by the promotion rule, and to send you any applicable prizes.
To enforce our Terms of Service, Community Guidelines, and other conditions and policies.
Consistent with your permissions, to provide you with location-based services, such as advertising and other personalized content.
To train and improve our technology, such as our machine learning models and algorithms.
To combine all the Information We Collect or receive about you for any of the foregoing purposes.
To facilitate sales, promotion, and purchases of goods and services and to provide user support.
For any other purposes disclosed to you at the time we collect your information or pursuant to your consent.

develop, provide, operate and improve our Services and our business;
establish, maintain and service your user profile for our Services;
verify or maintain the quality or safety of the Services;
conduct Know Your Customer checks and other screens permitted by law when you set up an account;
facilitate invitations to friends who you want to invite to join our Services;
enable security features of our Services, such as (for example) by sending you security codes via email or SMS, and remembering devices from which you have previously logged in;
communicate with you about our Services, including by sending announcements, updates, security alerts, and support and administrative messages;
understand your needs and interests, and personalize your experience with our Services and our communications;
enable communication with other Service users; and
provide support for our Services, and contact you where requested or respond to your requests, questions and feedback.

Research and development. We may use your personal data for research and development purposes, including to analyze and improve our Services and our business. As part of these activities, we may create aggregated, de-identified or anonymous data from personal data we collect. We make personal data into anonymous data by removing data that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve our Services and promote our business.

Marketing and advertising. We may collect and use your personal data for marketing and advertising purposes:

Direct marketing. We may send you direct marketing communications about our products, services or promotions that may be of interest to you. Our processing of your personal data for marketing purposes is based on our legitimate interest, or on your consent, or as otherwise permitted by applicable laws. You have the right to prevent direct marketing of any form at any time, this right can be exercised by following the opt-out link attached to each communication or by sending an email to help@cirqle.com.
Interest-based advertising. We may engage third-party advertising companies and social media companies to display ads on other online services. These companies may use cookies and similar technologies to collect information about your interaction (including the data described in the automatic data collection section above) over time across our Services, our communications and other online services, and use that information to serve online ads that they think will interest you. This is called interest-based advertising. We may also share information about our users with these companies to facilitate interest-based advertising to those or similar users on other online platforms. You can learn more about your choices for limiting interest-based advertising in the Advertising choices section below.

Compliance and protection. We may use your personal data to:

comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;
protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
audit our internal processes for compliance with legal and contractual requirements or our internal policies;
maintain appropriate business records;
enforce the terms and conditions that govern our Services;
and prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

With your consent. In some cases, we may specifically ask for your consent to collect, use or share your personal data, such as when required by law.

To create aggregated, de-identified and/or anonymized data. We may create aggregated, de-identified and/or anonymized data from your personal data and other individuals whose personal data we collect. We make personal data into de-identified and/or anonymized data by removing information that makes the data identifiable to you. We may use this aggregated, de-identified and/or anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve our Services, promote our business or marketing purposes.

Profiling: We do not engage in profiling which results in legal or similarly significant effects, as defined under applicable law.

How We Share Your Information

We may share your personal data with third parties as detailed below and as otherwise described in this Privacy Policy.

Affiliates. We may share your personal data with our corporate parent, subsidiaries, and affiliates, for purposes consistent with this Privacy Policy.
Service providers. We share personal data with those third parties who provide services on our behalf or help us operate our Services or our business (such as hosting, information technology, customer support, email delivery, marketing, and website analytics).
Payment processors and fraud detection service providers. We share personal data with payment processors and fraud detection service providers for the purposes of facilitating payments done via the Services and securing the Services and protecting it against fraud, unauthorized transactions (such as money laundering), claims or other liabilities.
Advertising partners. We may share your personal data with third-party advertising companies for the interest-based advertising purposes described above.
Creators. As a Creator, we may publicly identify you as a Creator with Cirqle, including in connection with our marketing and promotional materials. In addition, we may publicly share information related to your use and activity of the Services (including earnings, audience and viewership metrics, and other similar analytics);
Third-party platforms and social media networks. Our Services may contain certain social media features, such as sharing content from Cirqle to external social media networks. If you have enabled features or functionality that connect our Services to a third-party platform or social media network (such as by linking your account to a third party’s services), we may disclose the personal data that you authorized us to share. We do not control the third party’s use of your personal data and such third party’s use will be in accordance with such party’s privacy policy.
Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.
Government Agencies and regulators. We may share personal data with law enforcement agencies, public authorities or other parties: (i) in order to respond to a subpoena or court order, judicial process or to regulatory authorities, if we believe we are required to do so by law, or that doing so is reasonably necessary to comply with legal processes; (ii) when we believe it necessary or appropriate to disclose personal data to law enforcement authorities, such as to investigate actual or suspected fraud or violations of law, breaches of security, or breaches of this Privacy Policy; (iii) to respond to claims against us; and (iv) to protect the rights, property, or personal safety of Cirqle, our customers or the public.
In the context of a corporate transaction. Personal data may be disclosed if we go through a business transition such as a merger, sale, transfer of all or a portion of Cirqle’ assets, acquisition, bankruptcy or similar event. In the event that we sell any business or assets, we will disclose your data to the prospective buyer. If all, or substantially all, of our assets are acquired by a third party, data held by us about our users will be one of the transferred assets.
Other users. Your personal data, such as your profile information and user-generated content and your email address may be visible to other users of our Services. For example, other users may have access to your profile or content through the course of your use of our Services. In addition, as a Fan, your email and other personal data that you have provided to Cirqle may be shared with each Creator to whom you subscribe. Where your personal data can be seen, collected and used by others, including being cached, copied, screen captured or stored elsewhere by others (e.g., search engines), we are not responsible for any such use of data.

