Privacy Notice

1. Introduction

This Privacy Notice explains how Circlworld Technology Limited ("Circlworld", "we", "us") collects, uses, stores, and protects your personal data when you use the Circlworld platform.

We are committed to protecting your privacy and handling your data with transparency. Circlworld operates as a non-custodial coordination protocol — we do not hold or move your funds, and we minimise the personal data we collect to what is necessary for the platform to function.

2. Data We Collect

2.1 Account Data

When you create a Circlworld account, we collect:

• Email address
• Phone number
• Full legal name
• Date of birth (for identity verification)

2.2 Identity Verification Data

When you complete identity verification (KYC), our third-party verification provider processes:

• Government-issued identity document images
• Biometric data (selfie with liveness check, at Enhanced level)
• Proof of address documentation

Circlworld receives only the verification result — not the raw document images or biometric data. We store the last four digits of your document number, the document type, the issuing country, and the verification outcome. Full document data is retained by the verification provider under their own privacy policy.

2.3 Participation Data

Your activity on the platform is recorded to build your trust profile:

• Contribution records (amounts, timing, payment methods)
• Voting and governance participation
• Payout receipts
• Dispute history
• Endorsements given and received

2.4 Technical Data

• IP address (hashed for security, not stored in raw form)
• Device type and browser
• Session data

3. How We Use Your Data

We use your data to:

• Operate the Circlworld platform and coordinate circle activities
• Verify your identity to the level required for your tier
• Compute your trust score and generate trust reports
• Process sponsorship payments (via Stripe)
• Communicate platform activity and security events
• Comply with applicable laws and regulations

4. Your Rights

Under applicable data protection laws, you have the right to:

• Access your personal data
• Correct inaccurate data
• Delete your data (subject to legal retention requirements)
• Export your data in a portable format
• Object to certain processing
• Withdraw consent where processing is based on consent

Exercise these rights at Settings → Privacy & Data or by contacting privacy@circlworld.com.

5. Data Retention

We retain your data for as long as your account is active plus a regulatory retention period as required by applicable AML/CFT legislation. KYC verification data is retained for the period required by the relevant jurisdiction (typically 5-7 years after account closure).

6. Contact

For privacy enquiries: privacy@circlworld.com

Data Protection Officer: Drew St'Clair, Circlworld Technology Limited, Kingston, Jamaica.

Full Privacy Notice content to be finalised by legal counsel. This is a structural placeholder.