Privacy policy

1Who we are

Cirklo is a location and safety app for families and groups of friends. This policy applies to the Cirklo app (Android and iPhone) and to the getcirklo.com website, together the “Service”.

The data controller is [PREENCHER: nome ou razão social] ([PREENCHER: CPF ou CNPJ]), [PREENCHER: endereço]. Our data protection officer is [PREENCHER: nome do encarregado de dados], reachable at hitalocunhadesousa@gmail.com.

2Data we collect

Data you provide

Account: first and last name, phone number, date of birth and, if you want, a profile photo.
Emergency contacts: name, phone number and relationship of up to 5 people. This is data about other people: let them know they may get a text if you trigger SOS.
Places: name, address, position and radius of the places you create, such as Home or School.
Preferences: notifications, “Do not disturb” hours, sharing per circle, place suggestions and appearance.
SOS PIN and duress PIN: stored only in encrypted form (hashed). No one, not even us, can see the numbers.

Data the app collects

Precise location, including when the app is closed, if you allow it: position, accuracy, speed and time. While you’re moving, the app records a point every few meters; when you’re still, it uses low-power location and records points from time to time; during an SOS, every 5 seconds. Without internet, points are kept on the phone for up to 7 days and sent once you’re back online.
Arrivals and departures at your circles’ places, detected by the phone itself.
Battery level, to show it on the map and alert the circle when it’s low.
Motion sensor, only for crash detection (Premium). Accelerometer data is analyzed on the phone and isn’t sent; we only record that a possible crash was detected and what happened next.
Device and app usage: operating system (Android or iPhone), model, app version, language, notification identifier, crash reports (to fix bugs) and aggregate screen usage statistics.

Data we derive from location

Stops: places where you stayed 25 minutes or more, which make up the history timeline.
Place suggestions: places you and your circle visited 3 or more times in 7 days.
Daily summary: distance traveled, number of stops and time spent moving.

Data we receive from other people and companies

From other users: when someone adds you as an emergency contact, we receive your name and phone number. When someone invites you to a circle, we only see the code used to join.
From app stores: purchases are made and billed by Google Play or the App Store. We only receive the plan, period, renewal dates and status. We have no access to your card details.

3How we use data

Purpose	Legal basis
Show your live location, history and places to your circles; send arrival, departure, check-in and low battery alerts	Performance of the contract (the terms of use) and your consent to location access, given in your phone’s permissions
SOS, crash detection and duress PIN: alert your circles and text your emergency contacts a location link	Protection of life and physical safety (vital interests) and performance of the contract
Keep records of alerts (SOS, crash and duress) for 10 years	Establishment, exercise or defense of legal claims
Login by text code, one session per account, fraud and abuse prevention	Performance of the contract and legitimate interests
Fix crashes and understand which screens are used, to improve the app	Legitimate interests
Subscriptions and plans	Performance of the contract
Data about children and teenagers	Specific consent from a parent or guardian

We don’t use your data for advertising, we don’t sell data, we don’t build advertising profiles and we don’t make automated decisions that produce legal effects on you.

4Who we share data with

With the people in your circles

Your name, photo, phone number, live location, battery, history (within the plan’s period) and arrivals and departures at that circle’s places, only in circles where your sharing is on.
With sharing off, people in that circle see “Sharing off” and don’t see your history for that period. Your location is still recorded in your account, and only you can see it.
Check-in, SOS and crash alerts appear in all your circles, including those with sharing off, because they’re meant to get you help.

With your emergency contacts

During an SOS, they get a text with a link to see your live location. The link stops working 24 hours after the alert ends.

With companies that make Cirklo work

We use service providers that process data on our behalf, under contract and only to provide the Service:

Supabase: database, login and photo storage.
Vercel: hosting for the website and for the functions that send notifications and texts.
Twilio: login and SOS text messages.
OneSignal: push notifications.
Google Firebase (Analytics and Crashlytics): screen usage statistics and app crash reports.
RevenueCat, Google and Apple: subscriptions and payments.
Google Maps, Apple Maps, Google Places and OpenStreetMap: maps, addresses and “Nearby places”. Only the requested coordinate is sent to these services, never your name.

