Consumer Protection Policy

This Consumer Protection Policy sets out Circlworld's commitment to fair treatment of consumers using our platform. It explains the standards we apply, the protections you can expect, and how we handle situations where things go wrong.

This Policy is in addition to your statutory consumer protection rights, which we do not contract out of. Where this Policy provides protections beyond your statutory rights, those additional protections apply. Where your statutory rights provide more than this Policy, your statutory rights govern.

1. Scope and application

1.1 Who this Policy applies to

This Policy applies to:

All members of the Circlworld platform using personal (non-business) accounts
Free tier members and Pro tier members
Consumers in the Caribbean, the United Kingdom, the United States (where service is available), and other jurisdictions as expansion proceeds

This Policy applies less directly to:

Business tier organisations — protected by commercial contract law rather than consumer protection
Enterprise partners (banking and lending partners) — governed by partnership agreements
Treasurer partners in their capacity as independent contractors — protected by the Treasurer Partner Agreement and applicable employment/contractor law

Treasurer partners also retain consumer status when participating in circles as members.

1.2 Legal frameworks

This Policy is designed to be consistent with consumer protection law in:

United Kingdom: Consumer Rights Act 2015, Consumer Protection from Unfair Trading Regulations 2008, Financial Conduct Authority Consumer Duty (where applicable), Equality Act 2010
Jamaica: Consumer Protection Act 2005, Fair Trading Commission Act, Microcredit Act 2021 (where applicable)
United States: State-by-state consumer protection laws as expansion occurs
Caribbean diaspora markets: Applicable consumer protection in each jurisdiction

2. Our consumer protection principles

We commit to seven principles in all dealings with consumers.

2.1 Fairness

We treat all consumers fairly regardless of:

Race, ethnicity, or national origin
Gender or gender identity
Sexual orientation
Religion or belief
Age (subject to 18+ minimum)
Disability
Socioeconomic status
Country of residence (within our service areas)
Diaspora status
Any other characteristic protected under applicable equality law

2.2 Transparency

We provide clear, honest, and complete information about:

Our products and services
Pricing and fees
The structure of community savings (custody, risks, your responsibilities)
Your rights and how to exercise them
Limitations of our service

2.3 Honest dealing

We do not engage in:

False or misleading marketing
High-pressure sales tactics
Hidden fees or unexpected charges
Aggressive collection practices
Manipulative design (dark patterns)
Misrepresentation of benefits or risks

2.4 Suitability

We aim to provide services suitable for the consumers we serve:

Our marketing accurately describes who the platform is for
We provide information to help you assess whether Circlworld is right for you
We do not pressure consumers into features that are not suitable for them
We do not target vulnerable consumers with inappropriate offers

2.5 Vulnerable customer support

We recognise that some consumers are in vulnerable circumstances and may need additional support. We:

Train staff to recognise indicators of vulnerability
Provide accessibility accommodations (see Accessibility Statement)
Apply additional care in communications with potentially vulnerable consumers
Refer to appropriate support services where relevant

2.6 Easy redress

When things go wrong, we make it easy for you to:

Raise a complaint
Get a response
Receive remedies where appropriate
Escalate externally if you are not satisfied

2.7 Continuous improvement

We treat consumer feedback as valuable input:

We track complaints by category and severity
We use root cause analysis to identify systemic issues
We update products, processes, and policies in response to feedback
We report on consumer experience in annual transparency reports (commencing Year 2)

3. Clear and honest marketing

3.1 What we commit to

Our marketing and platform copy:

Accurately describes what Circlworld does
Does not promise outcomes we cannot deliver
Does not exaggerate benefits
Does not minimise risks
Clearly distinguishes the operating company (Circlworld) from community savings groups (circles)
Discloses Circlworld's non-custodial position prominently

3.2 Specific representations

When we make specific representations:

About earnings potential (in Treasurer Partner marketing):

Earnings figures are illustrative based on stated assumptions
We disclose the assumptions
We do not guarantee any specific earnings outcome
Past or illustrative earnings do not guarantee future results

About participation outcomes (member marketing):

Trust Reports document participation; they do not guarantee credit approval
Acceptance by lenders is at lenders' discretion
Saving discipline is real, but financial outcomes depend on many factors

About AI capability:

We do not overstate what AI can do
We disclose AI limitations
We do not represent AI as human or as a substitute for professional advice

3.3 What we do not do

We do not:

