Privacy Policy

1 Definitions

• Personal Information means information that identifies you, relates to you, describes you, or can reasonably be linked to you (for example: name, email, phone number, photos, device identifiers, or account activity).
• Service Providers (also called "processors" or "sub-processors") are companies we use to help operate CircleMatch (for example: hosting, SMS delivery, payments, and app reliability services). They may process Personal Information only on our instructions and only to provide services to CircleMatch.

2 Who We Are and Who This Is For

CircleMatch is intended for adults 18 years of age or older. We do not knowingly collect Personal Information from anyone under 18. If you believe a minor has provided information, contact us so we can delete it.

Controller/Operator: Innovative Technology Enterprise Strategic Solutions (iTESS), LLC

Business Address: 11808 Edmond Woods Way, Bowie, Maryland 20721, United States

3 Information We Collect

We collect information in three ways: (A) information you provide, (B) information collected automatically, and (C) information from other users/your Circle.

A) Information You Provide

Account & Contact Information

• Name (or display name/username)
• Email address
• Phone number (for verification, account security, and Circle invites)
• Date of birth or age confirmation (18+)

Profile Information

• Photos you upload
• City/region and other profile fields you choose to complete
• Compatibility and lifestyle questionnaire answers
• Preferences and "what you're looking for" selections
• Bio text or other content you add to your profile

Circle of Trust Information

• Names and contact details (phone/email) of Circle members you invite
• Circle membership settings
• Circle actions: approvals/declines, feedback (where enabled), and timestamps

Communications & Support

• Messages or content you send in-app (if/when messaging is enabled)
• Reports you submit, support requests, and related correspondence

Payment Information (If Applicable)

If CircleMatch offers paid features, purchases are processed by third-party payment processors. We receive records such as plan type, transaction date/time, and payment status. We do not store full card numbers.

B) Information We Collect Automatically

Device & App Activity

• Device type, operating system, app version
• Browser type (web), language settings
• App events (feature usage, screens viewed), timestamps
• Diagnostic data (crash logs, performance metrics)

Network & Location

• IP address
• Approximate location inferred from IP
• If you enable it, precise device location (you can disable this in device settings)

Cookies (Web)

We may use cookies or similar technologies for:

• Login/session management
• Security and fraud prevention
• Performance measurement and basic analytics

C) Information From Other Users / Your Circle

Because CircleMatch is social-by-design, we process:

• Circle member decisions and feedback (as permitted by your settings)
• Reports from other users about safety or policy violations
• Interaction signals (e.g., match approvals, invites, acceptances)

4 How We Use Your Information

A) Provide and Maintain the Service

• Create and manage your account
• Verify phone/email and secure logins
• Build your profile and enable matching/compatibility features
• Send and manage Circle invitations
• Display and manage Circle reviews/approvals
• Provide customer support

B) Safety, Integrity, and Security

• Detect, prevent, and investigate fraud/spam/abuse
• Enforce our Terms, community guidelines, and trust & safety rules
• Secure our systems and users

C) Service Communications (Not Third-Party Marketing)

We may send service messages by email or SMS such as:

• Verification codes and login alerts
• Circle invitations and Circle activity notifications
• Account/security updates and essential service notices

D) Improve and Develop CircleMatch

• Debug, troubleshoot, and improve performance
• Understand feature usage in aggregated form
• Run internal testing and quality assurance

5 Text Messages (SMS) and Consent

If you provide your phone number, CircleMatch may send SMS messages for:

• Account verification and security
• Circle invitations
• Critical account notifications (where enabled)

Where required, we obtain consent through clear disclosures during onboarding or feature use. You can opt out by replying STOP (and reply HELP for assistance). Message and data rates may apply.