For legal reasons or to protect people

We may share data when required by law, by court order or by a request from a competent authority, or when needed to protect someone’s life or safety.

If the company changes

If Cirklo is sold or merged, data may be transferred to the new company, which must follow this policy. We’ll let you know beforehand.

5You’re in control

Location: change the permission at any time in your phone’s settings. Without “Allow all the time”, your position only updates while the app is open.
Sharing per circle: turn it off in Profile > My location. Each circle has its own switch.
Notifications: choose what you get and your “Do not disturb” hours in Profile > Notifications.
Place suggestions: turn them off in Profile > My location.
Crash detection: turn it off in Profile > Crash detection.
Leave a circle: at any time, in Circle.
Delete your account: in Profile > Delete account, or on the Delete account page.

6How long we keep data

Data	Period
Location history, check-ins and alert list	Based on the best plan among your circles: 1 day (Free), 7 days (Plus) or 30 days (Premium). After that, it’s deleted automatically.
Points not yet sent, stored on the phone	Until they’re sent, for at most 7 days.
Stops used for place suggestions	7 days, or the plan’s period if longer. They don’t appear in the app beyond the plan’s period.
Place suggestions	24 hours on screen; the record is deleted 7 days later.
Daily summary	For as long as the account exists.
Account, photo, places, emergency contacts and preferences	For as long as the account exists, or until you delete them.
App crash reports	90 days.
Screen usage statistics	2 months.
Alert records (SOS, crash and duress), with the route during the alert	10 years, including after the account is deleted. They’re kept separate from the account and only accessed by court order or at the request of a competent authority.

7Children and teenagers

People under 18 can only join a circle with the approval of an adult guardian who is already in that circle. The approval is recorded, with the date and who approved it.
Minors can’t subscribe to plans or be circle admins.
The guardian can request access to, correction of or deletion of the minor’s data at any time at hitalocunhadesousa@gmail.com.

8Security

All communication between the app, the website and the servers is encrypted (HTTPS).
Every database query goes through access rules: a person can only read data from people who share a circle with them.
Profile photos are kept in private storage and only open through temporary links.
PINs are stored only in encrypted form. Each account is signed in on one device at a time.

No system is 100% secure. If an incident could put you at risk, we’ll notify you and the authorities as required by law.

9International transfers

Some providers store or process data outside the country where you live, including in the United States and the European Union. These transfers follow the safeguards required by data protection laws, such as standard contractual clauses.

10Your rights

Wherever you live, you can ask for:

access to your data and a copy of it (portability);
correction of incomplete or wrong data (you can change your name and photo directly in the app);
deletion of your data or your account;
information about who we share data with;
withdrawal of consent, by turning off location or sharing at any time.

European Union and United Kingdom (GDPR)

You can also ask us to restrict processing, object to processing based on legitimate interests and lodge a complaint with your country’s data protection authority.

United States (including California)

You have the right to know what data we collect, to request deletion or correction and not to be discriminated against for exercising your rights. We don’t sell or “share” personal information for cross-context behavioral advertising, so there’s nothing to opt out of.

Brazil (LGPD)

You can also ask for unnecessary data to be anonymized or blocked and lodge a complaint with the National Data Protection Authority (ANPD).

For any request, email hitalocunhadesousa@gmail.com. We reply within 15 days (or the deadline required by the law where you live) and may ask you to confirm the request is yours.

11Cookies and website

The getcirklo.com website doesn’t use tracking cookies or advertising tools. We only store one cookie with the language you chose.

12Changes to this policy

We may update this policy. If the change is important, we’ll let you know in the app before it takes effect. The date at the top shows the latest update.

13Contact us

Privacy questions: hitalocunhadesousa@gmail.com. Data protection officer: [PREENCHER: nome do encarregado de dados].