Privacy policy

1. Who we are

CircleSave helps people run rotating savings circles (ajo, esusu, susu and others) in the UK and Nigeria. This policy explains what we collect when you use CircleSave, why we need it, who we share it with and what you can ask us to do with it.

CircleSave Ltd is responsible for your information. We’re a company registered in England and Wales (company no. 16935930), and our registered office is at 5b Norfolk Street, Sunderland, UK. CircleSave is software, not a bank. Members pay each other directly, and no money passes through us.

2. What we collect

2.1 What you give us

• Your phone number. You sign in with a code we send to your WhatsApp, and it’s where your reminders go.
• Your name, and your email address if you give it to us.
• The circles you create or join: the amount, how often everyone pays, the payout order and who’s in it.
• The bank account your pot is paid into. In the UK that’s the name on the account, the sort code and the account number. In Nigeria it’s the bank, the account number and the name on the account. We store the account number encrypted. We use these details to check the account looks right and to show the members paying you where to send the money. We never move your money.
• The result of your ID check before your turn: the name and date of birth on your ID, and whether they match your payout account. Stripe checks your document and selfie and keeps those images. We don’t.
• If you sign up as a Circle Maker, your Maker code and the circles that came from your link.
• Anything you send us on WhatsApp, in the support chat or by email.

2.2 If an organiser added you

An organiser can add you to their circle with your name and phone number before you’ve joined. We use these to send you the join message and to show the organiser whether you’ve joined. If you don’t want to be in the circle, tap Not now on the join message or ask the organiser to remove you. Until you join, you won’t get reminders.

2.3 What we record as a circle runs

• Who has paid, who hasn’t, and when each payment was due.
• The buttons you tap on our WhatsApp messages (such as “I’ve sent it” or “I’ll be late”), and when our messages were delivered and read.
• The agreement you accept when you join a circle, with the time and how you accepted it.
• Any letter of demand or payment record a member prepares in the circle.

2.4 Technical information

• Your device and browser type, and the pages you visit on our public pages. Vercel Analytics counts visits without cookies. If you accept cookies, Google Analytics, Google Ads and the Meta Pixel also tell us how you found CircleSave and whether you set up a circle after seeing one of our ads.
• Your rough location from your IP address, so we can show you the right country’s page.
• Cookies, which section 8 explains.

3. Late-payment flags

We don’t use AI to judge you. We use two simple rules. If you’re still overdue at the end of two rounds in a row, or you tap “I’ll be late” two rounds running, your organiser sees a private flag so they can check in with you.

A flag doesn’t remove you from a circle, change your turn or affect anything outside CircleSave. People make those decisions, not the flag.

4. How we use your information

• To run your circles: tracking payments, showing the board and setting the payout order.
• To send the WhatsApp messages the circle needs, like sign-in codes, and the reminders you’ve said yes to.
• To check payout accounts and IDs, so each pot goes to the right person.
• To show organisers late-payment flags (section 3).
• To keep a payment record members can rely on if there’s a dispute about money owed.
• To pay Circle Makers what they’ve earned.
• To answer your questions and fix problems.
• To spot fraud and misuse, and keep CircleSave secure.
• To see how the site is used and which of our ads work, so we can improve both.

5. Our legal reasons

UK data protection law says we need a lawful reason for each thing we do with your information. Ours are:

• Our agreement with you: running the circles you create or join, signing you in, and sending the messages the service depends on.
• Your consent: WhatsApp reminders, the ID and selfie check with Stripe, Google Analytics, Google Ads and Meta Pixel cookies, and emails about new features such as pay by bank. You can change your mind at any time. If you’d rather not do the ID check, your organiser can vouch for you instead.
• Legitimate interests: late-payment flags, keeping payment records for disputes, preventing fraud and improving CircleSave. We’ve weighed these against your rights, and you can object (section 11).
• Legal obligation: keeping our own business records and answering lawful requests from courts and authorities.

6. Who we share it with

We don’t sell your information.

6.1 Companies that help us run CircleSave

• Meta (WhatsApp), which carries our messages to you
• Stripe, which checks your ID document and selfie before your turn
• Vercel, which hosts the website and runs our analytics
• DigitalOcean and Neon, which host our servers and database
• Crisp, which runs the support chat
• Google, which runs Google Analytics and Google Ads on our public pages
• Meta, which runs the Meta Pixel on our public pages if you accept cookies, so we can see which Facebook and Instagram ads lead to someone setting up a circle. If you accepted, our server also tells Meta when you set up a circle, with your IP address, browser type and the Meta cookie ids (section 8). It never sends your phone number, name or email.

They can only use your information to provide their service to us. Meta, Stripe and Google also have their own privacy policies for what they do as companies in their own right.

