Privacy Policy (United States)

This privacy policy applies between you, the User of this Website and Circular Concierge Ltd, the owner and provider of this Website. Circular Concierge Ltd takes the privacy of your information very seriously. This privacy policy applies to our use of any and all Data collected by us or provided by you in relation to your use of the Website. This privacy policy should be read alongside, and in addition to, our Terms and Conditions, which can be found in the footer.

Definitions and Interpretation

  1. In this privacy policy, the following definitions are used:

Data: collectively all information that you submit to Circular Concierge Ltd via the Website. This definition incorporates, where applicable, the definitions provided in applicable Privacy Laws;

Cookies: a small text file placed on your computer by this Website when you visit certain parts of the Website and/or when you use certain features of the Website. Details of the cookies used by this Website are set out in the clause below (Cookies);

Privacy Laws: any applicable law relating to the processing of personal information, including but not limited to state privacy laws such as the California Consumer Privacy Act (CCPA), California Privacy Rights Act (CPRA), Virginia Consumer Data Protection Act (VCDPA), Colorado Privacy Act (CPA), and other applicable US federal and state privacy regulations;

Circular Concierge Ltd: we or us, Circular Concierge Ltd, a company incorporated in England and Wales with registered number 12946664 whose registered office is at 30 Greyhound Road, London, N17 6XW;

User or you: any third party that accesses the Website and is not either (i) employed by Circular Concierge Ltd and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to Circular Concierge Ltd and accessing the Website in connection with the provision of such services; and

Website: the website that you are currently using, and any sub-domains of this site unless expressly excluded by their own terms and conditions.

  1. In this privacy policy, unless the context requires a different interpretation:

A. the singular includes the plural and vice versa;

B. references to sub-clauses, clauses, schedules or appendices are to sub-clauses, clauses, schedules or appendices of this privacy policy;

C. a reference to a person includes firms, companies, government entities, trusts and partnerships;

D. "including" is understood to mean "including without limitation";

E. reference to any statutory provision includes any modification or amendment of it;

F. the headings and sub-headings do not form part of this privacy policy.

Scope of This Privacy Policy

  1. This privacy policy applies only to the actions of Circular Concierge Ltd and Users with respect to this Website. It does not extend to any websites that can be accessed from this Website including, but not limited to, any links we may provide to social media websites.

  2. For purposes of the applicable Privacy Laws, Circular Concierge Ltd is the "business" or "controller". This means that Circular Concierge Ltd determines the purposes for which, and the manner in which, your Data is processed.

Data Collected

  1. We may collect the following Data, which includes personal information, from you:

A. name;

B. gender;

C. profession;

D. contact information such as email addresses and telephone numbers;

E. billing address and shipping address;

F. financial information such as credit/debit card numbers (processed securely by our payment processor);

G. IP address and device information (automatically collected);

H. browsing behavior and website usage data (automatically collected);

I. a list of URLs starting with a referring site, your activity on this Website, and the site you exit to (automatically collected);

in each case, in accordance with this privacy policy.

How We Collect Data

  1. We collect Data in the following ways:

A. data is given to us by you; and

B. data is collected automatically.

Data That Is Given to Us by You

  1. Circular Concierge Ltd will collect your Data in a number of ways, for example:

A. when you contact us through the Website, by telephone, post, email or through any other means;

B. when you register with us and set up an account to receive our products/services;

C. when you complete surveys that we use for research purposes (although you are not obliged to respond to them);

D. when you enter a competition or promotion through a social media channel;

E. when you make payments to us, through this Website or otherwise;

F. when you elect to receive marketing communications from us;

G. when you use our services;

H. in each case, in accordance with this privacy policy.

Data That Is Collected Automatically

  1. To the extent that you access the Website, we will collect your Data automatically, for example:

A. we automatically collect some information about your visit to the Website. This information helps us to make improvements to Website content and navigation, and includes your IP address, device type, browser type, the date, times and frequency with which you access the Website and the way you use and interact with its content.

