Privacy Policy

Effective Date: September 14, 2025
Last Updated: July 11, 2026
Version: 2.4

Our Circle Inc. (“Our Circle,” “we,” “us,” or “our”) is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile application and related services (the “App”) and when you visit our website at ourcircle.org (the “Site”). We refer to the App and the Site together as the “Service.”

1. Scope

  • Applies to: The Site (including forms, landing pages, and email signup), the App (iOS/Android), and any communications or services we provide.
  • Audience: Our Circle is intended for adults aged 18+ who are parents and caregivers. We do not knowingly allow minors to create accounts.
  • Organization administrators: If you also serve as an administrator for a Verified Organization (see Section 7), your use of the Organization Portal or the Gather app is governed by the separate Organization Portal & Gather Privacy Policy. This Policy governs your personal use of the App as a parent or caregiver.

Not a HIPAA Covered Entity: Our Circle is not a healthcare provider or HIPAA covered entity. Information shared in the App is for peer support and community features, not medical care.

2. Information We Collect

2.1 Information You Provide

  • Account & Profile: Name, email, birth year (for age validation), city/state/ZIP code (used to determine your approximate location), languages, photos, optional profile details (such as occupation, bio, interests, and icebreaker answers), and optional verification data.
  • Child Profiles (optional, provided by parent/guardian): Child’s first name or nickname, birth year and age, gender, support needs, interests, traits, activity level, and a free-text description — all optional and chosen by you. We store a birth year rather than a full birth date, and child profiles have no photo field. Providing support-needs information is optional and never implies any diagnosis. Parents remain in control of this information and can edit or delete it at any time.
  • Content & Communications: Posts, comments, reactions, messages, groups, events, and audio room (Loops) participation metadata.
  • Educational Content: Webinar registration, attendance tracking, viewing activity, speaker information you choose to access, and calendar integration for event reminders.
  • Gaming & Voice Features: Game preferences, platform choices, gaming group memberships. If you link your Discord account, we collect your Discord username, display name, user ID, and avatar URL. We do not access Discord messages or other Discord activity beyond voice room participation.
  • Support & Feedback: Reports, requests, survey responses, and other communications.
  • Optional AI bio helper: If you use the “help me write my bio” feature, the answers you provide (activities, an optional family detail, goals, and vibe words) are sent to our AI provider to draft a bio for your review.
  • Website forms: Email signup and contact forms.
  • Loops (audio rooms): Participation metadata (e.g., room ID, join/leave times, device/network diagnostics). We do not record or store audio content by default. If we ever introduce optional recording, we will clearly disclose it and seek required consent.

Sensitive data (special categories): Certain information you choose to provide (e.g., a child’s support needs) may be considered sensitive under applicable law. Providing such information is optional and based on your explicit consent, which you may withdraw at any time by toggling off fields or deleting the child profile in the App. Where we rely on other lawful bases (e.g., to provide the Service or for safety), we will state so. We apply additional safeguards to help protect this information. We treat support-needs and similar health-adjacent information as sensitive: we use it only to provide the features you request (such as community features), we never use it for advertising, and we never sell it.

2.2 Information Collected Automatically

  • Device & Usage: Device model, OS/version, app version, IP address, language, time zone, in-app actions, performance metrics, and crash reports.
  • Identifiers: Firebase authentication tokens, push notification tokens (FCM/APNs), and deep link/app link parameters. Your account identifier is also used as your analytics user ID.
  • Multi-Factor Authentication (MFA): If you enable two-factor authentication, your phone number is stored with our authentication provider for SMS verification codes.
  • Location: The App does not access your device’s GPS and does not request any location permission. Instead, you provide a ZIP code or city, which we convert to approximate map coordinates (the center point of that area). We store those coordinates, your city/state/ZIP, and derived proximity codes of varying precision to power distance-based discovery, nearby feeds, groups, and events, and we keep a short history of your recent location changes. In the App, other users see your city and state and approximate distances. You can update your location in settings, and expanding your discovery radius (Extended Discovery) is optional.
  • Cookies & similar tech (Site): We use cookies and local storage for analytics and site functionality (e.g., Google Analytics).

Automated content and photo analysis: Content and photos you upload are analyzed by automated systems on our servers, including third-party AI services (see Section 5), for safety and content moderation — for example, verifying that profile photos depict a real person. We do not use facial recognition to identify users and we do not create or store biometric identifiers; the only biometric processing connected to the App is the optional identity verification performed by Veriff, described in Sections 5 and 9.