Use deceptive imagery or testimonials
Manufacture social proof
Make comparative claims without basis
Imply regulatory approval or endorsement we do not have
Use scarcity manipulation ("only 5 spots left!" when not true)
Use false urgency ("offer expires tonight!" when not true)
Pressure consumers to upgrade or take actions

4. Clear pricing

4.1 Transparent fees

All fees are disclosed prominently before you commit:

Pro subscription: £29/month (£290/year for annual) — visible at signup
Coordination fees: 2.0%/1.5%/1.0% by tier, with £35/circle/month cap and free exemption for small circles — visible at circle joining
Trust Reports: £12.99 Basic / £19.99 Enhanced for free users; included in Pro — visible at point of purchase
AI Assist: £3 Basic / £7 Enhanced / £35 Enterprise per query for non-included tiers — visible at point of use
LLP/CLP documentation drafting: £15/document — visible at point of order
Other fees: disclosed at the relevant point

4.2 No hidden fees

We commit:

No charges we have not disclosed in advance
No fees that activate after a period of free use (unless clearly disclosed)
No fees for exercising consumer rights (data access, correction, etc.)
No early termination fees on monthly subscriptions
No reactivation fees for closed accounts

4.3 Fee changes

If we change fees:

30 days' notice for existing users
Email notification
In-platform notification
The change applies prospectively — existing commitments at the current rate are honoured

You can cancel before the change takes effect without penalty.

4.4 Refunds

We provide refunds in the following circumstances:

First 14 days of Pro subscription — full refund, no questions asked
Service unavailability — pro-rata refund for periods of significant unavailability
Material breach — full refund where we have materially breached our obligations
Charge errors — full refund of any incorrectly charged amount, plus interest where required by law
Statutory cooling-off — as required by applicable law

Refunds are processed within 14 days of approval. Refunds go to the original payment method where possible.

5. Disclosure of non-custodial structure

5.1 Why this matters

A fundamental fact about Circlworld that consumers must understand: Circlworld does not hold your money. Members contribute through their own bank accounts. Funds are held by the members themselves, in a dedicated Circle account, or by a partner institution — never by Circlworld and never by the Treasurer's personal account. The Treasurer governs the rotation and records each contribution; they do not custody member funds.

This structure carries specific implications that we disclose clearly:

Your treasurer is responsible for handling contributions and disbursements
If your treasurer misuses funds, the recourse is to the treasurer (civil and possibly criminal), not to Circlworld
Circlworld is not a deposit-taking institution; your contributions are not protected by deposit insurance schemes (e.g., UK FSCS, Jamaica Deposit Insurance Scheme)
The protections that apply to bank deposits do not apply to circle contributions

5.2 Where this is disclosed

This disclosure appears in:

The Risk Disclosure (linked from settings and signup)
The circle joining flow (before you commit to joining)
The Terms of Service
The Pro upgrade flow (when sponsorship is offered)
The treasurer enrolment flow (when becoming a treasurer)

5.3 What we do to mitigate risk

The protections we provide:

Treasurer KYC verification before they administer circles
Treasurer Levels and graduation system (new treasurers limited in scale)
Dual-attestation contribution flow (both sender and receiver attest)
Transparency dashboard (every action visible to all circle members)
Append-only audit log (cryptographically signed, tamper-evident)
Dual confirmation payout (for circles electing it)
Dispute resolution process
Treasurer performance metrics and Community Health monitoring

These reduce risk substantially. They do not eliminate it. Community savings has always involved trust in the treasurer; Circlworld makes that trust observable and accountable.

6. Suitability and right product

6.1 Is Circlworld right for you?

We provide information to help you assess whether Circlworld suits your situation:

The About / Circles Overview page explains how pardna and equivalent practices work
The Risk Disclosure explains what can go wrong
The Treasurer FAQ explains the treasurer role for those considering it
The Pricing page explains all subscription and service tiers

6.2 Free tier first

Most members do not need Pro. We:

Make the free tier available as the default
Do not bury the free tier
Allow downgrade from Pro to free without penalty
Do not pressure free users to upgrade

Pro is genuinely useful for cross-border participation, sponsorship, and members who want their Trust Reports as portable credentials. It is not necessary for normal circle participation.

