This privacy policy (“Privacy Policy”) sets out the privacy practices of thecirclefinance.com (“Website”). Generally, you may visit the Website without providing personal information about yourself. However, there are times when we may need to obtain personal information from you in order to provide certain services, products, or communications with you. The purpose of this Privacy Policy is to help you understand what information we collect as well as how we use and safeguard the information you provide to us on our Website or through other means of communication with us including our surveys. By interacting with this Website, you agree that your visit to our Website and any dispute over our online privacy practices, is governed by this Privacy Policy.

Information We Collect

Personal Information You Provide To Us Or Ask A Third Party To Provide Us:

• We may collect personal information, including your name, cell phone number, email address, and certain demographic data, when you choose to voluntarily provide to us by subscribing to a newsletter, making inquiries regarding our products or services, requesting news from us, participating in surveys and the results of the surveys, reporting any issues you have found with our Website, participating in a promotional offer, providing us with feedback on our Website, or otherwise interacting with us.


• We do not knowingly collect, use, or disclose personal information from children under the age of 16. If we find we have collected any information regarding a child, we will immediately delete the same. By using our Website, you represent that you are at least 16 years of age.


• When we provide you the opportunity to engage in public actions such as comment on articles on the Website that are designed to be visible to other users, including comments, reviews, ratings or any other items that you submit for publication, then the information disclosed in your public activities, along with your name, image or photo, becomes public and may be used for online and offline promotional or commercial uses in any and all media. If you choose to engage in public actions, you should be aware that any personal information you submit can be read, collected, and used by other users of these areas. We are not responsible for the personally identifiable information you choose to submit in the course of your public actions, and we have no responsibility to publish, take down, remove, or edit any of your public postings or submissions.

Non-Personal Information Collected Using Technology:

• When you access and browse our Website, generally we do not request any personally identifiable information. However, we may collect, and track information provided to us by your device, including the website you came from, browser type, unique device identifiers, IP address, domain name, geolocation information, time and date of access and other information that does not personally identify you. We may use this information alone or together with your personal information to customize content and presentation on our Website. Non-personal information that we collect may be combined with other information about you.


• We may collect non-personal information about you through cookies, pixel tags, web beacons and similar technologies. Cookies are small strings of text sent by the Website to your browser which are then stored by your browser on your computer’s hard drive.


• Our advertisers may also use cookies and other technology to track and collect non-personal information about you when you click through the advertisement to their website. We are not responsible for their privacy practices.


• Most web browsers automatically accept cookies, but it is possible to change your browser setup to allow you to control whether you will accept cookies, reject cookies, or to notify you each time a cookie is sent to you. If your browser is set to reject cookies, you may not be able to use or access all or a portion of our Website or features or may not receive personalization on the Website. In addition, advertisers may not recognize you when you return to their Website. The “Help” section of your browser will tell you how to prevent your browser from accepting cookies.


• We use various ad services provided by Google that connects the activity on our Website with their advertising network and they may use cookies that collects information regarding certain patterns in your browsing history. To opt-out of this tracking, please see https://support.google.com/ads/answer/2662922?hl=en. We also participate in all of Google’s Analytics Advertising. This includes: (i) Remarketing with Google Analytics; (ii) Google Display Network Impression Reporting; (iii) Google controlled Campaign Manager integration; and (iv) Google Analytics Demographics and Interest Reporting. Google uses cookies to track activity performed by Google Analytics and its AdWords or DoubleClick cookie. To opt-out please see https://tools.google.com/dlpage/gaoptout/. We also use Google Analytics which is an analysis service. Google utilizes the data collected through its cookies to track and examine the use of this site, to prepare reports on its activities, and to share them with other Google services. You may opt-out of the Google Analytics service using Google’s Browser Add-on here https://tools.google.com/dlpage/gaoptout/.

How We Use Your Information

• We collect, retain and use information you provide us for to: correspond with you regarding our Website or services; inform you of developments in our company or with our services that we believe may be of interest to you; We may customize your use of the Website’s services; send you newsletters or news alerts; monitor Website traffic patterns and Website usage; comply with applicable laws; enforce our Terms of Use or other agreements; maintain or administer the services, perform business analyses or for other internal purposes to improve the quality of our business, the Website and other products and services we offer; and protect the rights, property or safety of the Website, our users and others.