3. How We Use Information

  • Core functionality: Create and manage accounts, enable discovery and matching, power feeds and groups, messaging, events, and Loops (audio rooms).
  • Educational features: Provide webinar registration, live and recorded educational sessions, speaker profiles, calendar reminders, and engagement analytics to improve content quality.
  • Gaming features: Enable private gaming groups and optional Discord voice integration. When you link Discord, we use your Discord account information solely to provide voice room access and display participant information to group members. We do not access your Discord messages or other Discord activity.
  • Safety & trust: Age gating, optional ID verification, automated content moderation, abuse and scam prevention, fraud detection, and policy enforcement. We use automated tools — including third-party AI services — to review user-generated content for safety and compliance with our Terms; moderation decisions can be appealed, with human review of appeals that are not resolved automatically.
  • Personalization: Recommend connections, groups, and content based on your profile, preferences, and activity. Distance-based features use only the approximate location you provide.
  • Communications: Send service emails and push notifications about account activity, security, and important updates; marketing emails with your consent.
  • Analytics & improvement: Understand usage, fix bugs, improve performance, and develop new features.
  • Subscriptions & payments: Manage purchases and entitlements via RevenueCat and the applicable app stores.
  • Marketing: We run ads on third-party platforms (e.g., Facebook/Instagram). These ads are delivered by the platform and do not use your website activity from our Site for retargeting. On the Site, we use analytics only (e.g., Google Analytics) to understand aggregate usage.
  • Loops operations: Provide real-time audio via third-party infrastructure without retaining audio content by default; we may use anonymized telemetry to monitor quality and prevent abuse.

4. Cookies, SDKs, and Tracking Technologies

  • Website cookies: Used for essential functions and analytics (e.g., Google Analytics). We do not use an advertising pixel on the Site. Manage via your browser settings or any site controls we provide.
  • Mobile SDKs: The App uses SDKs for authentication, analytics, performance monitoring, messaging, remote configuration, subscriptions, and crash/error reporting (see Sentry in Section 5).
  • Ad tracking: We do not show in-app ads at this time. If we introduce ads in the future, we will update this policy and, where required, obtain consent (e.g., iOS App Tracking Transparency).

5. Third-Party Services We Use

We share information with service providers who process data on our behalf, strictly for the purposes described below:

  • Firebase & Google Cloud (Google): Authentication (including SMS verification codes), Firestore database, Cloud Functions, Storage, Analytics, Remote Config, Messaging, App Check device-integrity checks, and Google Cloud infrastructure — including a Cloud SQL (PostgreSQL) database that keeps a copy of certain profile, location, post, and group information to power discovery and feeds — and Google Maps/Geocoding services used to convert the ZIP code or city you enter into approximate coordinates. Privacy & Security
  • Render (API hosting): Our application programming interface (api.ourcircle.org) runs on Render infrastructure. App requests — and the information they carry — transit Render’s servers, protected by the same authentication and device-integrity checks as the rest of the Service. Privacy Policy
  • Cloudflare: Images and Stream for secure media storage/optimization and video delivery, including recorded webinar hosting. Some media uploads go directly from your device to Cloudflare, which receives your device’s IP address in the process. Privacy Policy
  • Agora: Real-time audio for Loops. Agora receives the room identifier, a hashed numeric ID (not your name or account ID), the live audio stream, and connection metadata. Audio is not recorded. Privacy Policy
  • RevenueCat: Subscription and purchase management. RevenueCat receives your account identifier and store purchase/receipt data; we never see your payment card details. Privacy Policy
  • Apple & Google platform services: App distribution, push notification delivery, in-app billing, and device-integrity attestation. Accounts are created with email and password; a small number of legacy accounts may retain a linked Google sign-in, which can be unlinked in settings. Apple • Google
  • Veriff (optional): Identity verification for trust and safety, available with Circle Plus (our optional paid subscription). When you verify, Veriff collects images of your government-issued ID and a selfie and performs a biometric face comparison on Veriff’s systems. We receive and store the verification result, a risk score, your verified first and last name, the document type and issuing country/state, and your attempt history — we do not store your ID images, your date of birth, your document number, or any biometric data, and verification images are deleted by Veriff under its retention policy. Verification is optional, is not required to use the Service, and provides a verified badge; it does not guarantee anyone’s identity or safety. Attempt limits apply. Privacy Policy
  • Discord (optional): Voice communication for gaming groups. When you link your Discord account via OAuth, we collect your Discord username, display name, user ID, and avatar URL. We use this information solely to provide voice room access and display participant information. We do not access your Discord messages, message history, or other Discord activity. You can unlink your Discord account at any time. Privacy Policy
  • Zoom: Live webinar platform for educational sessions. Webinar links are provided to registered users for live sessions. Privacy Policy
  • YouTube (embedded videos): If a post, comment, or message contains a YouTube link, the App may display an embedded YouTube player. Loading or playing the embedded video connects your device to YouTube (Google), which receives your device’s IP address and applies its own privacy policy. Privacy Policy
  • OpenAI (automated content moderation, translation & AI features): We use OpenAI’s services, server-side, to review user-generated content, bios, and profile photos — for safety and policy compliance; to translate content between English, Spanish, and French when requested; and to power optional features such as the bio-writing helper. OpenAI processes this content on our behalf and, under its API terms, does not use it to train its models. Moderation decisions can be appealed through the App, and appeals that are not resolved automatically are reviewed by a person. Privacy Policy
  • Mailgun (SMTP): Transactional email delivery. Privacy Policy
  • Sentry: Crash and error reporting for the App and our servers. Crash reports may include your IP address, and device information. Privacy Policy
  • Google Analytics (Site): Website analytics. Privacy Policy
  • Meta (Facebook/Instagram Ads): We buy ads that are delivered on Meta’s platforms. We do not use the Meta Pixel on our Site and do not share Site analytics data with Meta. Privacy Policy