6.3 Treasurer suitability

If you are considering becoming a treasurer:

We provide the Treasurer Partner Agreement at enrollment
We require acknowledgment of fiduciary obligations
We provide jurisdiction-specific tax guidance
We do not pressure you into the role
You can leave the Programme with 30 days' notice

The Programme provides meaningful income at scale but takes time to build. We do not represent it as a quick income source.

6.4 When Circlworld might not be right for you

We disclose openly that Circlworld is not appropriate if:

You are under 18
You reside in a restricted jurisdiction (see Restricted Jurisdictions)
You cannot commit to regular contributions (circles require reliable participation)
You do not have a network of people you would join a circle with (the matching pathway helps but is not a substitute for community)
You are seeking insurance or guaranteed deposit-like protection (Circlworld does not provide this)
You require regulated investment advice (Circlworld provides information, not advice)

7. Vulnerable consumers

7.1 Who may be vulnerable

A consumer may be vulnerable due to:

Health vulnerabilities — physical or mental health conditions affecting their interactions
Life event vulnerabilities — bereavement, divorce, job loss, immigration status uncertainty, domestic violence
Resilience vulnerabilities — low income, debt, single-income households
Capability vulnerabilities — language barriers, low numeracy or financial literacy, low digital skills
Age-related vulnerabilities — particularly elderly users

These categories are not mutually exclusive. A given individual may be in multiple categories or move between them.

7.2 Our approach

We:

Train staff to recognise indicators of vulnerability
Apply enhanced care in communications with potentially vulnerable consumers
Avoid pressure tactics in any context
Provide alternative formats and channels where standard ones are difficult
Refer to appropriate support services where relevant
Do not market upgrades or additional features to consumers showing distress indicators
Pause or slow processes where consumers may need additional time

7.3 What we do not do

We do not:

Take advantage of vulnerable circumstances
Withhold information from consumers based on assumed inability to understand
Treat vulnerable consumers paternalistically
Restrict their rights without their consent
Use vulnerability as a basis for differential treatment in pricing or terms

7.4 What you can do

If you are in vulnerable circumstances and need accommodation:

Tell us — support@circlworld.com or Settings → Support
Request a trusted person to be authorised on your account (subject to verification)
Pause activity where helpful
Access our Resource Hub for additional information
Use our Accessibility accommodations

We do not require you to disclose details of your vulnerability. A simple request for accommodation is sufficient.

8. Information and decision support

8.1 What we provide

We help consumers make informed decisions through:

Plain-language explanations of how the platform works
The Risk Disclosure (linked from settings and key flows)
Educational content on community savings (the About page, Treasurer Resource Hub)
AI Assist for individual questions (subject to information-not-advice boundary)
Customer support for personal queries

8.2 What we do not provide

We do not provide:

Regulated financial advice — we are not authorised to give financial advice
Tax advice — consult a qualified tax adviser
Legal advice — consult a qualified lawyer
Investment advice — we do not offer investments
Insurance — we do not provide insurance

For these, we will refer you to appropriate qualified professionals. We do not refer you to specific firms in exchange for fees.

8.3 Free tier access

Free tier members have access to:

Full platform functionality for circle participation
Customer support
Educational content
Risk Disclosure and policy documents
Basic Trust Reports (£12.99 per report)

We do not paywall essential information needed to make informed decisions.

9. Service quality

9.1 Service standards

We commit to:

Platform availability — 99% uptime as a target (we monitor and report)
Customer support response — within 48 hours for free users, faster for Pro, faster still for Business and Enterprise
Dispute resolution — initial response within 5 business days, substantive response within 20 business days
Subject rights requests — within 30 days
Complaint responses — within 20 business days

9.2 Service interruption

If the platform is significantly unavailable:

We provide information about the outage
We provide estimated restoration time
We pro-rata refund subscription periods affected by significant outage
We continue communication via email if platform-based notifications are unavailable

9.3 Service termination

If we discontinue the service:

We provide at least 90 days' notice
We facilitate data export
We ensure Trust Reports remain verifiable (see Risk Disclosure for continuity framework)
We refund unused subscription periods
We do not abandon active circles — wind-down support is provided

10. Treasurer-administered circles

10.1 Special considerations

Because treasurers hold funds, consumer protection considerations specific to circles include:

Disclosure of treasurer identity and standing before you commit
Visibility of treasurer's performance record
Right to leave a circle (subject to cycle dynamics)
Dispute resolution where the treasurer is the subject

10.2 Treasurer disclosures to members

Before you commit to a circle, you see:

Treasurer's name and verification level
Treasurer's Identity Level (Community Builder, Circle Leader, etc.)
Treasurer's circle history (circles administered, completion rate, dispute rate)
New treasurer status if applicable
Treasurer Partner status (treasurer is enrolled in the CGP)
The treasurer's interest in your Pro upgrade (Activation Bonus + Residual)

We require these disclosures so you can make an informed choice.