B. we will collect your Data automatically via cookies, in line with the cookie settings on your browser. For more information about cookies, and how we use them on the Website, see the section below, headed "Cookies".

Our Use of Data

  1. Any or all of the above Data may be required by us from time to time in order to provide you with the best possible service and experience when using our Website. Specifically, Data may be used by us for the following reasons:

A. internal record keeping;

B. improvement of our products/services;

C. transmission by email of marketing materials that may be of interest to you (with your consent where required);

D. contact for market research purposes which may be done using email, telephone, or mail. Such information may be used to customize or update the Website;

E. processing and fulfilling your orders and bookings;

F. customer service and support;

G. fraud prevention and security;

H. in each case, in accordance with this privacy policy.

  1. We may use your Data for the above purposes if we deem it necessary to do so for our legitimate business interests. If you are a California resident or resident of another state with applicable privacy rights, you have specific rights regarding your personal information (see the section headed "Your Privacy Rights" below).

Legal Basis for Processing

  1. We process your personal data based on one or more of the following legal grounds:

A. Contractual Necessity – where processing is necessary for the performance of a contract with you, or to take steps at your request before entering into a contract. Examples include:

  • Creating and managing your account
  • Processing bookings and payments
  • Providing customer service and support

B. Legitimate Interests – where we have a legitimate business interest in using your data and this interest is not overridden by your rights and freedoms. Examples include:

  • Improving and securing our Website and services
  • Preventing fraud or misuse
  • Understanding how users interact with our platform
  • Internal analytics and business operations

C. Consent – where you have provided clear and informed consent for specific purposes. Examples include:

  • Receiving marketing communications
  • Participating in surveys or promotions
  • Use of certain cookies

You can withdraw your consent at any time by contacting us at support@cicon.app.

D. Legal Obligations – where we are required to process your data to comply with legal or regulatory obligations. Examples include:

  • Retaining payment records for tax and accounting purposes
  • Complying with lawful requests from public authorities
  • Responding to subpoenas or court orders

Marketing Communications

  1. For the delivery of marketing communications to you via email, we will need your consent. We will provide you with the opportunity to opt-in to receiving such communications.

  2. You have the right to withdraw consent to marketing communications at any time. To unsubscribe, you may:

  • Click the "unsubscribe" link in any marketing email we send you
  • Contact us at support@cicon.app
  • Adjust your communication preferences in your account settings

Who We Share Data With

  1. We may share your Data with the following categories of recipients for the following reasons:

A. Service providers and business partners – To help us provide, improve, and secure our services;

B. Payment processors – To process your payments and handle refunds (such as Stripe);

C. Shipping and logistics providers – To fulfill and deliver your orders (such as Royal Mail or other carriers);

D. Communication service providers – To send notifications and updates (such as Twilio);

E. Cloud infrastructure providers – To host and maintain our systems (such as AWS);

F. Professional advisors – To obtain legal, accounting, or other professional advice;

G. Law enforcement and regulatory authorities – When required by law or to protect our rights;

H. Business transferees – In the event of a merger, acquisition, or sale of assets.

Third-Party Service Providers

  1. We use third-party service providers to help us operate our business and provide services to you. These providers include:

These service providers are contractually required to protect your data and use it only for the purposes we specify.

International Data Transfers

  1. As a company based in the United Kingdom, your personal information may be transferred to and processed in countries outside the United States, including the UK and other jurisdictions where our service providers operate.

  2. When we transfer your data internationally, we implement appropriate safeguards, such as:

  • Standard contractual clauses
  • Ensuring recipients are located in jurisdictions with adequate data protection laws
  • Other legally recognized transfer mechanisms

Keeping Data Secure

  1. We use technical and organizational measures to safeguard your Data, for example:

A. access to your account is controlled by a password and a username that is unique to you;

B. we store your Data on secure servers;

C. payment details are encrypted using SSL/TLS technology (typically you will see a lock icon or "https" in your browser when we use this technology);

D. regular security assessments and updates;

E. employee training on data protection;

F. access controls limiting who can view your data.

  1. If you suspect any misuse or loss or unauthorized access to your Data, please let us know immediately by contacting us via this email address: support@cicon.app.

