1. About this Acceptable Use Policy
1.1 Purpose
This Acceptable Use Policy ("AUP") describes the conduct expected of Members on the Circlworld platform and the conduct that Circlworld prohibits. The AUP is incorporated by reference into the Terms of Service available at circlworld.com/legal/terms and forms part of the agreement between you and Circlworld.
1.2 Why this AUP exists
Circlworld is community infrastructure. The Platform's value depends on the integrity of the participation it credentials. When members participate honestly, the trust profiles generated by the Platform mean something — to other members, to lenders, to employers, to the broader financial system the credentials are intended to bridge into.
Conduct that undermines this integrity damages all members, not just the immediate counterparties. The AUP exists to define such conduct clearly and to give Circlworld the operational authority to address it.
1.3 Member responsibility
By using the Platform, you agree to comply with this AUP. Your responsibility extends to:
- Your own conduct on the Platform
- Conduct under your account by any person you have permitted to use it (you remain responsible even where the conduct is by someone else acting under your credentials)
- Cooperating with Circlworld's enforcement of the AUP, including responding to enquiries about your conduct
1.4 Plain-language summary (non-binding)
The provisions of this AUP are binding in the form set out below. The following plain-language summary describes the substance in non-binding form.
(a) Use the Platform honestly. Make accurate attestations. Honour the obligations you take on within circles. (b) Treat other members with respect. Harassment, threats, and discriminatory conduct are not tolerated. (c) Do not use the Platform to launder funds, evade sanctions, or commit financial crimes. (d) Do not manipulate trust scores or attempt to gain credentials through dishonest means. (e) Do not attempt to compromise the Platform's security or to access information you are not entitled to. (f) Where you become a treasurer, take the fiduciary responsibility seriously. (g) Breach of the AUP can result in account restrictions, account termination, recording of the breach in your trust profile, and (in serious cases) referral to law enforcement.
2. Conduct expected of all Members
2.1 Honest attestation
When you make any attestation on the Platform — whether attesting that you sent a contribution, confirming as treasurer that you received a contribution, voting in a circle governance matter, issuing or accepting an endorsement, raising or responding to a dispute — your attestation must be honest and accurate to the best of your knowledge.
Attestations on the Platform are recorded in the audit log and become part of the trust profile of the attesting member. Dishonest attestation is a serious matter affecting not only your own profile but the integrity of every credential the Platform produces.
2.2 Performance of obligations
When you take on an obligation within a circle, an LLP transaction, a CLP transaction, a sponsorship, or any other arrangement coordinated through the Platform, you must perform the obligation in accordance with the terms agreed. The Platform's role is to make these obligations observable; the obligations themselves run between you and the other parties.
If you encounter genuine difficulty performing an obligation, your responsibility is to communicate — with your treasurer, with the circle, with the counterparty, with Circlworld support if appropriate. Quietly defaulting without communication is a separate breach from defaulting with communication.
2.3 Respectful interaction
The Platform provides structured interaction surfaces (circle communications, dispute communications, endorsement quotes, treasurer notes). You must use these surfaces respectfully:
- Treat other members with the courtesy you would expect from them
- Do not engage in harassment, threats, or intimidation
- Do not engage in discriminatory conduct based on race, ethnicity, national origin, religion, gender, sexual orientation, disability, age, or any other protected characteristic
- Do not use slurs, hate speech, or content that incites hatred against any group
Communications outside the Platform (private messages, in-person communication) are not directly governed by the AUP, but conduct outside the Platform that affects relationships within a circle — for example, threats to other circle members about the circle's operation — may be relevant to dispute resolution and to AUP enforcement.
2.4 Accurate identity
You must provide accurate identity information at signup and during identity verification. You must not:
- Provide false personal information
- Use an identity document that does not belong to you
- Attempt identity verification on behalf of another person
- Create multiple personal accounts
- Allow another person to use your account
If your identity information changes (name change following marriage, change of residence, etc.), you must update it in your Settings Panel.
3. Prohibited conduct
The following conduct is prohibited on the Platform. The list is not exhaustive of every form of misconduct; Circlworld reserves the right to address conduct that breaches the spirit of this AUP even where not specifically enumerated below.