10.3 Your right to leave a circle

You can leave a circle by request to the treasurer. Acceptance of your departure depends on:

Where you are in the rotation
Whether you have received your payout yet
Other members' agreement to absorb your position
Replacement member availability

If the treasurer or circle declines to release you mid-cycle, you have remedies through:

The dispute resolution process
The complaints process
External venues (small claims court, consumer protection authority)

10.4 If your treasurer misuses funds

If you believe your treasurer has misused contributed funds:

Document what happened — the audit log preserves evidence
Raise it with the circle — other members may help resolve
Initiate a dispute through the platform — formal process
Contact Circlworld at compliance@circlworld.com
Consider legal action — civil suit against the treasurer; potentially criminal complaint
Report to authorities where appropriate (police, financial crimes unit)

Circlworld supports you through this process by providing audit log evidence, dispute mediation, and (in serious cases) Programme suspension of the treasurer.

We acknowledge: while Circlworld provides robust infrastructure to detect and address misuse, we are not the custodian of the funds and cannot guarantee recovery if a treasurer absconds. This is the structural reality of pardna and similar community savings practices, made transparent through our infrastructure rather than created by it.

11. Subscription cancellation

11.1 Right to cancel

You can cancel your Pro subscription at any time:

Settings → Subscription → Cancel
Email billing@circlworld.com
No reasons required
No cancellation fees

11.2 What happens on cancellation

When you cancel:

Pro features remain available until the end of your current billing period
You revert to free tier at the next billing cycle
Your data is retained (account is not closed)
Your circles continue to operate (cancellation does not affect existing circles)
Trust Reports you have already shared remain valid

11.3 14-day refund period

For new Pro subscriptions, you have a 14-day cooling-off period during which you can cancel for a full refund. This applies regardless of platform usage during those 14 days.

11.4 Account closure

To close your account entirely (different from subscription cancellation):

Settings → Account → Close Account
Email support@circlworld.com
Subject to wind-down of active circle participation (we cannot close your account mid-cycle without notice to other members)

Data retention after closure follows our Data Protection Policy Section 10. The full Account Closure Policy (when published) sets out the detailed procedure.

12. Complaints and redress

12.1 How to complain

See our Complaints Handling Policy for the full process. In brief:

Online: circlworld.com/legal/complaints
Email: complaints@circlworld.com
Platform: Settings → Support → Raise a Complaint
Post: to the relevant Circlworld entity

12.2 Timelines

Acknowledgment: within 5 business days
Substantive response: within 20 business days
Complex cases: up to 40 business days (with notice)

12.3 Remedies available

Where a complaint is upheld, available remedies include:

Apology and explanation
Refund of fees
Reversal of decisions
Service-level remediation
Compensation for direct losses caused by our error
Process improvements to prevent recurrence

We do not offer compensation for indirect or consequential losses unless required by law.

12.4 External escalation

If our response does not satisfy you, you can escalate externally. See the Complaints Handling Policy Section 7 for details. The principal authorities:

United Kingdom: ICO (data), Trading Standards (consumer), Financial Ombudsman Service (where applicable), Citizens Advice
Jamaica: Consumer Affairs Commission, Office of the Information Commissioner, Fair Trading Commission
United States: State Attorney General, FTC, CFPB (where applicable)
Other jurisdictions: as applicable

12.5 Class actions and group remedies

Where multiple consumers are affected by a similar issue, we may consider:

Bulk remediation (the same remedy provided to all affected)
Process changes that benefit all users
Group communication explaining the issue and resolution

We respect consumers' rights to bring individual or class actions and do not contract out of these rights.

13. Marketing communications

We send transactional communications (account, service, security) without separate consent — these are part of platform operation.

For marketing communications (newsletters, feature announcements, promotional content), we obtain separate consent.

13.2 Easy opt-out

Every marketing communication includes a one-click unsubscribe link. You can also manage preferences at Settings → Privacy → Communication Preferences.

Unsubscribe is honoured immediately. We do not require reasons or attempt to re-engage you after unsubscribe.

