**1. Overview**

Sirkle . (“Sirkle,” “we,” “us,” and “our”) respects your privacy and is committed to protecting it through compliance with this Privacy Notice (“Privacy Notice”). This Privacy Notice describes the types of information we may collect from you when you visit the website at https://sirkle.ai/ or use the services offered there (the “Platform”), and that you may provide in electronic messages to Sirkle. It also describes our practices for collecting, using, maintaining, protecting, and disclosing that information. This Privacy Notice also explains how we use artificial intelligence (AI) to process your information, ensuring our AI practices are aligned with our commitment to your privacy.

Please read this Privacy Notice to understand our policies and practices regarding your information and how we will handle it. If you do not agree with our policies and practices, do not use the Platform. By accessing or using the Platform, you agree to this Privacy Notice.

Sirkle may change this Privacy Notice at any time, at its discretion. Your continued use of the Platform after we make changes is deemed to be acceptance of those changes, so please check the Privacy Notice periodically for updates.

This Privacy Notice is subject to and governed by the Sirkle Terms of Service (“Terms of Service”) available on the Platform. The services are part of the Platform and are described further in the Terms of Service.

**2. The Types of Information That Sirkle Collects About You and How Sirkle Collects Information About You**

Sirkle may collect two types of information from you when you visit the Platform: Personal Information and Non-Personal Information (collectively “Information”).

– **Personal Information** refers to data by which you may be personally identified, such as name, email address, employer, job title and department, telephone number, and other information listed in Section 12.
– **Non-Personal Information** means data that is about you but does not identify you specifically. If you do nothing during your visit to our Platform but browse, read pages, or view content, we will gather and store information about your visit that does not identify you personally.

We collect Information:

– Directly from you when you provide it to us.
– Through our communications with you.
– From third parties.
– Automatically as you navigate through the Platform.
– Automatically, on an aggregate level, when you utilize our services. This includes interactions with AI-powered tools and features, which are designed to respect your privacy while enhancing your experience.
– Through analytics.

**Information You Provide Directly to Sirkle:** The Information that you provide us directly through our Platform may include:

– Information that you provide when you subscribe to our services or purchase our products.
– Information you provide when you create an account on our Platform or subscribe to our mailing list.
– Information that you provide by filling in forms on our Platform.
– Information that you provide when you report a problem with our Platform. We may ask you for additional Information to resolve the problem.
– Information that you provide in connection with an inquiry you have.
– Records and copies of your correspondence (including email addresses), if you contact us.
– Your responses to surveys.
– Details of transactions you carry out through the Platform.

**Information Automatically Collected from You:** The Information that Sirkle may automatically collect and store about you when you visit the Platform may include:

– Your location;
– The Internet Protocol Address and domain name used. The Internet Protocol address is a numerical identifier assigned either to your internet service provider or directly to your computer. We use the Internet Protocol address to direct internet traffic to you;
– The type of browser and operating system you used;
– The date and time you visited the Platform;
– The web pages or services you accessed at the Platform;
– The website you visited prior to coming to the Platform; and
– Cookies, which are small text files that a web server (such as Sirkle or its chosen web hosting company server) places on a user’s computer. When accessing a cookie, the Sirkle server reads a number associated with a browser but is unable to determine any data about a user. With that number, our web server can tailor its content to the needs of the specific browser, and we can optimize the Platform for your use. You can remove or reject cookies using your browser or device settings, but in some cases, doing so may affect your ability to use our products and services.

**Google Analytics Advertising Features:** We also may have the following Google Analytics Advertising Features Implemented: Demographics and Interest Reporting, Remarketing, GDN Impression Reporting, and DoubleClick Campaign Manager. These features collect data using Google advertising cookies and anonymous identifiers. Sirkle and third-party vendors use these first-party cookies to assess the success of online marketing campaigns, inform future campaigns and improve usability on the Platform. To learn how to opt-out of the Google Analytics Advertising Features we use, please see Google Analytics’ currently available opt-outs for the web at https://tools.google.com/dlpage/gaoptout.