6.2 People in your circles

Other members see your name, whether you’ve paid each round and when your turn is. Your organiser also sees your phone number and any late-payment flag (section 3).

When it’s your turn to be paid and your ID check is done, the members paying you see the name on your payout account and its account details, so they can send the money. They only see them while their payment to you is open. Your organiser sees the name on the account, the last four digits and whether your ID check is done, so they can vouch for you if the check doesn’t work. When a member pays you, they can tell us whether their bank recognised your name, and we pass a mismatch on to your organiser.

If you stop paying after your turn, a member you owe can prepare a letter of demand and download the circle’s payment record for what you owe them. It includes your payments, the agreement you accepted when you joined and the messages we sent you. They can show it to a mediator or a court. Your organiser can download the whole record, and you can download your own.

6.3 Circle Makers

If you set up a circle through a Circle Maker’s link, the Maker sees your first name and how full your circle is. They don’t see your phone number or who has paid.

6.4 When the law requires it

We’ll share information if a court, the police or another authority lawfully asks for it, or if we need to protect someone’s safety or enforce our terms.

6.5 If CircleSave is sold

If another company buys or merges with CircleSave, your information would pass to them, and this policy would still apply to it.

7. Keeping it safe

Everything sent between your device and CircleSave is encrypted. We store bank account numbers encrypted. Sign-in links work once, and we only keep a scrambled copy of them. Only people who need access to our systems have it.

No system is perfectly secure. If something goes wrong that puts you at risk, we’ll tell you and the regulator, as the law requires.

8. Cookies

We use a small number of cookies:

• Signing in (circlesave_access_token, circlesave_phone_e164): keep you signed in. They last 12 hours.
• Country (cs_market): remembers whether you chose the UK or Nigeria page. It lasts a year.
• Circle Maker link (cs_maker): remembers whose link you came from, so we can thank them if you start a circle. It lasts 60 days.
• Your cookie choice (cs_consent): remembers whether you accepted or rejected cookies. It lasts about six months.
• Support chat: Crisp sets its own cookies once you open the chat.
• Google Analytics and Google Ads (_ga, _ga_*, _gcl_au): only if you tap Accept. They show us how people find CircleSave and which ads lead to someone setting up a circle. They last between 90 days and two years.
• Meta Pixel (_fbp, _fbc): only if you tap Accept. They show us which Facebook and Instagram ads lead to someone setting up a circle. They last 90 days.

If you reject cookies, Google’s tag still runs on our public pages, but it doesn’t set or read any cookies. It sends Google basic information without them, such as that a page was viewed, which Google uses to estimate how our ads perform. The Meta Pixel doesn’t load at all unless you accept. Neither runs on your dashboard or on sign-in links.

You can change your choice at any time with Cookie settings at the bottom of our public pages. Vercel Analytics doesn’t use cookies. You can also delete or block cookies in your browser settings, but you’ll need the sign-in cookies to use your dashboard.

9. How long we keep it

• Your account and circles: while you use CircleSave.
• A circle’s payment record, including the agreement members accepted: after the circle ends, because members may need it if there’s a dispute about money owed. If a member opens a case about money owed, we keep what’s in it until six years after the case closes, the usual time limit for a claim like this.
• Our own business records, such as invoices: as long as UK law requires.

When we no longer need something, we delete it or remove anything that could identify you.

10. Information sent abroad

We’re based in the UK. Some of the companies in section 6.1 store or process information in other countries, including the United States. When information leaves the UK, we rely on the UK’s adequacy rules or its International Data Transfer Agreement, so it stays protected. If you’re in Nigeria, your information is processed in the UK and those other countries, with the protections the Nigeria Data Protection Act 2023 requires.

11. Your rights

You can ask us to:

• give you a copy of your information
• correct anything that’s wrong
• delete your information, unless we have to keep it (for example, a payment record in a dispute)
• limit how we use it
• send it to you or another service in a common format
• stop using it for something you object to
• stop anything you gave consent for

These rights come from UK data protection law. If you live in Nigeria, the Nigeria Data Protection Act 2023 gives you the same rights. Email hello@circlesave.app and we’ll reply within one month.

12. Children

CircleSave is for people aged 18 and over. We don’t knowingly collect information about anyone younger. If you think we have, please tell us and we’ll delete it.

13. Changes to this policy

If we change this policy, we’ll update the date at the top. If a change affects how we use your information, we’ll tell you on your dashboard before it takes effect.

14. Contact us

Questions about your information, or about this policy? Get in touch:

If you’re unhappy with how we’ve handled your information, you can complain to the Information Commissioner’s Office in the UK (ico.org.uk) or, in Nigeria, the Nigeria Data Protection Commission (ndpc.gov.ng).