6. How We Share Information

  • No selling of personal information: We do not sell or rent your personal information. We also do not share children’s profile information with advertisers.
  • Service providers: We share data with vendors listed above to operate and improve the Service under contracts that limit their use of your data.
  • Other users: Information you include in your profile — including any child profile details you choose to show, your city/state, and approximate distance — is visible to other signed-in users according to your profile settings. If you join through another member’s invite link, that member is notified with your display name and photo and a connection between you is created automatically.
  • Verified Organizations: If you join a Verified Organization’s group, that organization receives the information described in Section 7.
  • Discord (limited scope): When you link Discord for gaming features, we share your Our Circle parent name with Discord to set your server nickname, and we query real-time voice room participation to display who is in voice channels. We do not share child profiles, connection history, messages, or other app activity with Discord.
  • Legal and safety: We may disclose information if required by law or to protect rights, safety, and integrity of our users and the Service.
  • Business transfers: In a merger, acquisition, or asset sale, information may be transferred subject to this Policy.
  • Advertising platforms: We buy ads that are delivered on third-party platforms (e.g., Facebook/Instagram). We do not share your Site activity with these platforms for retargeting, and children’s profile information is not shared with advertisers.

7. Verified Organizations

Our Circle partners with organizations such as hospitals, clinics, nonprofits, and community groups (“Verified Organizations,” also referred to as “Organizations”) that may create and manage private groups within the App. This section explains how your information is handled when you interact with organization-managed groups. Verified Organizations access member information through our Organization Portal and the Gather administrator app; their handling of that information is governed by an Organization Subscription Agreement (referred to in earlier versions of these documents as the “Partner Agreement”) and by the Organization Portal & Gather Terms of Use (the Organization Portal & Gather Privacy Policy governs how Our Circle handles administrators’ own information).

7.1 What Verified Organizations Can See

When you join a organization-managed group (e.g., by scanning a QR code or entering an invite code), the Verified Organization’s authorized staff can see:

  • Display name (your parent name as shown in your profile)
  • Profile photo
  • Email address (the email on your account)
  • General location (your city and state — not your precise location)
  • Join date and how you joined (including any invite code you used)
  • Engagement summary (number of posts and comments within their group)
  • Event RSVPs (your name, photo, RSVP status, and response time for that organization’s events)
  • Badges the organization assigns to you within the group
  • Content you share in their groups (your posts and comments) and messages you exchange with the organization in one-to-one organization chats

Verified Organizations use this information to verify members and keep their groups safe and private. They do not have access to your child profiles or support-needs details, your phone number, your precise location, your private messages with other families, your connections, or your activity outside their groups.

7.2 Consent

Before joining a organization-managed group, you will be shown a clear disclosure explaining what information the Verified Organization can see. Joining the group constitutes your consent to share this limited profile information with the Verified Organization. You may withdraw consent at any time by leaving the group.

7.3 Organization Data Use Restrictions

Verified Organizations are contractually prohibited from:

  • Using group membership or member data as part of clinical, medical, or health records, or to make enrollment or eligibility decisions
  • Sharing, selling, or enriching member information with third parties, or using it to train AI or machine-learning systems
  • Using member data for marketing, advertising, fundraising, or solicitation outside of the Our Circle platform, or contacting members outside the Service
  • Exporting, scraping, or copying member data out of the administrative tools
  • Retaining member data after a member leaves the group or the organization’s participation ends, except transient copies in notification or digest emails, which must be destroyed when no longer needed

If a Verified Organization requires the use of group data for care coordination or clinical purposes, a separate agreement (such as a Business Associate Agreement) must be executed.