  2. In the event of a data breach that affects your personal information, we will:

A. Assess the nature and severity of the breach, including the type of data affected and the risk to your rights;

B. Notify affected users via email without unreasonable delay where legally required;

C. Notify relevant regulatory authorities as required by applicable law;

D. Keep a record of any personal data breaches;

E. Take appropriate remedial actions to mitigate any harm caused and to reduce the risk of future incidents.

Data Retention

  1. Circular Concierge Ltd retains your Data for the following durations:

A. Account information: We retain your account information for as long as your account remains active, plus 24 months after your last login or interaction. This enables us to offer seamless service if you return and helps us understand usage patterns to improve our offerings.

B. Booking and transaction data: We retain booking and transaction information for up to 7 years from the end of the financial year in which a transaction occurred. This duration reflects our legal obligations under tax and accounting laws. It also supports fraud prevention, security, and the handling of potential disputes or refunds.

C. Payment information: We do not store full card details. Where necessary (e.g., for recurring services), payment data is stored securely by our payment processor in accordance with PCI-DSS standards and retained until the service is terminated or consent is withdrawn.

D. Communication records: We retain customer service communications (e.g., support emails or chat transcripts) for 24 months to improve service quality and for internal training.

E. Marketing preferences and data: We retain marketing consent and preferences for 36 months from your last interaction (e.g., clicking an email, visiting the site). You may withdraw consent at any time via the unsubscribe link or by contacting us.

F. Website usage and analytics data: We retain anonymized usage and analytics data for 24 months to understand how visitors interact with our Website and improve user experience. This data does not identify individual users.

  1. After these retention periods expire, your personal data will be either:
  • Anonymized so that it can no longer be associated with you, or
  • Permanently deleted or destroyed in a secure manner, or
  • Archived with restricted access if required to meet legal obligations.
  1. Exceptions to these periods may apply where:
  • Retention is required to comply with legal or regulatory obligations
  • There is an active dispute, investigation, or legal claim
  • You have explicitly asked us to retain data (e.g., for ongoing service use)

Your Privacy Rights

  1. Depending on your state of residence, you may have the following rights regarding your personal information:

Rights Under California Law (CCPA/CPRA)

If you are a California resident, you have the right to:

A. Right to Know: Request that we disclose what personal information we collect, use, disclose, and sell about you.

B. Right to Delete: Request deletion of your personal information that we have collected from you, subject to certain exceptions.

C. Right to Correct: Request correction of inaccurate personal information we maintain about you.

D. Right to Opt-Out of Sale/Sharing: We do not sell your personal information. If this changes, we will provide you with the right to opt-out.

E. Right to Limit Use of Sensitive Personal Information: We do not use or disclose sensitive personal information for purposes other than those permitted without an opportunity to limit such use.

F. Right to Non-Discrimination: We will not discriminate against you for exercising any of your privacy rights.

Rights Under Other State Laws

If you reside in Virginia, Colorado, Connecticut, Utah, or other states with comprehensive privacy laws, you may have similar rights including:

  • Right to access your personal data
  • Right to correct inaccuracies in your personal data
  • Right to delete your personal data
  • Right to data portability
  • Right to opt out of targeted advertising
  • Right to opt out of profiling in furtherance of decisions that produce legal or similarly significant effects

  1. To exercise any of these rights, please contact us at support@cicon.app. We will respond to your request within the timeframe required by applicable law (typically within 45 days, with a possible extension of an additional 45 days when reasonably necessary).