3.1 Financial misconduct
You must not:
(a) Misappropriate funds. As a treasurer, this includes diverting circle funds to personal use, failing to disburse payouts on the agreed schedule (without good cause communicated to the circle), or using circle funds in ways the circle has not authorised. As any member, this includes false claims of contribution that lead other members to make payouts or extend credit to you in error.
(b) Engage in money laundering or terrorism financing. The Platform must not be used to layer or integrate proceeds of crime, to disguise the source of funds, to finance terrorism or proliferation of weapons of mass destruction, or to evade sanctions imposed by the United Nations, the United Kingdom, the European Union, the United States, or any other jurisdiction whose sanctions Circlworld is required to honour.
(c) Evade tax obligations. The Platform must not be used to disguise income or to evade tax obligations in your jurisdiction of residence or any other applicable jurisdiction.
(d) Conduct fraudulent transactions. This includes (but is not limited to) chargeback fraud (initiating a chargeback against a sponsorship charge after receiving the corresponding benefit), payment instrument fraud (using a stolen card or bank account), and trust report fraud (sharing a trust report you know to be inaccurate or manipulated).
(e) Operate a Ponzi scheme or similar pyramid structure. Circles are rotating savings associations in which all members both contribute and receive. A scheme in which earlier members are paid from the contributions of later members without genuine reciprocal participation is a pyramid structure, not a circle, and is prohibited.
3.2 Trust profile manipulation
You must not:
(a) Coordinate false endorsements. Endorsements must reflect the genuine view of the endorser, formed from genuine experience with the endorsed member. Coordinating with other members to issue endorsements that do not reflect such genuine experience — including endorsement-trading arrangements — is prohibited.
(b) Coordinate sham circles. A circle whose primary purpose is to generate trust profile credit for its members rather than to operate as a real rotating savings association is a sham. Sham circles include (but are not limited to) circles in which members make notional contributions that are immediately refunded, circles formed solely to inflate trust scores before a credit application, and circles formed by colluding parties to credential one another.
(c) Conduct false attestation patterns. Where a member or treasurer makes attestations that, on review, are systematically not corroborated by the corresponding party's attestation, or that are systematically reversed after the credential effect has been received, this constitutes false attestation pattern and is prohibited.
(d) Manipulate disputes. This includes raising disputes you know to be unfounded for the purpose of damaging another member's trust profile, falsely responding to legitimate disputes, or coordinating with other members to produce a particular dispute outcome.
(e) Share or sell trust reports. Trust reports are personal credentials. You may share your own trust report with recipients of your choice (consistent with the Terms of Service and Privacy Notice). You must not sell your trust report or your access to your trust report; you must not share another member's trust report you have received as a recipient.
3.3 Platform integrity
You must not:
(a) Compromise the Platform's security. This includes attempting to gain unauthorised access to other members' accounts, to circle data you are not a member of, to Circlworld's systems, or to data held in transit or at rest. Security research conducted under Circlworld's Responsible Disclosure Policy is welcomed; unauthorised attempts to access systems are not.
(b) Reverse-engineer or circumvent Platform controls. You must not reverse-engineer the Platform's software, attempt to circumvent its access controls, exploit vulnerabilities (other than through Responsible Disclosure), or develop tools that interact with the Platform in unauthorised ways.
(c) Automate the Platform without authorisation. Use of the Platform's official API is governed by separate API terms. Scraping, bot use, or automation outside those terms is prohibited.
(d) Submit malicious content. This includes attempting to inject scripts, malware, or other code into the Platform; uploading files containing viruses or malicious code; or submitting content designed to disrupt the Platform's operation or to harm other members' devices.
(e) Spam the Platform. This includes mass-sending circle invitations, mass-issuing endorsements, or otherwise generating volumes of activity that are not proportionate to genuine community savings participation.