7.4 Organization Activity Monitoring

All Verified Organization actions within the portal (e.g., viewing members, removing members, generating invites) are logged in an audit trail for security and accountability purposes.

7.5 When You Leave an Organization Group

When you leave or are removed from a organization-managed group, your membership record is deleted and your profile information is no longer visible to the Verified Organization. Content you posted within the group (posts and comments) may remain visible to other group members.

7.6 Sponsored Memberships

A Verified Organization may pay to sponsor Circle Plus benefits for members of its groups. If your membership is sponsored, benefits are granted and removed automatically based on your group membership and the organization’s subscription status. You are not charged, the organization does not receive your payment information, and the organization is billed based only on aggregate member counts — never your identity or activity. If you already have your own Circle Plus subscription, sponsorship does not affect it.

8. Children’s Privacy

  • Adults only: The App is for users 18+. We do not knowingly collect personal information directly from children; accounts may be created only by adults.
  • Parent-provided child data: Parents and guardians may optionally add information about their children to facilitate meaningful connections. Because it comes from you, we treat it as your sensitive information and protect it accordingly. Support-needs entries are optional and never imply any diagnosis or condition. Parents control this data and can edit or delete it at any time, including per-child controls over what appears on your profile.
  • Advertising: Children’s information is not used for advertising and is not shared with advertisers.
  • Accidental collection: If we learn that a user under 18 has created an account, we will delete the account and associated data.

9. Data Retention

  • Account data: Retained while your account is active. You can delete your account at any time in the App’s settings. Upon account deletion, we delete or anonymize personal data within approximately 30 days, unless retention is required by law. Some information persists after deletion: comments you left on other users’ content may remain (with the display name shown at the time), copies of photos and videos you uploaded may be retained on our media-hosting provider’s systems after they stop being displayed in the App, moderation and safety records may be retained where needed to protect the community, and we keep a de-identified record of the deletion (with no name, email, or contact information) for analytics.
  • Content: Posts, comments, messages, groups, events, webinar registrations, and Loops metadata are retained until you delete them or your account, subject to technical and legal limitations.
  • Verification data: Identity verification attempt history (results, risk scores, verified name, and document type/country — never images, date of birth, or document numbers) is retained for the life of your account for audit and safety purposes and is deleted when your account is deleted. ID images are not stored by us and are deleted by Veriff according to its retention policy.
  • MFA data: Phone numbers used for SMS two-factor authentication are retained while MFA is enabled on your account. Related security logs are retained for as long as needed to detect and investigate security issues, and may be retained after account deletion where needed for security and audit purposes.
  • Biometric information: We do not collect, store, sell, lease, trade, or otherwise profit from biometric identifiers or biometric information. Optional identity verification involves a facial-geometry comparison performed entirely on Veriff’s systems; we contractually require that any biometric data collected in connection with your verification be permanently destroyed once the verification purpose is satisfied, and in any event within three (3) years of your last interaction with the Service, in accordance with applicable biometric privacy laws.
  • Discord linking: Discord account information is retained while your Discord account remains linked. You can unlink at any time to remove this data.
  • Operational logs & analytics: Retained only for as long as reasonably necessary to ensure the security, integrity, and performance of the Service.
  • Moderation & safety records: Records of moderation decisions, appeals, reports, enforcement actions, and content flagged by our safety systems (which may include a retained copy of flagged content) are kept as needed to enforce our Terms, handle appeals, and protect the community.
  • Place Submissions & listing integrity: Certain content (e.g., Place Submissions, associated photos/reviews, and related discussion context) may continue to be displayed or retained as reasonably necessary to preserve listing integrity, safety/audit logs, dispute resolution, and compliance, consistent with our Terms. Backups and caches may persist until they expire or are overwritten in the ordinary course of our backup cycles.
  • Organization group membership: When you leave or are removed from a organization-managed group, your membership record is deleted and your profile information is no longer accessible to the Verified Organization. Organization activity audit logs are retained for security and compliance purposes.

10. Security

  • Protections: Encryption in transit, secure cloud infrastructure, strict access controls, App Check, regular monitoring, EXIF stripping for uploaded images, media access controls, crash/performance monitoring, and HMAC-SHA256 signature validation for webhooks.
  • Multi-factor authentication: We support two-factor authentication via SMS to protect your account.
  • Limitations: No method of transmission or storage is 100% secure; we strive to protect your information and encourage you to use strong, unique passwords, enable MFA, and keep your device updated.