**3. How Sirkle Uses Information It Collects About You and the Purposes for the Collection and Use**

We use Information that we collect about you or that you provide to us, including any Personal Information, for the following purposes:

– To present our Platform and the Platform Content (as defined in the Terms of Service) to you.
– To provide you with the products or services that you request from us. For example, if you inquire regarding our services, we will use the contact information you give us to communicate with you about the services we provide.
– To provide customer support.
– To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
– To analyze how our products and services are used.
– To notify you about changes to our Platform or any products or services we offer or provide though it.
– To provide you with information regarding your account.
– To communicate with you regarding our products and services, including for marketing purposes.
– To personalize our services and advertising to you.
– To diagnose service or technical problems.
– To maintain security.
– In any other way we may describe when you provide the information.
– To fulfill any other purpose for which you provide it.
– For any other purpose with your consent.
– To develop and improve our Platform, products, and services and to develop new products and services.
– To inform and enhance the AI algorithms used in our services, ensuring they are ethical and aligned with user privacy expectations. All AI interactions are designed with the utmost regard for your privacy and data protection.

Platform statistics are compiled into traffic reports, which help Sirkle understand, anticipate, and respond to user needs. If we learn, for example, of heightened interest in certain aspects of the Sirkle website, we are likely to highlight that information on the Platform home page. This information helps us create a better overall experience for Platform users.

We will only retain your Personal Information for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements and for other purposes described in this Privacy Notice. We may retain your Personal Information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information, and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting, or other requirements. In some circumstances, you can ask us to delete your data: see your legal rights below for further information. And in some circumstances, we will anonymize your Personal Information (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

**4. How Sirkle Protects Your Information**

We have implemented measures designed to protect your Information from accidental loss and from unauthorized access, use, alteration, and disclosure. Unfortunately, the internet is not completely secure. Although we are working to protect your Information, we cannot guarantee the security of your Information either in transmission or when stored. We are not responsible for circumvention of any privacy settings or security measures contained on the Platform. We implement additional security measures for data processed by AI technologies, ensuring robust protection against unauthorized AI use or access.

**5. When Sirkle Shares Your Information**

We may use and disclose Non-Personal Information about our users without restriction. We may disclose Personal Information that we collect or you provide as described in this Privacy Notice:

– To our subsidiaries and affiliates.
– To contractors, service providers, and other third parties we use to support our business, as described further below, including third-party payment facilitators.
– To a buyer or other successor (potential or actual) in connection with a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Sirkle’s assets, including any related due diligence.
– To fulfill the purpose for which you provide it.
– For any other purpose disclosed by us when you provide the information.
– With your consent.
– To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
– To enforce or apply our Terms of Service.
– If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Sirkle or others.

Sirkle does not sell any of your Personal Information. We do not share Information processed by our AI with third parties without your explicit consent, except as necessary for providing the services or as required by law.

**6

. Third Party Payment Facilitators**

We use a third-party payment facilitator to assist us in processing your personally identifiable payment information securely. Such third-party payment facilitators’ use of your Personal Information is governed by their own privacy policies, which may or may not contain privacy protections as protective as this Privacy Notice. Purchases made through these third-party payment facilitators are subject to their terms of service and privacy policies. We encourage you to review such third-party payment facilitators’ terms of service and privacy policies before providing any Personal Information.

**7. Links to Third Party Platforms**

Sirkle may provide links to third-party websites. Sirkle does not control these third-party websites and is not responsible for their privacy practices. We encourage you to learn about the privacy practices of those third parties.

**8. Social Media Widgets**

Our Platform may include social media features, such as the Facebook button and widgets, such as the Share This button or interactive mini-programs that run on our Platform. These features may collect your IP address, which page you are visiting on our Platform, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our Platform. Your interactions with these features are governed by the privacy policy of the company providing it.

**9. Cross-Border Transfer of Data**

If you use our Platform outside of the United States, your information will be transferred to the United States. By using our Platform or providing us with your information, you consent to this transfer.

**10. Your Rights and Choices**

**10.1 Your Data Protection Rights**

Depending on where you live, you may have the following rights with respect to your Personal Information:

– **Access**: You have the right to request a copy of the Personal Information we hold about you.
– **Correction**: You have the right to request that we correct any Personal Information you believe is inaccurate. You also have the right to request that we complete the information you believe is incomplete.
– **Deletion**: You have the right to request that we delete your Personal Information, under certain conditions.
– **Object to Processing**: You have the right to object to our processing of your Personal Information, under certain conditions.
– **Restrict Processing**: You have the right to request that we restrict the processing of your Personal Information, under certain conditions.
– **Data Portability**: You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.
– **Withdraw Consent**: Where we are relying on consent to process your Personal Information, you have the right to withdraw your consent. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.
– **Automated Decision-Making**: You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us at our email: privacy@sirkle.ai.