3.4 Illegal content and conduct
You must not use the Platform to:
(a) Engage in conduct that is illegal in your jurisdiction of residence, the jurisdiction in which the conduct occurs, or any jurisdiction Circlworld operates in (b) Distribute illegal content, including content that infringes intellectual property rights, content that constitutes child sexual exploitation material, content that incites violence, or content that is otherwise illegal (c) Threaten violence against another person, group, or community (d) Facilitate human trafficking, modern slavery, or forced labour (e) Engage in the unauthorised sale of regulated goods (firearms, controlled substances, prescription medications, etc.) (f) Conduct activity that violates the prohibitions of the Bribery Act 2010 (United Kingdom), the Corruption Prevention Act (Jamaica), the Foreign Corrupt Practices Act (United States, where applicable), or equivalent anti-bribery legislation
3.5 Misrepresentation
You must not misrepresent:
(a) Your identity (Clause 2.4) (b) Your circle's nature or purpose (Clause 3.2(b)) (c) Your relationship to Circlworld. You are not authorised to claim that you represent Circlworld, that your circle is endorsed by Circlworld, or that the Platform is regulated as a financial services firm in any jurisdiction (it is not, as set out in the Terms of Service Clause 4.1) (d) The credentials produced by the Platform. You may share your trust report; you must not claim that it represents more than it does (for example, you must not claim it is a credit score issued by a credit bureau)
4. Treasurer-specific obligations
If you act as a treasurer of a circle, the obligations in this Clause 4 apply to you in addition to the general obligations in Clauses 2 and 3.
4.1 Fiduciary conduct
As a treasurer in a Category A (member-to-member) circle, you do NOT hold members' contributed funds in your personal account. Members contribute through their own bank accounts directly to the receiving member each round. Funds are held by the members themselves, in a dedicated Circle account, or by a partner institution — never by Circlworld and never by your personal account. Your fiduciary responsibility runs to the other circle members in respect of the coordination, the record, and the rotation. The Risk Disclosure at circlworld.com/legal/risk-disclosure describes this responsibility in detail; this AUP supplements with specific conduct requirements:
(a) NEVER take temporary custody of cycle contributions in your personal account, even for convenience or to bridge a member's late payment (b) Do not use the circle's funds for personal purposes, even with the intention of replacing them (c) Disburse payouts on the agreed schedule, except where the dual confirmation mechanism has paused or otherwise delayed disbursement (d) Confirm receipt of contributions promptly in the Platform's attestation flow (typically within 72 hours, after which auto-confirmation applies) (e) Maintain accurate records of every contribution received and every payout disbursed (f) Respond to member enquiries about contributions and disbursements within a reasonable time (g) Cooperate constructively with dispute resolution where disputes arise
4.2 Capacity and graduation
You must operate within the limits of your treasurer level. The Platform enforces these limits at circle creation and member-add operations. Attempting to circumvent the limits — for example, by recruiting a nominee to create a circle in your effective control — is prohibited.
4.3 Honest endorsement
As a treasurer, your endorsements of circle members carry particular weight in the Platform's credentialing system. Issue endorsements only where your direct experience supports them. Do not coordinate endorsements with other treasurers or with members in ways that produce credentials disconnected from actual performance.
4.4 Transparency in circle administration
You must not edit or attempt to edit past audit log entries. Where you need to correct an error, append a correction in accordance with the Platform's correction mechanism. The append-only audit log is enforced at multiple architectural layers; attempts to circumvent it are themselves logged and constitute a separate breach of this AUP.
You must not withhold material information from circle members. Specifically: members are entitled to see all events in the circle's audit log in real time; you may not gate access to the audit log, delay disclosure of events, or otherwise obscure circle activity from the membership.