  2. You may designate an authorized agent to make a request on your behalf. We may require verification of your identity and the agent's authority to act on your behalf.

Withdrawing Consent

  1. Where we rely on your consent to process your personal information, you have the right to withdraw that consent at any time by contacting us at support@cicon.app.

  2. Withdrawing consent will not affect the lawfulness of any processing carried out before your withdrawal and may impact our ability to deliver certain services.

Do Not Track Signals

  1. Some web browsers have a "Do Not Track" feature that signals to websites you visit that you do not want to have your online activity tracked. Our Website does not currently respond to Do Not Track signals.

Children's Privacy

  1. Our Website and services are not directed to children under the age of 13 (or 16 in some jurisdictions). We do not knowingly collect personal information from children. If you believe we have collected information from a child, please contact us immediately at support@cicon.app and we will take steps to delete such information.

Links to Other Websites

  1. This Website may, from time to time, provide links to other websites. We have no control over such websites and are not responsible for the content of these websites. This privacy policy does not extend to your use of such websites. You are advised to read the privacy policy or statement of other websites prior to using them.

Changes of Business Ownership and Control

  1. Circular Concierge Ltd may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of Circular Concierge Ltd. Data provided by Users will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this privacy policy, be permitted to use the Data for the purposes for which it was originally supplied to us.

  2. We may also disclose Data to a prospective purchaser of our business or any part of it.

  3. In the above instances, we will take steps with the aim of ensuring your privacy is protected and will provide notice as required by applicable law.

Cookies

  1. This Website may place and access certain Cookies on your computer. Circular Concierge Ltd uses Cookies to improve your experience of using the Website and to improve our range of services. Circular Concierge Ltd has carefully chosen these Cookies and has taken steps to ensure that your privacy is protected and respected at all times.

  2. Before the Website places Cookies on your computer, you will be presented with a message requesting your consent to set those Cookies. By giving your consent to the placing of Cookies, you are enabling Circular Concierge Ltd to provide a better experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of the Website may not function fully or as intended.

  3. This Website may place the following types of Cookies:

Strictly Necessary Cookies

These are cookies that are required for the operation of our Website. They include, for example, cookies that enable you to log into secure areas of our Website, use a shopping cart or make use of e-billing services.

Analytical/Performance Cookies

They allow us to recognize and count the number of visitors and to see how visitors move around our Website when they are using it. This helps us to improve the way our Website works, for example, by ensuring that users are finding what they are looking for easily.

Functionality Cookies

These are used to recognize you when you return to our Website. This enables us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

Targeting Cookies

These cookies record your visit to our Website, the pages you have visited and the links you have followed. We will use this information to make our Website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

  1. You can manage your cookie preferences through your browser settings. For more information about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org.

California Shine the Light Law

  1. California residents may request information about our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us at support@cicon.app.

General

  1. You may not transfer any of your rights under this privacy policy to any other person. We may transfer our rights under this privacy policy where we reasonably believe your rights will not be affected.

  2. If any court or competent authority finds that any provision of this privacy policy (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this privacy policy will not be affected.

  3. Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.

Governing Law

  1. For US residents: This privacy policy will be governed by and interpreted according to the laws of the State of [Your State], without regard to its conflict of law provisions. Any disputes will be subject to the jurisdiction of the courts of [Your State] or, where applicable, resolved through binding arbitration as set forth in our Terms and Conditions.

Changes to This Privacy Policy

  1. Circular Concierge Ltd reserves the right to change this privacy policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the Website and you are deemed to have accepted the terms of the privacy policy on your first use of the Website following the alterations.

  2. We will provide notice of material changes as required by applicable law, which may include posting a notice on our Website or sending you an email.

Contact Us

  1. If you have any questions about this privacy policy or our privacy practices, please contact us:

Email: support@cicon.app

Address: Circular Concierge Ltd
30 Greyhound Road
London, N17 6XW
United Kingdom

Last Updated: 8th December 2025