• The information, including the personal information, you provide to us may be used for any purpose we deem appropriate and may be given or disclosed to our affiliates, partners, vendors, advertisers, licensees and third parties. You acknowledge that you understand when you disclose personal information (name, email address, zip code) in connection with your use of our services, such information can be monitored, collected and used by us or others and may result in unsolicited messages from other users or third parties.


• We may use demographic and preference information to provide advertising on the Website to target the users for whom they are most pertinent. This means users may see advertising that is most likely to interest them, and many advertisers send their messages to people who are most likely to be receptive, improving both your experience and the effectiveness of the advertising.


• We may use your information to show you relevant ads both on our services and elsewhere or measure the effectiveness of ads. To learn more about how you can opt out of interest-based advertising, please visit www.networkadvertising.org

How We Disclose Your Information

• We may provide your information, including your personal information, to third parties, such as service providers, vendors, and advertisers, for a variety of purposes, including, without limitation, for direct marketing purposes. We reserve the right to disclose to third parties all of the information that we collect online about you and other visitors.


• We may share in aggregate, statistical from non-personal information regarding the visitors to our Website, traffic patterns and Website usage with our affiliates, investors, advertisers or other third parties.


• We may disclose information we maintain when required to do so by law or may disclose such information in response to a request from a law enforcement agency or authority, subpoena, court order or legal process, or to establish or exercise our legal rights or defend against legal claims.


• We may share information with third parties in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of the Terms of Use or as otherwise required by law.


• If we sell, buy, or merge with other companies or businesses. In such transactions, we may include your information among the transferred assets.


• We share your information with third party advertising companies to target and serve some of the advertisements that appear on our Website, and these companies likewise may use their own cookies, web beacons and similar technologies to collect information from users of our Website. These companies may use that information, sometimes in conjunction with similar information gathered from other websites, to deliver advertisements on this Website, tailored to match the interests of consumers. The collection and use of information by these companies is governed by the relevant third party’s privacy policy and is not covered by our privacy policy. If you would like information on how to opt-out of these information collection practices, please visit http://www.networkadvertising.org/choices/.

Links to Third Party Websites

Our Website may offer links to other websites, including links embedded in advertisements and links to various news sources that are not under our control. Such links to other websites may have information policies and practices different from ours. We do not own or control such companies and websites and are not responsible for the privacy policies or practices or the content of such websites.

How We Protect Your Information

We use reasonable industry-accepted technology and controls to protect your data from disclosure to unauthorized third parties. Although these measures have been found by our industry to be effective, use of the Internet and computer systems remain vulnerable to unauthorized access. Thus, we do not guarantee that all information you provide to us will not be accessed by unauthorized persons. We are not responsible for third party conduct outside of our control.

Changes to This Privacy Policy

This Privacy Policy may be changed from time to time. Any changes will be posted on this page. Any revised Privacy Policy will apply only to information collected after the effective date of such revised Privacy Policy, and not to information collected under any earlier Privacy Policy.

Opting Out

If, at any time, you prefer not to receive email marketing information, surveys, or newsletters from us, simply follow the unsubscribe link at the bottom of each email or email us at [email protected].

California Resident rights.

Shine the Light: One time a California resident can ask us to disclose what information we received or shared about them and from what category of third-parties this was done for marketing purposes. California residents also have the right to know we do not respond to do not track signals or cookies. Please make this request by calling us at 866-259-3470

California Consumer Protection Act of 2018 and California Privacy Rights Act of 2020: This Privacy Notice for California Residents supplements the information contained in our primary Privacy Notice and applies solely to all visitors, users, and others who reside in the State of California ("consumers" or "you"). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and as amended by the California Privacy Rights Act (“CPRA”). Any terms defined in the CCPA and CPRA have the same meaning when used in this Notice. The CCPA and CPRA are collectively referred to as the “CCPA” for purposes of this Notice.

California Resident Privacy Rights.

(A) Right to Know About Personal Information Collected, Disclosed, or Sold and the Right to Correct the same.

