Privacy Policy
Effective date: July 15, 2024
At Circleback AI, Inc. (“Circleback”), we recognize the trust you place in us when using our Services and take your privacy seriously. Please read this Privacy Policy to learn how we treat your personal data. By using or accessing our Services in any manner, you acknowledge that you accept the practices and policies outlined below, and you hereby consent that we will collect, use and share your information as described in this Privacy Policy.
Remember that your use of Circleback’s Services is at all times subject to our Terms of Service. Any terms we use in this Policy without defining them have the definitions given to them in the Terms of Service.
What this Privacy Policy Covers
This Privacy Policy covers how we treat Personal Data that we gather when you access or use our Services. “Personal Data” means any information that identifies or relates to a particular individual and also includes information referred to as “personally identifiable information” or “personal information” under applicable data privacy laws, rules or regulations. This Privacy Policy does not cover the practices of companies we don’t own or control or people we don’t manage.
Personal Data
Categories of Personal Data We Collect
This list details the categories of Personal Data that we may collect:
Profile or Contact Data
Examples of Personal Data We Collect
First and last name
Email
Job title
Company
Categories of Third Parties With Whom We Share this Personal Data
Service Providers
Parties You Authorize, Access or Authenticate
Payment Data
Examples of Personal Data We Collect
Payment card type
Last 4 digits of payment card
Billing address, phone number, and email
Categories of Third Parties With Whom We Share this Personal Data
Service Providers (specifically our payment processing partner)
Meeting Data
Examples of Personal Data We Collect
Meeting recording
Meeting transcript
Meeting calendar event information
Circleback’s use and transfer of information received from Google APIs to any other app adheres to Google API Services User Data Policy, including the Limited Use requirements.
Categories of Third Parties With Whom We Share this Personal Data
Service Providers (including AI model and transcription providers, strictly on a transactional basis for providing the Services)
Device/IP Data
Examples of Personal Data We Collect
IP address
Device ID
Domain server
Type of device/operating system/browser used to access the Services
Categories of Third Parties With Whom We Share this Personal Data
Service Providers
Parties You Authorize, Access or Authenticate
Web Analytics
Examples of Personal Data We Collect
Web page interactions
Referring webpage/source through which you accessed the Services
Non-identifiable request IDs
Statistics associated with the interaction between device or browser and the Services
Categories of Third Parties With Whom We Share this Personal Data
Service Providers
Parties You Authorize, Access or Authenticate
Social Network Data
Examples of Personal Data We Collect
Email
Phone number
User name
IP address
Device ID
Categories of Third Parties With Whom We Share this Personal Data
Service Providers
Parties You Authorize, Access or Authenticate
Other Identifying Information that You Voluntarily Choose to Provide
Examples of Personal Data We Collect
Identifying information in emails or letters you send us
Categories of Third Parties With Whom We Share this Personal Data
Service Providers
Business Partners
Parties You Authorize, Access or Authenticate
Categories of Sources of Personal Data
We collect Personal Data about you from the following categories of sources:
You
When you provide such information directly to us.
When you create an account or use our interactive tools and Services.
When you voluntarily provide information in free-form text boxes through the Services or through responses to surveys or questionnaires.
When you send us an email or otherwise contact us.
When you use the Services and such information is collected automatically.
Through Cookies (as defined and described further below).
If you use a location-enabled browser, we may receive information about your location and device, as applicable.
If you download and install certain applications and software we make available, we may receive and collect information transmitted from your computing device for the purpose of providing you the relevant Services, such as information regarding when you are logged on and available to receive updates or alert notices.
Third Parties
Vendors
We may use analytics providers to analyze how you interact and engage with the Services, or third parties may help us provide you with customer support.
Our Commercial or Business Purposes for Collecting Personal Data
Providing, Customizing and Improving the Services
Creating and managing your account or other user profiles.
Processing orders or other transactions; billing.
Providing you with the products, services or information you request.
Meeting or fulfilling the reason you provided the information to us.
Providing support and assistance for the Services.
Improving the Services, including testing, research, internal analytics and product development.
Personalizing the Services, website content and communications based on your preferences.
Doing fraud protection, security and debugging.
Carrying out other business purposes stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws.
Marketing the Services
Marketing and selling the Services.
Corresponding with You
Responding to correspondence that we receive from you, contacting you when necessary or requested, and sending you information about Circleback or the Services.
Sending emails and other communications according to your preferences or that display content that we think will interest you.
Meeting Legal Requirements and Enforcing Legal Terms
Fulfilling our legal obligations under applicable law, regulation, court order or other legal process, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities.
Protecting the rights, property or safety of you, Circleback or another party.
Enforcing any agreements with you.
Responding to claims that any posting or other content violates third-party rights.
Resolving disputes.
We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated or incompatible purposes without providing you notice.
How We Share Your Personal Data
We disclose your Personal Data to the categories of service providers and other parties listed in this section. Depending on state laws that may be applicable to you, some of these disclosures may constitute a “sale” of your Personal Data.
Service Providers. These parties help us provide the Services or perform business functions on our behalf. They include:
Hosting, technology and communication providers.
AI model providers.
Transcription providers.
Security and fraud prevention consultants.
Analytics providers.
Support and customer service vendors.
Product fulfillment and delivery providers.
Payment processors.
Our payment processing partner collects your voluntarily-provided payment card information necessary to process your payment.
Please see Stripe’s terms of service and privacy policy for information on its use and storage of your Personal Data.
Business Partners. These parties partner with us in offering various services. They include:
Businesses that you have a relationship with.
Companies that we partner with to offer joint promotional offers or opportunities.
Parties You Authorize, Access or Authenticate
Third parties you access through the services.