6 Sharing of Information

A) No Sale / No Third-Party Marketing Sharing

B) Service Providers (Limited Sharing to Run the App)

We may share limited information with vetted Service Providers who help us operate CircleMatch (e.g., cloud hosting, SMS delivery, fraud prevention, customer support tools, app performance monitoring, and payment processing). These providers are contractually restricted to:

• Use data only to provide services to CircleMatch
• Keep it confidential and secure
• Not sell it or use it for their own marketing

C) Legal and Safety Disclosures

We may disclose information if required to comply with law, legal process, valid government requests, or to protect rights, safety, and security (for example: investigating fraud or abuse).

D) Business Transfers

If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, or sale of assets, information may be transferred as part of that transaction. We will provide notice where required.

7 SDKs and Service Providers We Use

Cloud Hosting & Infrastructure

Amazon Web Services (AWS) – hosting, databases, storage, security logging/monitoring.

SMS / Phone Verification

Twilio Verify / Twilio Messaging – phone verification (one-time codes), Circle invitation SMS, and account/security SMS.

App Reliability & Analytics (Performance Only)

Firebase (Google) – may include services such as Crashlytics (crash reporting), Analytics (app usage metrics), Cloud Messaging (push notifications), Remote Config (feature toggles), and/or Authentication (if enabled).

Note: We configure these tools for product performance and reliability. We do not allow them to use your data for their own advertising purposes.

Payments (If Applicable)

Stripe – payment processing for subscriptions, tokens/credits, or other paid features. Stripe receives payment details; CircleMatch does not store full card numbers.

Platform Providers

Apple and Google – may process information necessary for app distribution, device services, and sign-in flows where enabled (e.g., Sign in with Apple / Google Sign-In).

8 App Tracking and Advertising

9 Your Choices, Rights, and Controls

A) Access, Correction, and Portability

You can review and update key account/profile information in the app settings. You may also request access to certain information we hold about you by contacting us.

B) Communication Preferences

• Essential service messages (security, verification, system notices) may not be fully optional.
• Where available, you can opt out of non-essential messages.
• For SMS (where enabled): reply STOP to opt out and HELP for assistance.

C) Location Permissions

You can disable precise location access in your device settings.

D) Delete Your Account and Data

CircleMatch provides:

1. In-app account deletion pathway, and
2. A web-based deletion request link: https://circlematch.ai/delete-account

When users request deletion, we delete your account and associated Personal Information within a reasonable period, subject to limited exceptions described in "Data Retention."

10 Data Retention

We retain Personal Information only as long as necessary to:

• Provide the service
• Maintain security and prevent fraud/abuse
• Comply with legal obligations
• Resolve disputes and enforce agreements

Deletion exceptions: We may retain limited information (e.g., audit logs, transaction records, abuse-prevention records) if required by law or for legitimate security and fraud-prevention purposes.

11 Security

We use reasonable administrative, technical, and physical safeguards designed to protect your information, including access controls, encryption in transit, monitoring, and secure vendor management. No method of transmission or storage is completely secure—please use caution when sharing information.

12 Data About Circle Members You Invite

If you invite a Circle member, you confirm you have permission to provide their contact details for the purpose of sending the invite and enabling CircleMatch functionality. We use that contact information only to deliver invitations and enable Circle participation—not for third-party marketing.

13 U.S. State Privacy Rights

Depending on where you live, you may have rights such as:

• Request access to Personal Information we hold about you
• Request correction of inaccurate information
• Request deletion (subject to legal/security exceptions)
• Appeal certain decisions (where required)

To exercise a privacy right, contact us at the email below. We may need to verify your identity before fulfilling a request.

14 International Users

If you access CircleMatch from outside the United States, your information may be transferred to and processed in the United States or other jurisdictions where our Service Providers operate. Those jurisdictions may have different privacy laws than your home country.

15 Third-Party Links and Services

CircleMatch may link to third-party websites or services. Their privacy practices are governed by their own policies, not ours.

16 Changes to This Privacy Policy

We may update this Privacy Policy periodically. We will revise the Effective Date and, when appropriate, provide additional notice in the app or on our website.

17 Contact Us

Privacy Contact: support@circlematch.ai

Support Contact: support@circlematch.ai

Mailing Address: 11808 Edmond Woods Way, Bowie, Maryland 20721, United States