13.3 Frequency

We are conservative with marketing frequency. Typical cadence:

Monthly newsletter (consent-based)
Feature announcements (transactional, all users)
Occasional partner offers (consent-based, opt-in)

We do not send daily marketing.

13.4 No spam

We do not:

Sell your contact details to third parties
Allow third parties to market to you through our channels
Send unsolicited offers from partners (unless you have opted in to partner offers)
Use deceptive subject lines
Pretend marketing is transactional

14. Equality and non-discrimination

14.1 Our commitment

We do not discriminate against consumers on the basis of:

Race, ethnicity, or national origin
Gender or gender identity
Sexual orientation
Religion or belief
Age (subject to 18+ minimum)
Disability
Marital status
Pregnancy or maternity
Socioeconomic status
Any other protected characteristic under applicable equality law

14.2 Where this applies

This commitment applies in:

Account approval and KYC
Customer support
Treasurer Partner Program approval
Pricing and tier access
Dispute resolution
Marketing and communications

14.3 Accessibility

We provide accessibility accommodations as set out in our Accessibility Statement. If you need accommodations, request via accessibility@circlworld.com.

14.4 Equality complaints

If you believe you have experienced discrimination, raise it through our complaints process. We investigate equality complaints with particular care.

15. Cross-border participation

15.1 Diaspora considerations

Many Circlworld members participate cross-border (diaspora supporting members in countries of origin, or members in countries of origin supported by diaspora). We:

Disclose cross-border-specific considerations at participation
Disclose Travel Rule applicability for cross-border transfers above thresholds
Disclose foreign exchange considerations
Disclose jurisdiction-specific limits

15.2 Limited recourse across borders

You should know:

Consumer protection in one country may not apply to actions in another
Enforcement of judgments across borders can be difficult
Currency and exchange-rate risk is your responsibility

We disclose these limitations where relevant.

15.3 Our cross-border commitments

Regardless of geography, we commit:

The same standards of fair treatment
The same complaints process
Honouring statutory rights of your country of residence
Cooperation with cross-border regulatory inquiries

We disclose that the treasurer earns from your upgrade
We disclose the approximate financial interest
We disclose that this does not change the Pro price
We disclose that the upgrade is optional

The disclosure is presented clearly, not buried in terms.

16.3 What treasurers must do

Treasurer Partners are required (Treasurer Partner Agreement, Clause 7) to:

Disclose their earning interest when recommending Pro upgrade
Not pressure members to upgrade
Not misrepresent Pro features
Not use Activation Bonus motivations to recruit unsuitable members

Violations are reported through the complaints process and may result in Programme suspension.

17. Reviews and testimonials

17.1 If we feature you

If we feature you in our marketing (testimonials, case studies, photographs):

We obtain explicit consent before publication
We provide a draft for your review
You can withdraw consent and we will remove published content (subject to reasonable lead time)
We do not pay you for featuring unless explicitly disclosed
We do not pressure you to feature in our marketing

17.2 Our published reviews

When we publish testimonials or reviews:

We do not edit content in ways that change the substance
We disclose if the reviewer is a Circlworld employee, partner, or relative
We do not manufacture or fabricate reviews
We honour the reviewer's right to update or withdraw

18. Updates to this Policy

18.1 Material changes

For material changes affecting your rights:

30 days' notice
Email notification to affected users
In-platform notification
Updated date and version

You can cancel your relationship with Circlworld before material changes take effect without penalty.

18.2 Minor changes

For minor changes (clarifications, formatting):

Rolling updates
Updated date at the top of this page

General consumer questions: support@circlworld.com
Complaints: complaints@circlworld.com
Privacy: privacy@circlworld.com
Accessibility: accessibility@circlworld.com
Compliance: compliance@circlworld.com
Platform: Settings → Support
Post: to the relevant Circlworld entity

19.2 External consumer protection authorities

United Kingdom: Citizens Advice (citizensadvice.org.uk); Trading Standards (via your local council); Competition and Markets Authority (gov.uk/cma)
Jamaica: Consumer Affairs Commission (cac.gov.jm)
United States: Federal Trade Commission (ftc.gov); state Attorney General
Other: as applicable

This Consumer Protection Policy is read together with our Terms of Service, Privacy Notice, Data Protection Policy, Risk Disclosure, Complaints Handling Policy, Accessibility Statement, and other applicable policies. Where there is any inconsistency, the most consumer-protective provision applies.