Circlo Privacy Policy

Effective date: March 13, 2026

Circlo ("we", "our", "us") provides an offline, proximity-based app that lets people nearby create and join rooms, chat, and play mini-games.

This Privacy Policy explains what data Circlo processes, why, and your choices.

1) Scope

This Privacy Policy applies to the Circlo mobile application on Android and iOS.

2) Data We Process

Circlo is designed as a local-first app. The app does not require account signup.

Depending on how you use the app, Circlo may process:

• Display name (optional): the nickname you choose.
• Room and participation data: room name, room ID, and member list while a room is active.
• Chat and game data: messages and game actions needed to run room chat and mini-games.
• Technical connection data: temporary in-app device/session identifiers used to route local messages between participants.

3) How Data Is Collected and Shared

• Nearby communication: when you use room discovery/join features, data is exchanged with nearby devices via Bluetooth/local peer-to-peer transport.
• No account database by default: Circlo does not require creating an online account to use core features.
• Participant visibility: data you send in a room (such as nickname and chat messages) is visible to other participants in that room.

4) On-Device Storage

Circlo stores limited data on your device for app functionality, such as your saved display name preference.

Room, chat, and game state may also be held locally while sessions are active for synchronization and user experience.

5) Safety and Moderation Data

To provide a safe user experience (per Apple Guideline 1.2), Circlo processes the following:

• Block Lists: When you block a user, their unique identifier is stored locally on your device to ensure their content remains hidden from you.
• Abuse Reports: If you report a user, the report (including the offending content and user ID) is queued and transmitted to our moderation team once an internet connection is available. This information is used exclusively for safety enforcement and is not shared with third parties.

6) Permissions

To support nearby discovery and connectivity, Circlo may request platform permissions, including:

• Bluetooth / Nearby Devices
• (On certain Android versions) Location permission for Bluetooth scanning

If you deny these permissions, nearby room discovery and joining may not work.

7) Why We Process Data

We process data only to:

• enable room creation and joining,
• synchronize chat and game actions among participants,
• keep the app functional and reliable on your device.

8) Data Retention

We retain data only as long as needed for app operation and local functionality on your device.

Because Circlo is local-first, many room/session data elements are temporary and tied to active use.

9) Children

Circlo is not directed to children under the age required by applicable law in your jurisdiction (for example, under 13 in some regions). If you believe a child provided personal data in violation of law, contact us so we can review and take appropriate action.

10) Security

We use reasonable technical and organizational measures appropriate for a local-first mobile app. No system can guarantee absolute security.

11) International Use

If local data protection laws apply to you (for example GDPR/UK GDPR/CCPA), you may have rights regarding access, correction, deletion, or objection, depending on your jurisdiction and applicable exemptions.

12) Third-Party Services

Circlo currently does not use third-party analytics, advertising, or crash-reporting SDKs.

13) Changes to This Policy

We may update this Privacy Policy from time to time. We will update the effective date above and, where required, provide additional notice.

14) Contact

Data controller / publisher: Adem Beno
Email: [email protected]