**10.2 Marketing**

You may opt out of receiving marketing emails from us by following the instructions in those emails or by emailing us at privacy@sirkle.ai. If you opt out, we may still send you non-marketing emails, such as those about your account or our ongoing business relations.

**10.3 Cookies and Tracking Technologies**

You can set your browser to refuse all or some browser cookies or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of the Platform may be inaccessible or not function properly.

**11. Children’s Privacy**

Our Platform is not intended for children under 16 years of age. No one under age 16 may provide any information to or on the Platform. We do not knowingly collect Personal Information from children under 16. If you are under 16, do not use or provide any information on this Platform. If we learn we have collected or received Personal Information from a child under 16, we will delete that information.

12. California Privacy Rights
Under California law, California residents have certain rights regarding their Personal Information, including the rights listed below. California law requires us to identify these rights to you. Subject to some exceptions, you have:

The right to know the categories of Personal Information that we have collected and the sources from which we obtained the Information.
The right to know the business purposes we have for sharing Personal Information.
The right to know the categories of third parties with whom we have shared Personal Information.
The right to access the specific pieces of Personal Information we have collected, and the right to request the deletion of your Information.
The right to opt-out of the sale of your Personal Information, as a “sale” is defined under the California Consumer Privacy Act of 2018 (“CCPA”), and in some cases the sharing of your Personal Information. Note that Sirkle does not sell your Personal Information.
The right to correct your Personal Information.
The right to restrict processing of sensitive Personal Information, such as social security numbers, passport numbers, racial or ethnic origin, and financial account and payment card information.
Personal Information Collected
We may collect the following Personal Information about you:

Identifiers: Such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.
Personal Information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)): Such as a name, signature, address, telephone number, or credit card number.
Protected classification characteristics under California or federal law: Such as age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
Commercial Information: Such as products or Services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Internet or other similar network activity: Such as information on a consumer’s interaction with a website, application, or advertisement.
Geolocation data: Such as physical location.
Inferences drawn from other Personal Information: Such as profiles reflecting a person’s preferences.
Additional information about the categories of Personal Information collected and the categories of sources from which Personal Information is collected is in Section 2 of the Privacy Notice. The purpose for collecting the Personal Information listed above is in Section 3 of the Privacy Notice. The third parties with which Sirkle may share the Personal Information listed above is in Section 5 of this Privacy Notice. We confirm that we do not sell any Personal Information processed by AI or otherwise to third parties for their direct marketing purposes.

Exercising Your Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described in this California section, please submit your request to info@sirkle.ai.

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child.

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period. If we deny your request, we will provide reasons for the denial. You may only make a verifiable consumer request for access or data portability twice within a 12-month period.

Sirkle will not discriminate against you for exercising any of your CCPA rights.

Other California Privacy Rights
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of the Platform that are California residents to request certain information regarding Sirkle’s disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please contact Sirkle at the email address in Section 14 below.

13. Your Choices About Information
We may, from time to time, send you emails regarding new products and Services that we feel may interest you. In addition, if you indicated upon registration that you are interested in receiving offers or information from us and our partners, we may occasionally call or send you direct mail about products and Services that may be of interest to you. Only Sirkle (or agents working on behalf of Sirkle and under confidentiality agreements) will send you these solicitations, and only if you have previously indicated that you wish to receive them. If you do not want to receive solicitations from us, you can “opt-out” by accessing your account online and editing your account information to no longer receive such offers and mailings.

If you no longer wish to receive marketing or promotional communications from us, click on the “unsubscribe link” provided in such communications or send us an email to info@sirkle.ai. You can also log in to your account and change the applicable communication settings so that you no longer receive such communications.

You have the option to customize how AI interacts with your data on our Platform, including opting out of specific AI-driven features that personalize your experience.

If you opt out of receiving marketing/promotional emails, we may still send you non-promotional emails, such as emails about your accounts or our ongoing business relations. Please report your concerns about collection or use of Personal Information through the Platform to info@sirkle.ai.

14. How To Contact Us About This Privacy Notice
To ask questions about this Privacy Notice and our privacy practices, contact us at info@sirkle.ai. We welcome your questions or concerns about how we use AI in relation to your privacy. Please don’t hesitate to reach out to us at info@sirkle.ai for any AI-related privacy inquiries.

EFFECTIVE DATE: June 17, 2024

– **Biometric information**: Genetic,