If we become aware of a data incident affecting your information, we will provide notices as required by law and may temporarily restrict features to protect users. Additional details appear in our Terms.

11. International Data Transfers

Your information may be processed in the United States and other countries where our providers operate. While we do not currently serve EU residents, we use appropriate safeguards for data transfers as a best practice (e.g., EU Standard Contractual Clauses and the UK International Data Transfer Addendum where applicable with our service providers), and apply additional security measures as appropriate.

12. Your Rights & Choices

Our Commitment to Privacy: We do not sell or rent your personal information to third parties, and we never will. While Our Circle does not currently qualify for GDPR regulation (we do not offer goods or services to EU residents), we provide the privacy rights and protections described below as best practices for all users, regardless of location, to demonstrate our commitment to privacy and transparency.

  • Access & portability: Request a copy of your data.
  • Correction & deletion: Update your information or delete your account/data.
  • Preferences: Manage email subscriptions and push notifications in-app or on your device, and update your location (city/ZIP) in the App’s settings.
  • Cookies: Control cookies via your browser and device settings.

12.1 European Economic Area/UK (GDPR/UK GDPR – Best Practices)

  • Lawful bases: We follow GDPR-style processing principles including consent (e.g., marketing, certain analytics), contract (providing the Service), legitimate interests (security, improvement), and legal obligations.
  • We provide GDPR-equivalent rights including access, rectification, erasure, restriction, portability, and objection; you may withdraw consent at any time where processing relies on consent.

Sensitive data (special categories): Certain information you choose to provide (e.g., a child’s support needs) may be considered sensitive under applicable law. Providing such information is optional and based on your explicit consent, which you may withdraw at any time by toggling off fields or deleting the child profile in the App. Where we rely on other lawful bases (e.g., to provide the Service or for safety), we will state so. We apply additional safeguards to help protect this information. We treat support-needs and similar health-adjacent information as sensitive: we use it only to provide the features you request (such as matching and community features), we never use it for advertising, and we never sell it.

12.2 Requests, Verification & Response Times

To exercise your rights, email help@ourcircle.org. We may request information to verify your identity and authority (e.g., for child data managed by a parent/guardian). We aim to respond within 30 days, with one extension if needed for complex requests.

12.3 United States State Privacy Rights

Depending on your state of residence (for example, California, Colorado, Connecticut, Virginia, Texas, Oregon, Montana, or Maryland), you may have rights to know, access, correct, delete, and obtain a portable copy of your personal information, and to appeal a decision on your request. We honor these rights for all users as described above. We do not sell your personal information, we do not share it for cross-context behavioral advertising, and we do not use or disclose sensitive personal information (such as support-needs details, account credentials, the contents of your messages, and the biometric verification performed by Veriff on our behalf) for any purpose other than providing the Service, safety, and legal compliance. To exercise any right — directly or through an authorized agent — email help@ourcircle.org; we will verify your request, respond within the timelines in Section 12.2, and never discriminate against you for exercising your rights. If we decline to take action on your request, you may appeal by replying to our response or emailing help@ourcircle.org with “Appeal” in the subject line; if your appeal is denied, you may contact your state Attorney General to submit a complaint.

13. Choices About Ads

We do not currently serve in-app ads. For the Site, you can adjust browser settings, use available privacy controls, and manage preferences with participating platforms. On mobile devices, you can also reset your advertising ID and limit ad tracking in OS settings. If we add in-app ads, we will update this policy and provide appropriate consent and opt-out controls.

Do Not Track & opt-out preference signals: Some browsers offer a “Do Not Track” (“DNT”) setting or can send opt-out preference signals such as the Global Privacy Control (“GPC”). Our Site does not currently respond to DNT signals, and the analytics provider we use (Google Analytics — see Sections 4 and 5) may collect information about your visits to the Site over time. Because we do not sell your personal information or share it for cross-context behavioral advertising, there is no sale or sharing for these signals to opt out of; if our practices ever change, we will honor opt-out preference signals as required by law. You can also send any opt-out request to help@ourcircle.org.

14. Changes to This Policy

We may update this Privacy Policy to reflect changes in our practices or legal requirements. We will post the updated policy here and, for material changes, provide additional notice (e.g., in-app or by email).

15. Contact Us

For privacy questions or requests, contact us:

By using the App or Site, you acknowledge that you have read and understand this Privacy Policy.