Privacy Policy

1. Introduction

Welcome to CircleSave. We are committed to protecting your privacy and ensuring the security of your personal information. This Privacy Policy explains how Undapp Technologies LTD ("we," "our," or "us") collects, uses, discloses, and safeguards your information when you use our platform and services.

CircleSave is operated by Undapp Technologies LTD, a company registered in England and Wales (Company No. 15112268). By using our services, you agree to the collection and use of information in accordance with this policy.

2. Information We Collect

2.1 Personal Information

We collect information that you provide directly to us, including:

• Name, email address, and contact information
• Account information
• Profile information and preferences
• Financial information necessary for transactions (processed securely through our banking partners)
• Identity verification documents (when required for compliance purposes)
• Communication preferences and correspondence

2.2 Financial Information

To facilitate savings circles and financial transactions, we collect:

• Contribution amounts and payment history
• Circle membership details and participation records
• Transaction records and payout information
• Bank account details (processed securely through our banking partners and payment processors)

2.3 Usage and Technical Information

We automatically collect certain information when you use our platform:

• Device information (browser type, operating system)
• Usage patterns and interaction data
• Cookies and similar tracking technologies

2.4 AI Risk Prediction Data

To provide our AI powered risk prediction services, we may collect and analyze:

• Historical transaction patterns
• Payment behavior and reliability indicators
• Circle participation history
• Anonymized and aggregated data for model improvement

3. How We Use Your Information

We use the collected information for the following purposes:

• Service Provision: To provide, maintain, and improve our savings circle platform
• Transaction Processing: To facilitate contributions, payouts, and financial transactions
• Risk Assessment: To analyze and predict default risks using AI technology, protecting all circle members
• Account Management: To create and manage your account, process registrations, and handle authentication
• Communication: To send you updates, notifications, reminders, and respond to your inquiries
• Compliance: To comply with legal obligations, including anti-money laundering (AML) and know-your-customer (KYC) requirements
• Security: To detect, prevent, and address fraud, security issues, and technical problems
• Analytics: To analyze usage patterns, improve our services, and develop new features
• Legal Protection: To protect our rights, property, and safety, as well as that of our users

4. Legal Basis for Processing (GDPR)

Under the General Data Protection Regulation (GDPR), we process your personal data based on:

• Contractual Necessity: To perform our contract with you and provide our services
• Legal Obligation: To comply with financial regulations, AML, and KYC requirements
• Legitimate Interests: For fraud prevention, security, and service improvement
• Consent: Where you have provided explicit consent for specific processing activities

5. Information Sharing and Disclosure

We do not sell your personal information. We may share your information in the following circumstances:

5.1 Service Providers

We share information with trusted third-party service providers who assist us in operating our platform:

• Banking partners for payment processing and account management
• Payment processors (including Stripe) for secure transaction handling
• Customer support and communication tools

All service providers are contractually obligated to protect your information and use it only for specified purposes.

5.2 Circle Members

Within your savings circles, other members may see:

• Your name and profile information
• Your contribution status and participation in the circle
• General activity within the circle (as necessary for transparency)

We do not share your financial details, bank information, or personal contact information with other circle members.

5.3 Legal Requirements

We may disclose your information if required by law, regulation, or legal process, including:

• Compliance with court orders or government requests
• Cooperation with law enforcement investigations
• Protection of rights, property, or safety
• Enforcement of our terms of service

5.4 Business Transfers

In the event of a merger, acquisition, or sale of assets, your information may be transferred to the acquiring entity, subject to the same privacy protections.

6. Data Security

We implement industry standard security measures to protect your information:

• Encryption: All data in transit is encrypted using TLS/SSL protocols
• Secure Storage: Sensitive data is stored using encryption at rest
• Access Controls: Strict access controls and authentication mechanisms
• Regular Audits: Security audits and vulnerability assessments
• Bank-Level Protection: Financial data is processed through regulated banking partners
• Monitoring: Continuous monitoring for security threats and anomalies

However, no method of transmission over the internet or electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your information, we cannot guarantee absolute security.

7. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to enhance your experience:

• Essential Cookies: Required for platform functionality and security
• Analytics Cookies: Help us understand how users interact with our platform
• Preference Cookies: Remember your settings and preferences

You can control cookies through your browser settings. However, disabling certain cookies may affect platform functionality.

8. Your Rights (GDPR)

Under GDPR and UK data protection laws, you have the following rights:

• Right of Access: Request a copy of your personal data
• Right to Rectification: Correct inaccurate or incomplete data
• Right to Erasure: Request deletion of your data (subject to legal obligations)
• Right to Restrict Processing: Limit how we use your data
• Right to Data Portability: Receive your data in a structured, machine-readable format
• Right to Object: Object to processing based on legitimate interests
• Right to Withdraw Consent: Withdraw consent where processing is based on consent

To exercise these rights, please contact us at privacy@circlesave.com. We will respond to your request within one month.

9. Data Retention

We retain your personal information for as long as necessary to:

• Provide our services and maintain your account
• Comply with legal and regulatory obligations (including financial record-keeping requirements)
• Resolve disputes and enforce agreements
• Maintain security and prevent fraud

Financial records may be retained for up to 7 years as required by UK financial regulations. When data is no longer needed, we securely delete or anonymize it.

10. International Data Transfers

Your information may be processed and stored outside the European Economic Area (EEA). When we transfer data internationally, we ensure appropriate safeguards are in place, including:

• Standard Contractual Clauses approved by the European Commission
• Adequacy decisions by the European Commission
• Other legally recognized transfer mechanisms

11. Children's Privacy

Our services are not intended for individuals under 18 years of age. We do not knowingly collect personal information from children. If you believe we have inadvertently collected information from a child, please contact us immediately.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes by:

• Posting the updated policy on our website
• Sending an email notification to registered users
• Displaying a prominent notice on our platform

The "Last updated" date at the top of this policy indicates when changes were last made. Your continued use of our services after changes constitutes acceptance of the updated policy.

13. Contact Us

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

You also have the right to lodge a complaint with the Information Commissioner's Office (ICO), the UK's data protection authority, if you believe your data protection rights have been violated.

ICO Website: https://ico.org.uk