Social media services.
Other users.
Legal Obligations
We may share any Personal Data that we collect with third parties in conjunction with any of the activities set forth under “Meeting Legal Requirements and Enforcing Legal Terms” in the “Our Commercial or Business Purposes for Collecting Personal Data” section above.
Business Transfers
All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part). Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.
Tracking Tools and Opt-Out
The Services use cookies and similar technologies such as pixel tags, web beacons, clear GIFs and JavaScript (collectively, “Cookies”) to enable our servers to recognize your web browser, tell us how and when you visit and use our Services, analyze trends, learn about our user base and operate and improve our Services. Cookies are small pieces of data– usually text files – placed on your computer, tablet, phone or similar device when you use that device to access our Services. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s). Please note that because of our use of Cookies, the Services do not support “Do Not Track” requests sent from a browser at this time.
We use the following types of Cookies:
Essential Cookies. Essential Cookies are required for providing you with features or services that you have requested. For example, certain Cookies enable you to log into secure areas of our Services. Disabling these Cookies may make certain features and services unavailable.
Functional Cookies. Functional Cookies are used to record your choices and settings regarding our Services, maintain your preferences over time and recognize you when you return to our Services. These Cookies help us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
Performance/Analytical Cookies. Performance/Analytical Cookies allow us to understand how visitors use our Services. They do this by collecting information about the number of visitors to the Services, what pages visitors view on our Services and how long visitors are viewing pages on the Services. Performance/Analytical Cookies also help us measure the performance of our advertising campaigns in order to help us improve our campaigns and the Services’ content for those who engage with our advertising.
You can decide whether or not to accept Cookies through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit our website and some of the Services and functionalities may not work.
To explore what Cookie settings are available to you, look in the “preferences” or “options'' section of your browser’s menu. To find out more information about Cookies, including information about how to manage and delete Cookies, please visit allaboutcookies.org.
Data Security and Retention
We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.
We retain Personal Data about you for as long as you have an open account with us or as otherwise necessary to provide you with our Services. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.
Personal Data of Children
We do not knowingly collect or solicit Personal Information from anyone under the age of 13. If you are under 13, please do not attempt to register for the Services or send any Personal Information about yourself to us. If we learn that we have collected Personal Information from a child under age 13, we will delete that information as quickly as possible. If you believe that a child under 13 may have provided us Personal Information, please contact us at support@circleback.ai.
European Union Data Subject Rights
Circleback complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) as set forth by the U.S. Department of Commerce. Circleback has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF. Circleback is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC) in relation to its compliance with the EU-U.S. DPF Principles. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) Program, and to view our certification, please visit www.dataprivacyframework.gov.
In compliance with the EU-U.S. DPF, Circleback commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (DPAs) with regard to unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF.
Personal Data We Collect
The “Categories of Personal Data We Collect” section above details the Personal Data that we collect from you.
Personal Data Use and Processing Grounds
The “Our Commercial or Business Purposes for Collecting Personal Data” section above explains how we use your Personal Data.
Sharing Personal Data
The “How We Share Your Personal Data” section above details how we share your Personal Data with third parties.
Data Subject Rights
You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email us at support@circleback.ai.
Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.
Access: You can request more information about the Personal Data we hold about you and request a copy of such Personal Data. You can also access certain of your Personal Data by logging on to your account.
Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. You can also correct some of this information directly by logging on to your account.
Erasure: You can erase some or all of your Personal Data from our systems by logging on to your account.
Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Services.
Portability: You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.
Objection: You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes, such as for direct marketing purposes.
Restriction of Processing: You can ask us to restrict further processing of your Personal Data.
Binding Arbitration: Under certain conditions, you may invoke binding arbitration for complaints regarding Circleback's compliance with the DPF Principles. To invoke binding arbitration, you must deliver notice to Circleback and follow the procedures and be subject to the conditions set forth in Annex I of the DPF Principles.
Transfers of Personal Data
The Services are hosted and operated in the United States (“U.S.”) through Circleback and its service providers, and if you do not reside in the U.S., laws in the U.S. may differ from the laws where you reside. By using the Services, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to Circleback in the U.S. and will be hosted on U.S. servers, and you authorize Circleback to transfer, store and process your information to and in the U.S., and possibly other countries. You hereby consent to the transfer of your data to the U.S. pursuant to: (i) a data processing agreement incorporating standard data protection clauses promulgated by the European Commission, a copy of which can be obtained at https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32010D0087, (ii) binding corporate rules for data protection that align with the U.S.-EU DPF requirements, or (iii) adherence to an industry- or technology-specific approved code of conduct blessed by the European Commission.
Circleback remains responsible for personal data received under the EU-U.S. Data Privacy Framework that is subsequently transferred to third parties and makes reasonable efforts to ensure third parties handle customer data in compliance with DPF Principles.
Inquiries and Complaints
In compliance with the EU-U.S. DPF, Circleback commits to resolve DPF Principles-related complaints about our collection and use of your personal information. EU individuals with inquiries or complaints regarding our handling of personal data received in reliance on the EU-U.S. DPF should first contact Circleback at support@circleback.ai.
Changes to this Privacy Policy
We’re constantly trying to improve our Services, so we may need to change this Privacy Policy from time to time, but we will alert you to any such changes by placing a notice on the Circleback website, by sending you an email and/or by some other means. Please note that if you’ve opted not to receive legal notice emails from us (or you haven’t provided us with your email address), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes. Use of information we collect is subject to the Privacy Policy in effect at the time such information is collected.
Contact Information
If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Data or your choices and rights regarding such collection and use, please do not hesitate to contact us at support@circleback.ai.