5. Sponsorship-specific obligations
5.1 Sponsor obligations
If you sponsor another member's contributions:
(a) Use a payment method that is genuinely yours and that you have authority to charge (b) Ensure the payment method has sufficient funds for the duration of the sponsorship you have committed to (or, if you anticipate inability to continue, end the sponsorship through the Platform rather than allowing the payment to fail) (c) Do not use sponsorship to launder funds or to disguise the source of contributions (d) Do not coerce or pressure the recipient regarding the sponsorship's expectations
5.2 Recipient obligations
If you accept sponsorship:
(a) Use the sponsored contributions for participation in the circle they are designated for; do not divert them to other purposes (b) Cooperate with the sponsor's reasonable enquiries about the circle and the contributions made on your behalf (c) Do not coordinate with the sponsor to manipulate trust profile outcomes (d) Do not accept sponsorship from a sponsor whose source of funds you know or have reasonable grounds to believe is illegal
6. Lending coordination obligations
6.1 Borrowing in good faith
If you borrow through the LLP, CLP, or third-party lender pathway:
(a) Borrow only what you reasonably believe you can repay (b) Provide accurate information to the lending parties (whether your own circle's members in LLP, other circles in CLP, or a regulated partner in the third-party pathway) (c) Honour the repayment schedule agreed (d) If you encounter genuine difficulty in repayment, communicate with the lending parties as early as possible
6.2 Lending in good faith
If you participate in lending (as an LLP contributor, a member of a CLP-lending circle, or in any other capacity):
(a) Do not coordinate to extract preferential terms from borrowers in financial difficulty (b) Do not use the lending mechanisms to disguise the source or movement of funds (c) Vote on lending matters honestly and based on your genuine assessment
7. Endorsements and reputation
7.1 Endorsement honesty
Endorsements must:
(a) Reflect your genuine view of the endorsed member, formed from genuine experience with them (b) Be based on conduct you have personally observed (not on what others have told you) (c) Use language that is accurate and not misleading (d) Be revoked promptly if your view changes materially
7.2 Endorsement misconduct
The following conduct is prohibited:
(a) Trading endorsements ("I will endorse you if you endorse me") (b) Bulk-issuing endorsements without genuine consideration of each (c) Issuing endorsements coordinated to inflate a member's profile artificially (d) Issuing endorsements in exchange for payment, services, or other consideration
8. Enforcement
8.1 How Circlworld enforces the AUP
Circlworld operates a tiered enforcement process for breaches of this AUP. The tier applied to a particular case depends on the severity, the breadth of impact, and the member's history.
Tier 1 — Notice and remediation. For minor breaches (a single false attestation later corrected; a heated communication in a dispute thread; a missed step in the treasurer process), Circlworld will notify the member of the breach and request remediation. No restriction is applied unless the member fails to remediate.
Tier 2 — Feature restriction. For breaches that materially affect other members or the integrity of the Platform (repeated false attestations; serious harassment; failure of treasurer fiduciary obligations short of misappropriation), Circlworld may restrict specific features. The restriction is described to the member, with the reason and the path to restoration.
Tier 3 — Account suspension. For significant breaches (active manipulation of trust profiles; coordinated misconduct; suspected money laundering pending investigation; sanctions/PEP monitoring hits), Circlworld may suspend the account pending investigation. Suspension is communicated to the member to the extent permitted by applicable law (some AML/CFT matters require confidentiality).
Tier 4 — Account termination. For the most serious breaches (treasurer misappropriation of funds; identity fraud; criminal use of the Platform), Circlworld may terminate the account. Termination is recorded in the member's trust profile. The Terms of Service Clause 14.3 governs the termination process.
Referral to authorities. Where conduct involves suspected criminal activity, Circlworld may make Suspicious Transaction Reports to the Financial Investigations Division (Jamaica) or the National Crime Agency (UK), and may cooperate with criminal investigations in accordance with applicable law.
8.2 Due process
Before taking enforcement action at Tier 2 or above, Circlworld will:
(a) Investigate the matter, including reviewing the audit log, considering attestations from affected parties, and (where appropriate) requesting evidence from the member (b) Provide the member with notice of the alleged breach and the opportunity to respond (except where applicable law or the protection of other members requires immediate action) (c) Document the decision and the reasoning (d) Communicate the outcome to the member with the path to appeal where appropriate
Where Circlworld takes immediate action without prior notice (because of the urgency or because applicable law requires confidentiality), the member will be informed as soon as it is permissible to do so.
8.3 Appeals
A member subject to enforcement action may appeal:
(a) Internal appeal: to Circlworld's compliance team at compliance@circlworld.com, within 30 days of notification (b) External escalation: in accordance with the Complaints Handling Policy at circlworld.com/legal/complaints, which describes escalation to the relevant supervisory authority
The Terms of Service Clause 16 sets out the broader escalation framework.
8.4 Effect on Trust Profile
Enforcement events at Tier 2 or above are recorded in the affected member's trust profile to the extent appropriate. The intention is not punitive but informative — other members deciding whether to interact with the affected member can see the relevant facts. Recording is proportionate to the breach: a minor breach remediated promptly may not be recorded; a serious breach is.