You have the right to request that we advise you what Personal Information we collect, use, disclose, and sell that belongs to you. Submit a verifiable consumer request using the link or call toll free 866-259-3470 to get the specific Personal Information we have collected about you. We are required to verify that you are the same consumer with whom we have the information in our systems. To verify your identity, we will require that you fill out a form in its entirety which includes your name, address, email address and other Personal Information we have collected. We may have collected several types of information about you when you visit and use our Website; examples include Personal Information, demographic information, behavioral information, and indirect information. Sometimes we collect combinations of these types of information. Categories of Sources from which we collected Personal Information:

1. Information collected directly and indirectly from you.
2. Information you provide us when you enter promotions or sweepstakes offered by us or our clients including networks and advertisers.
3. Information you provide us through telephone and web-based surveys, customer service correspondence, and general feedback.
4. Information we received directly or indirectly from our clients.
5. Analytics companies who provide demographic information such as gender, zip code, or any information that is not tied to your Personal Information. In addition, we may receive information about you from other online or offline sources, including third parties from whom we validate consumer self-reported information, and verify information we already have about you. This helps us to update, expand and analyze our records and provide products and services that may be of interest to you.
6. We also collect information provided by Service Providers and other third parties as set out in our main Privacy Policy, our advertisers, ad networks and third-party technology companies.

We have disclosed, shared and/or received compensation for our disclosure of Personal Information for the following commercial purposes in the preceding 12 months:

1. To obtain payment for our services or products.
2. To allow a third-party to market their products or services to you.
3. To provide you with information, products or services or resolve your questions or request to opt-out of marketing.
4. To provide you with marketing about our clients’ services that may be of interest to you.
5. To carry out our obligations and enforce our rights arising from any contracts entered into.
6. To improve our products and services, and present its contents to you including testing, research, analysis, and product development.
7. To personalize your experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads via email or text message (with your consent, where required by law).
8. To maintain the safety, security, and integrity of our platforms as well as products and services, databases and other technology assets, and business.
9. To respond to government or law enforcement requests and as required by applicable law, court order, or governmental regulations.
10. To evaluate or conduct a merger, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our business or assets.
11. As described to you when collecting your Personal Information or as otherwise set forth in the CCPA.

We have disclosed Personal Information to the following categories of third-parties:

1. Our affiliated entities.
2. Our Service Providers.
3. Data aggregators.
4. Advertisers and Ad Networks.
5. Third parties to whom you or your agents authorize us to disclose your Personal Information in connection with products or services we and/or third parties provide to you.
   We do not collect, distribute, share, or sell the Personal Information of anyone under the age of 16.

(B) Right to Request Deletion of Personal Information.

You have a right to request the deletion of your Personal Information if we have collected or maintained it in the past 12 months by submitting a verifiable consumer request to delete your information by emailing us or submitting your request by clicking here or call toll free 866-259-3470. Once we receive and confirm your verifiable consumer request, we will disclose to you the categories of Personal Information we collected about you; the categories of sources for the Personal Information we collected about you; Our business or commercial purpose for collecting or selling that Personal Information; the categories of third parties with whom we shared that Personal Information.

(C) Right to Opt-Out of the Sale of Personal Information or Use of GPC Signal.

Opt-Out of Sale of Personal Information. You have the right to opt-out of any sale of your personal information by a business by clicking here or call toll free at 866-259-3470.

Opt-Out Preference Signal (Global Privacy Control) You may use an Opt-Out Preference Signal, such as the Global Privacy Control (GPC), to opt-out of the sale/sharing of your personal information. However, this technology and our use of it is not fully developed by the market. Our database containing your information may not be linked to your browser identification and because your request to opt-out of sale/sharing will be linked to your browser identifier only and not linked to any account or database information as the connection between your browser and our database is not known to us, we may not be able to fulfill this request.

If you would like us to make the connection between your browser and your account within our database, please call us toll free at 866-259-3470 or submit the requested form through our website portal below.

(D) Right to Non-Discrimination.

You have a right not to be discriminated for the exercise of these privacy rights conferred by the CCPA. We will not deny you goods or services, charge you different prices or rates for goods or services, or deny you discounts or other benefits; nor will we provide you a different level or quality of goods or services or recommend a different level or quality of goods or services.

(E) Authorized Agent.

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information.

(F) Limitations on Requests.

You may only make a verifiable consumer request for access twice within a twelve (12) month period and you must provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or your authorized agent; provide sufficient detail that allows us to properly understand, evaluate, and respond to you. We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

(G) Response Time and Response Format.

We will cease sharing and selling your information within 10 days of receipt of your request and make every effort to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. We provide only the twelve (12) month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons why we cannot comply with a request, if applicable. We will provide our response in a manner that is readily useable that you can give the information from one entity to another entity without hindrance.

Changes to California Resident Privacy Notice. We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will enforce the terms of the new policy going forward. You will receive no other notice than an updated posting on this page. Please check back each time you enter our Website.

Contact Information.

If you have any questions or comments about this Privacy Statement, please do not hesitate to contact us at [email protected]