Privacy Policy

1. Who We Are

CIRQL is a live streaming and social discovery platform operated by CIRQL Ltd, a company incorporated in England and Wales. References to “CIRQL”, “we”, “us” or “our” in this policy refer to CIRQL Ltd.

We are committed to protecting the privacy of everyone who uses our platform. This Privacy Policy explains what personal data we collect, how we use it, and your rights in relation to it. It applies to all users of the CIRQL mobile application and website.
If you have any questions about this policy, you can contact us at: privacy@cirql.uk

2. What Personal Data We Collect

We collect the following categories of personal data:

  • Account information: name, email address, username, profile photo, and date of birth when you register
  • Location data: your real-time and approximate location when you use the map and live streaming features of the app
  • Content data: video, audio, and images from live streams and highlights that you choose to broadcast or upload
  • Usage data: how you interact with the app, including streams you watch, societies or creators you follow, and features you use
  • Device data: device type, operating system, IP address, and unique device identifiers
  • Communications: messages or reports you send to us

3. How We Use Your Personal Data

  • We use your personal data for the following purposes:
  • To operate and provide the CIRQL platform and its features
  • To display your live streams and content on the map to nearby users
  • To send you push notifications about activity from accounts you follow
  • To enforce these Terms and our Community Guidelines, including content moderation
  • To improve the platform based on how it is used
  • To communicate with you about your account or our service
  • To comply with our legal obligations

4. Our Lawful Basis for Processing

Under UK GDPR, we rely on the following lawful bases:

  • Contract: processing necessary to provide the service you have signed up for
  • Legitimate interests: processing necessary for the operation of a live social discovery platform, including real-time location display, content moderation, and safety measures. We have assessed that these interests are not overridden by your rights and freedoms
  • Legal obligation: where we are required by law to process your data
  • Consent: where we have specifically asked for your consent, such as for optional notifications

5. User Generated Content and Live Streams

When you broadcast a live stream on CIRQL, your stream will be visible to other users on the map in real time. Live streams may also be saved as replays that remain accessible to other users for a defined period after the stream ends.

You should be aware that your live stream may incidentally capture other individuals who have not consented to being filmed. CIRQL operates under a legitimate interests basis for this incidental capture, consistent with the practices of all major live streaming platforms. However, you remain personally responsible for the content of your broadcasts.

If you appear in someone else’s stream and wish to request its removal, you can report the content using the in-app reporting function or by contacting us at privacy@cirql.uk. We will review all takedown requests within 48 hours.

6. Children and Minors

CIRQL is not intended for use by anyone under the age of 18. We do not knowingly collect personal data from minors. If you believe a minor is using our platform, please contact us at privacy@cirql.uk.

Our content moderation system includes automated detection of content involving minors. Any stream flagged for this reason will be terminated immediately and reviewed by our moderation team.

7. How Long We Keep Your Data

We retain your account data for as long as your account is active. If you delete your account, we will delete your personal data within 30 days, except where we are required to retain it by law.

Replay content is retained for 48 hours after a stream ends, after which it is deleted from our servers. Highlight clips saved by creators are retained until the creator deletes them or their account is closed.

8. Sharing Your Data

We do not sell your personal data to third parties. We share your data only in the following circumstances:

  • With our service providers who assist us in operating the platform, including cloud hosting, content moderation, and analytics providers, all of whom are bound by data processing agreements
  • With law enforcement or regulatory authorities where required by law
  • With any successor business in the event of a merger, acquisition, or sale of assets

9. Your Rights

Under UK GDPR you have the following rights in relation to your personal data:

  • The right to access the personal data we hold about you
  • The right to correct inaccurate personal data
  • The right to request deletion of your personal data
  • The right to object to or restrict our processing of your data
  • The right to data portability
  • The right to withdraw consent where our processing is based on consent
  • To exercise any of these rights, please contact us at privacy@cirql.uk. We will respond within 30 days.

10. Cookies and Tracking

Our mobile application does not use browser cookies. We may use device identifiers and analytics tools to understand how the app is used. You can limit this through your device settings.

11. International Transfers

Your data may be processed outside the UK by our service providers. Where this occurs, we ensure appropriate safeguards are in place, including standard contractual clauses approved by the UK ICO.

12. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes via the app or by email. Continued use of CIRQL after a policy update constitutes acceptance of the revised policy.