Where a member successfully appeals an enforcement decision, the relevant trust profile entry is updated to reflect the corrected outcome.
9. Reporting AUP violations
9.1 How to report
If you observe conduct that you believe breaches this AUP, you can report it through:
(a) The in-app reporting mechanism in the relevant feature (e.g., in a circle's dispute flow, in a member's profile) (b) Email to abuse@circlworld.com (c) Email to compliance@circlworld.com for serious matters
You will receive an acknowledgment within 5 business days. Investigations typically conclude within 20 business days; complex matters may take longer.
9.2 Protection of reporters
A member who reports AUP violations in good faith will not be subject to adverse action for making the report. Reports are kept confidential to the extent practicable; in some cases the subject of the report will need to know the nature of the allegations to respond, but the identity of the reporter is protected unless they consent to disclosure or applicable law requires disclosure.
False reports (knowingly fabricated allegations made to harm another member) are themselves AUP breaches under Clause 3.2(d).
10. Responsible disclosure for security issues
If you discover a security vulnerability in the Platform, please report it through Circlworld's Responsible Disclosure Policy at circlworld.com/security or by email to security@circlworld.com.
Circlworld welcomes security research conducted in good faith and within the scope of the Responsible Disclosure Policy. Researchers who report vulnerabilities responsibly will not be subject to legal action under the Computer Misuse Act 1990 (UK) or the Cybercrimes Act 2015 (Jamaica) in respect of the in-scope research activity.
The Responsible Disclosure Policy describes the scope of authorised research, the procedure for reporting, the timeline for Circlworld's response, and the recognition framework for researchers.
11. Changes to this AUP
Circlworld may update this AUP from time to time. Material changes will be notified by email and through the Platform with at least 30 days' notice before they take effect. Continued use of the Platform after a material change takes effect constitutes acceptance.
The current version is always available at circlworld.com/legal/acceptable-use. Previous versions are archived.
12. Contact
For questions about this AUP:
- Reporting violations: abuse@circlworld.com (in-app reporting also available)
- Appeals and compliance: compliance@circlworld.com
- Security disclosures: security@circlworld.com
- General legal queries: legal@circlworld.com
Schedule 1 — Cross-references
This AUP integrates with other Circlworld documents and processes:
| Related document | Relationship | |------------------|--------------| | Terms of Service (circlworld.com/legal/terms) | The AUP is incorporated by reference into the Terms | | Privacy Notice (circlworld.com/legal/privacy) | Governs data processing in connection with AUP enforcement | | Risk Disclosure (circlworld.com/legal/risk-disclosure) | Describes the risks the AUP addresses | | Complaints Handling Policy (circlworld.com/legal/complaints) | Governs the complaints and appeals process | | Responsible Disclosure Policy (circlworld.com/security) | Governs security vulnerability reporting | | Trust Architecture (internal spec) | Describes the operational mechanisms that detect AUP violations |
Schedule 2 — Items Pending Finalisation
The following items in this AUP are placeholders and must be resolved before publication:
| Item | Location | Pending Decision | |------|----------|------------------| | Effective date | Header | Set at publication | | Last updated date | Header | Set at publication | | Version number | Header | Confirm 1.0 at publication | | Responsible Disclosure Policy | Clause 10 | Confirm policy is drafted and at circlworld.com/security | | Abuse reporting email setup | Clause 9.1 | Confirm abuse@circlworld.com is created and monitored | | In-app reporting mechanism | Clause 9.1 | Verify in-app reporting is implemented | | Tier definitions and thresholds | Clause 8.1 | Confirm operational definitions in compliance team's enforcement playbook | | Specific consumer credit law references | (where applicable) | Verify current statute references |
End of Acceptable Use Policy draft.
Document prepared: May 2026 Prepared by: Drafted with AI assistance; requires professional legal review in both jurisdictions before publication Next step: Review by Drew St'Clair in dual capacity as Barrister of England & Wales and Attorney-at-Law of Jamaica; subsequent review by external counsel; verification that operational definitions (Tier 1-4 enforcement, etc.) are consistent with the compliance team's enforcement playbook