Privacy Policy

1. Our commitment

Circl is built on the principle of data minimisation: we collect only what we need to operate the service and meet regulatory obligations. Every category of data we hold is documented, justified, and visible to you.

2. Information we collect

2.1 Account information

Name, email, phone number — required to identify you and operate your account.

2.2 KYC documents

Government-issued ID, address verification — required by law and the Bank of Jamaica for circle participation. Stored encrypted at rest.

2.3 Financial activity

Contributions, payouts, votes cast, proposals authored — recorded for circle audit trails and your transaction history.

2.4 Trust and behavioural data

On-time payment history, voting participation, dispute involvement — used to compute your informational trust score.

2.5 Device and access logs

IP address, browser, device information, login times — used for security and audit purposes only.

3. How we use your information

• To operate your account and your circles
• To verify your identity and meet regulatory obligations
• To compute your informational trust score
• To send transactional notifications (votes, payouts, disputes)
• To detect fraud and security threats
• To comply with court orders, regulatory requests, or AML investigations
• For analytics that improve the platform — only if you've granted consent

4. Your rights

You have the right to:

• Access all data we hold about you (visit My Data)
• Export your data in machine-readable format (JSON download)
• Correct inaccurate information
• Delete your account permanently (visit Delete account)
• Manage consent for non-essential data uses (visit Privacy controls)
• Withdraw consent at any time for non-essential purposes

5. Data sharing

We share data only when:

• You explicitly initiate an action that requires it (e.g. KYC verification with our identity provider)
• Required by law, court order, or regulatory request
• Necessary to detect or prevent fraud

We do not sell your data. Ever.

6. Data retention

We keep your data only as long as needed for the purpose collected. KYC documents are retained while your account is active and for a minimum period required by law thereafter. Audit trail entries you authored are retained indefinitely (anonymised on deletion) for regulatory compliance.

7. Security

We use industry-standard security: HTTPS for all traffic, encryption at rest for sensitive fields, role-based access control, and immutable audit logs. We never have access to your private keys or your funds.

8. International transfers

Diaspora circles involve cross-border data movement. We ensure equivalent protection wherever your data is processed, in alignment with Jamaica's data protection framework.

9. Contact

For privacy questions or to exercise your rights, contact us via the contact form.