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will update the date of this Privacy Policy and post it on our Website and/or App, but we will not be required to individually notify you. It is the users’ responsibility to periodically check whether there are any updates to the privacy policy. If the user continues using the app after any changes to the privacy policy, it shall be considered as irrevocable acceptance to the latest privacy policy. If required by law we will also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via email. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). We recommend that you check this Privacy Policy periodically for any updates or changes.

Your Rights

You may submit a request to know, access, correct or delete the information we have collected from or about you at https://www.tiktok.com/legal/report/privacy. You may appeal any decision we have made about your request by following the instructions in the communication you receive from us notifying you of our decision. You may also exercise your rights to know, access, correct, delete, or appeal by sending your request to the physical address provided in the “Contact Us” section below. You can also update your account information directly through your in-app settings, as well as request a copy of your TikTok data or request to deactivate by following the instructions here or delete your account by following the instructions here.

You may be entitled, in accordance with applicable law, to submit a request through an authorized agent. To designate an authorized agent to exercise choices on your behalf, please provide evidence that you have given such agent power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf. We will respond to your request consistent with applicable law and subject to proper verification. We will verify your request by asking you to send it from the email address associated with your account or to provide information necessary to verify your account.

More information about requests that we received can be found here.

While some of the information that we collect, use, and disclose may constitute sensitive personal information under applicable state privacy laws, such as information from users under the relevant age threshold, information you disclose in survey responses or in your User Content about your racial or ethnic origin, national origin, religious beliefs, mental or physical health diagnosis, sexual life or sexual orientation, status as transgender or nonbinary, citizenship or immigration status, or financial information, we only process such information in order to provide the Platform and within other exemptions under applicable law. For example, we may process your financial information in order to provide you the goods or services you request from us or your driver’s license number in order to verify your identity.

Your Choices

You may be able to control some of the Information We Collect through your device browser settings to refuse or disable Cookies. Because each browser is different, please consult the instructions provided by your browser. Please note that you may need to take additional steps to refuse or disable certain types of Cookies. In addition, your choice to disable Cookies is specific to the particular browser or device that you are using when you disable Cookies, so you may need to separately disable Cookies for each type of browser or device. If you choose to refuse, disable, or delete Cookies, some of the functionality of the Platform may no longer be available to you. Without this information, we are not able to provide you with all of the requested services.
You can navigate to "Ads" in your in-app settings to opt-out of targeted advertising based on personal information about your activity on nonaffiliated apps and websites.
You may be able to manage third-party advertising preferences for some of the third parties we work with to serve advertising across the Internet by using the choices available at https://www.networkadvertising.org/managing/opt_out.asp and https://www.aboutads.info/choices.
Your device may have controls that determine what Information We Collect. For example, you can control whether we can collect your mobile advertising identifier for advertising through settings on your Apple and Android devices.
You can opt out of marketing or advertising emails by using the “unsubscribe” link or mechanism noted in marketing or advertising emails.
If you have registered for an account, you may access, review, and update certain personal information that you have provided to us by logging into your account and using available features and functionalities.
Some browsers transmit “do-not-track” signals to websites. Because of differences in how browsers incorporate and activate this feature, we currently do not take action in response to these signals.

How long we keep your Personal Data

Data Security and Retention

We use reasonable measures to help protect information from loss, theft, misuse, unauthorized access, disclosure, alteration, or destruction. You should understand that no data storage system or transmission of data over the Internet or any other public network can be guaranteed to be 100 percent secure. Please note that information collected by third parties may not have the same security protections as information you submit to us, and we are not responsible for protecting the security of such information.

We retain information for as long as necessary to provide the Platform and for the other purposes set out in this Privacy Policy. We also retain information when necessary to comply with contractual and legal obligations, when we have a legitimate business interest to do so (such as improving and developing the Platform, and enhancing its safety, security and stability), and for the exercise or defense of legal claims.

The retention periods are different depending on different criteria, such as the type of information and the purposes for which we use the information. For example, when we process your information such as your profile information to provide you with the Platform, we keep this information for as long as you have an account. If you violate our Terms of Service, Community Guidelines, or other conditions or policies, we may remove your profile immediately but may keep other information about you to process the violation.

Cirqle may transmit your data to its servers or data centers internationally for storage and/or processing. Other entities with whom Cirqle may share your data as described herein may be located anywhere around the world as we may choose.

Questions, comments and requests regarding this Privacy Policy should be addressed to:

Contact us: https://www.cirqle.com/legal/report/privacy
Mailing Address: 22 SIN MING LANE #06-76, MIDVIEW CITY, Singapore 573969